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Considerations for Federal Contractors on President Biden’s EO, Effective Oct. 15, Ensuring Adequate COVID-19 Safety Protocols

On Sept. 9, 2021, President Biden issued his Executive Order on Ensuring Adequate COVID Safety Protocols for Federal Contractors (EO), mandating vaccines for all federal employees and covered federal contractor employees. Although the respective agencies are expected to promulgate guidance and rules effectuating the EO, which will become effective Oct. 15, 2021, the Safety Federal Workforce Task Force has given guidance as to protocols federal contractors should follow, building on the prior government safety protocol directive. Until federal contractors are contractually required to be vaccinated, contractors should note the following safety protocols for their employees who are not yet fully vaccinated or decline to provide information about their vaccination status.

The Task Force has advised agencies with onsite contractor employees as follows:

  • Onsite contractor employees not part of an agency testing program must provide proof of a CDC-approved negative COVID-19 test from no later than the previous three days before entry into a federal building;

  • Onsite contractor employees regularly tested pursuant to an agency testing program do not need to provide proof of a negative COVID-19 test no later than the previous three days prior to entry into a federal building, unless required to do so by the agency testing program; and

  • Federal contractor employees working on site should regularly complete virtual or in-person health checks, the information gathered from which will be used to assess the individual’s risk level and to determine whether the individual should be allowed entry to the workplace.


©2022 Greenberg Traurig, LLP. All rights reserved. National Law Review, Volume XI, Number 263

About this Author

Johnine Barnes, Greenberg Traurig Law Firm, Washington DC, Labor and Employment Litigation Attorney

Johnine P. Barnes has more than a decade of experience in litigating and defending administrative claims of harassment; retaliation and discrimination on the basis of age, race, sex and disability; wrongful discharge and breach of contract issues; and client compliance with the American with Disabilities Act, the Family and Medical Leave Act and other federal and state statutes governing employment. Johnine has counseled and represented companies, government agencies and associations on labor law issues, including the Fair Labor Standards Act, as well as analogous state...

Whitney Bly Edwards, Ph.D. Labor Lawyer Greenberg Traurig

Whitney Bly Edwards is a member of the Labor & Employment Practice in Greenberg Traurig’s Atlanta office. Prior to joining the Firm, she defended medical practitioners facing professional liability claims and represented healthcare facilities in litigation.

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