On September 9, 2021, President Biden announced OSHA is developing a rule requiring all employers with at least 100 employees to make sure their workforce is fully vaccinated or require unvaccinated workers to get a negative test at least once a week.
And in the interim, OSHA is issuing an emergency temporary standard to introduce the vaccine requirement. What actions should manufacturers with less than 100 employees take? With the Delta variant moving quickly throughout our communities, should all manufacturers require their employees to be vaccinated for COVID-19?
There are three important considerations for making this decision: the manufacturers ability to serve its customers, the manufacturers responsibility to ensure the safety of its employees, and legal considerations. Even after reviewing these issues, the approach a small manufacturer should take is different than you think.
Serving the Customer. A manufacturer must prepare for and ensure it can meet customer demands. COVID-19 infections can sideline workers and halt production. In an article published by McKinsey (April 23, 2020), their advice includes the following.
“Plant leaders can also plan their own response to risks that could directly affect operations in their facility—starting with what to do if an employee anywhere in the plant tests positive for a COVID-19 infection.” These responses might include asking the employees who are infected to not come to work and conducting internal contact tracing once a COVID-19 infection is reported. Ultimately, a manufacturer might decide to mandate vaccinations to ensure it can serve its customers.
Safety of Employees. A responsible manufacturer commits to providing a safe work environment. In a COVID-19 world, this means creating an environment that will minimize, or eliminate, if possible, the risk of catching COVID-19. OSHA issued guidance on mitigating and preventing the spread of COVID-19. Some of the recommendations are:
- Facilitate employees getting vaccinated by granting paid time off for this purpose.
- Implement physical distancing in all communal work areas for unvaccinated and otherwise at-risk workers.
- Provide workers with face masks.
- Maintain ventilation systems.
- Perform routine cleaning and disinfection.
While these measures cannot eliminate COVID-19 on the factory floor, they can go a long way in reducing the risk. Requiring vaccinations is another step an employer might take to reduce the risk of its employees becoming ill.
Legal. Beyond ensuring supply to customers and employee safety, there are legal considerations a manufacturer must reflect upon when considering mandating COVID-19 vaccinations. It is legal for employers to mandate that employees take the vaccine. In an article from CNN Politics, Wendy Parmet, a law professor and the director of Northeastern University’s Center for Health Policy and Law states
“The overall consensus is that in most situations, mandates are legally permissible. “There are some exceptions. If an employee has a disability or a sincerely held religious belief they can request to be exempt from the requirement to vaccinate.
Should small manufacturers require COVID-19 vaccinations? To serve its customers, protect its employees, and because it is legally permissible, one could conclude “yes.” But there is a different approach. Rather than mandate vaccinations, engage the workforce in creating and sustaining a safe and healthy work environment. This can be done by taking several actions.
- Educate employees on the risks of COVID-19. Present the facts about how contagious the disease is and the risks it poses to individuals. Educate the workforce on the safety of the vaccination. Engage informal leaders within the workforce to share why they have chosen to be vaccinated. Invite respected medical personnel from the community to speak to employees.
- Emphasize “why” the company exists, its purpose. Stress to employees the role each of them play in serving the customer and in taking care of their teammates. Highlight that if they are sick with COVID or infect their fellow workers they are putting their families, their livelihood, and the livelihood of their co-workers at risk.
- Provide on-site COVID-19 vaccinations. Give employees paid time off to get vaccinated and to deal with any symptoms that arise from the vaccination.
- Provide routine on-site testing for COVID-19. Make masks required personal protective equipment (PPE) in the work environment. Provide hand sanitizer or gloves. Clean and disinfect machines and common areas frequently.
- Ask employees to self-report if they have COVID-19 symptoms or if they have been in contact with anyone who has these symptoms.
Leaders should share the responsibility for ensuring customer demand is met and that employees are safe by engaging their teams in this effort. Ask employees about their concerns. Listen intently and respond accordingly. Encourage and highlight examples of desired behavior. Like most problems that occur on the shop floor, engaging those who work closest to the problem may bring the innovative solutions. The COVID-19 pandemic challenge is no different.
Making rules is easy. With COVID-19 there is plenty of justification for a small manufacturer to mandate employees be vaccinated. The hard work for leaders, however, is to empower and engage their workforce in protecting themselves and staying ready to produce for their customers.
About the Author: Mike Ungar is a Certified FocalPoint Business Coach and Trainer. He has 35 years of experience with Michelin in manufacturing and human resources. Mike is a graduate of the United States Military Academy at West Point and the Clemson MBA program.