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COVID-19 U.S. Vaccine Policy (ETS)

COVID-19 VACCINATION POLICY - U.S. CONTRACTORS (ETS)

As part of our continued commitment to protecting the health, safety and welfare of our employees, our contractors, their co-workers and their families, Staffing 360 Solutions is taking additional measures to minimize the risk of contracting and transmitting Covid-19 in the workplace.

In accordance with the Occupational Safety and Health Administration’s (OSHA’s) emergency temporary standard (ETS) for private employers with 100 or more workers, Staffing 360 Solutions is adopting this policy to comply with OSHA’s requirements, align with public health recommendations from the Centers for Disease Control and Prevention (CDC) and local health authorities, and comply with all applicable federal, state and local laws.

Compliance with this policy is a condition of your continued employment. Please read this policy carefully. This policy can be found on our websites:

https://www.monroestaffing.com/covid-19; https://www.keyresourcesinc.com/covid-19 and https://www.lighthouseprofessionalservices.com/covid-19


SCOPE

Effective January 10th, 2022 all persons in the scope of this policy are:

Staffing 360 Solutions contractors working on client sites or in Staffing 360 Solutions offices.

All persons in scope of this policy and who are hired after February 9, 2022, are required to be fully vaccinated by their first day of work or in the absence of full vaccination, submit a negative test result dated before their first day of work. This test result should not be dated more than 7 days before the start date of your assignment. After the initial test result, all persons in the scope of this policy are required to subsequent weekly testing as described in the next section.

Remote workers are subject to this policy only in the event that they visit one of our offices or a customer’s offices and/or come into physical contact with company employees, workers or customers. In this event, no matter how short the duration (e.g., one day or even just a few minutes), these workers must submit proof of full vaccination or a negative COVID-19 test dated no more than seven days prior to the date of their return to the workplace.

PROCEDURES

Persons in the scope of this policy have two options available to them:

Option 1: Provide Evidence of Full Vaccination

Unvaccinated workers are much more likely to contract and transmit COVID-19 in the workplace than vaccinated workers. 

COVID-19 vaccines have been determined to be safe and effective and provide the best possible protection against severe illness, hospitalization, and death from COVID-19.   

All contractors and their families are encouraged to get vaccinated for COVID-19 to protect themselves and others and reduce the spread of the virus.

Full vaccination status:
All persons who choose to receive a COVID-19 vaccine will need to show full vaccination status. Persons are considered fully vaccinated:

  • Two weeks (14 days) after their second dose in a 2-dose series, such as the Pfizer-BioNTech or Moderna vaccines, or
  • Two weeks (14 days) after a single-dose vaccine, such as Johnson & Johnson’s Janssen vaccine.

If you have not met these requirements, regardless of your age, you are NOT considered fully vaccinated. Booster shots and additional doses are not currently required as proof of full vaccination status.  

‍OSHA’s Vaccination and Testing ETS relies on employees and contractors providing truthful and accurate information, including, where applicable, proof of vaccination status and COVID-19 test results, to their employers, and on their employers maintaining accurate records of vaccination status and testing results. If Staffing 360 Solutions and/or OSHA discover that false statements or documents have been made or submitted, it will consider referrals to the US Department of Justice for criminal prosecution in appropriate cases.

Vaccination Guidance
COVID-19 vaccines are free and widely available. Search vaccines.gov, text your ZIP code to 438829 or call 1-800-232-0233 to find locations near you. 

The CDC website provides you with more information on vaccination efficacy, safety and its benefits.

Contractors are recommended to seek support from a healthcare provider for more information on each vaccine, including the common side effects.

Vaccination Support from us
Staffing 360 Solutions encourages all vaccination appointments to be scheduled outside the working day to ensure minimal disruption to your work.  In the event that you are unable to schedule an appointment outside of the standard working day, please email us at vaccinemandate@staffing360solutions.com with the time and date of your appointment and we will review your request and provide the appropriate approval and paid time off up to a maximum of four hours.  Should you feel unwell following the vaccination, you are eligible to receive reasonable paid time off (as needed) to recover from any vaccine-related side effects. You should notify us at vaccinemandate@staffing360solutions.com in this instance so we can notify your onsite supervisor of your absence. 

Documentation of Vaccination Status

Official documentation of vaccination status should be provided to the Staffing 360 Solutions Human Resources Department at vaccinemandate@staffing360solutions.com and include the following information:

  • The type of vaccine administered.
  • The date(s) of administration.
  • The name of the health care professional or clinic site administering the vaccine.
  • Please include your name, client site (if you are working) and the last 4 digits of your Social Security Number in the body of the email.

An immunization card from a healthcare provider or pharmacy, the completed CDC-issued vaccine card, or medical records is sufficient to verify vaccination status. Do not include any medical or genetic information with your proof of vaccination.

Note that a recent antibody test cannot be used to prove vaccination status.

Information provided to Staffing 360 Solutions

All persons subject to this policy are required to certify that the documentation they are submitting is true and correct.  False statements or documents made or submitted to Staffing 360 Solutions for the purposes of complying with our Covid-19 Policy required by OSHA’s Vaccination and Testing ETS could carry criminal penalties. The ETS relies on employees providing truthful and accurate information, including, where applicable, proof of vaccination status and COVID-19 test results, to their employers, and on their employers maintaining accurate records of vaccination status and testing results. If OSHA discovers that false statements or documents have been made or submitted, it will consider referrals to the US Department of Justice for criminal prosecution in appropriate cases.

‍Any persons found to have provided false documentation will be subject to termination of employment.

Option 2: Submit to Weekly Covid-19 Testing

Persons subject to this policy who choose not to be vaccinated against COVID-19 are required to present a negative COVID-19 test result weekly every Monday to the Human Resources (HR) Department at vaccinemandate@staffing360solutions.com before reporting to work.

Sourcing tests:

Persons who choose not to be vaccinated are responsible for obtaining a weekly COVID-19 test at their own cost (as permitted by state law). Contractors should independently schedule tests at point-of-care locations. These can be found by going to https://www.hhs.gov/coronavirus/community-based-testing-sites/index.html#ct.

Acceptable tests include Rapid or PCR tests. An at-home test may be used, but cannot be self-administered or self-read by the contractor unless it is observed by a member of staff of Staffing 360 Solutions or an authorized telehealth proctor. ‍

Sending your results:
Unless advised otherwise, Contractors should provide their COVID-19 test results every Monday morning prior to entering the worksite in the following way:


Failure to send in weekly test results in a timely way more than two times (either consecutively or non-consecutively) will result in disciplinary action, up to and including immediate termination from the assignment.

If a contractor’s test result shows positive for Covid-19, please go to section ‘Procedures in the Event of a Positive COVID-19 Test’ for more information on how to notify us.  Do not enter the worksite in this event.

Client-specific testing requirements:

Some clients may require our contractors to follow their testing protocols. In this event, we will notify you prior to your assignment or upon learning from the client of their testing protocols so that you are able to meet their expectations.

Information provided to Staffing 360 Solutions:

OSHA’s Vaccination and Testing ETS relies on employees and contractors providing truthful and accurate information, including, where applicable, proof of vaccination status and COVID-19 test results, to their employers, and on their employers maintaining
accurate records of vaccination status and testing results. If Staffing 360 Solutions and/or OSHA discover that false statements or documents have been made or submitted, it will consider referrals to the US Department of Justice for criminal prosecution in appropriate cases.


‍Any persons found to have provided false documentation will be subject to termination of employment.

Face Covering Requirement for Unvaccinated Individuals

Effective January 10th, 2022, any contractor who is not fully vaccinated will be required to wear a face-covering when indoors or when occupying a vehicle with another person for work purposes. A contractor who is alone in a room with floor to ceiling windows and a closed-door may remove their face covering, but should put it back on if they exit the room or another individual enters the room. A contractor may also remove their face coverings for a limited period while eating or drinking at the workplace, or for identification purposes in compliance with safety and security requirements.

Face coverings should consist of at least two layers of material that is either tightly woven or non-woven, and the face-covering must not have visible holes or openings. Face coverings should completely cover the wearer’s mouth and nose, must fit snugly against the sides of the face without gaps, and should be replaced when wet, soiled, or damaged.

Should you require a face-covering please contact your recruiter at your local office who will provide you with an appropriate supply.


Procedures in the Event of a Positive COVID-19 Test

Any person covered by this policy who tests positive for COVID-19, regardless of their vaccination status, is required to notify Staffing 360 Solutions as soon as safely possible. That notification should be done by contacting your recruiter as soon as you are aware.  If you are unsuccessful in reaching your recruiter, please notify us by emailing vaccinemandate@staffing360solutions.com

Staffing 360 Solutions is required to temporarily remove from the workplace any person who tests positive for COVID-19.

Should you be too unwell to notify us or you are hospitalized as a result of a positive COVID-19 test, please ensure a family member or similar notifies Staffing 360 Solutions as soon as possible.  This notification should be done by emailing vaccinemandate@staffing360solutions.com or calling the Human Resources Department at Staffing 360 Solutions.

Under the following conditions, a person who tests positive for COVID-19 may return to the workplace:

  • if they receive a negative result on a COVID-19 nucleic acid amplification test (NAAT) if possible; or
  • (1) after isolating for 5 days from the date of their positive test (if they never experienced symptoms), or at least 5 days have passed since the first appearance of any symptoms; AND (2) the person has gone at least 24 hours without a fever (without the use of fever-reducing medication);  (3) the person’s other symptoms of COVID-19 are improving (excluding loss of taste and smell).
  • Contractors must wear a well-fitted face-covering after returning to work for an additional 5 days.

ACCOMMODATION AND EXEMPTION REQUESTS

Medical Accommodation
Staffing 360 Solutions provides reasonable accommodations, absent undue hardship or a direct threat to health and safety in the workplace, to qualified individuals with disabilities or medical conditions that prevent them from getting vaccinated. Reasonable accommodation may include appropriate adjustment or modifications of employer policies, including this COVID-19 Vaccination Policy.

If you believe you need an accommodation regarding this policy because of a disability or medical condition, you are responsible for requesting a reasonable accommodation from the Human Resources Department by emailing vaccinemandate@staffing360solutions.com.

Religious Accommodation
Staffing 360 Solutions provides reasonable accommodations, absent undue hardship or a direct threat to health and safety in the workplace, to qualified individuals with sincerely held religious beliefs, observances, or practices that conflict with getting vaccinated.

If you believe you need an accommodation regarding this policy because of your sincerely held religious belief, you are responsible for requesting a reasonable accommodation from the Human Resources Department by emailing vaccinemandate@staffing360solutions.com.

Interactive Process
Staffing 360 Solutions will engage in an interactive dialogue with you to determine the precise limitations of your ability to comply with this COVID-19 Vaccination Policy and explore potential reasonable accommodations that could overcome those limitations. 

Staffing 360 Solutions encourages contractors to suggest specific reasonable accommodations. However, Staffing 360 Solutions is not obligated to make the specific accommodation requested and mayFinish Editing
 

 provide an alternative effective accommodation, to the extent any reasonable accommodation can be made without imposing an undue hardship on Staffing 360 Solutions or posing a direct threat to you or others in the workplace.

Exemption or Delay in Vaccination for Other Medical Reasons
Exemptions or a delay in vaccination for other medical reasons may be available on a case-by-case basis even if they do not qualify as a disability under federal, state, or local law.

Staffing 360 Solutions will engage in an interactive dialogue with you to determine whether an exemption is appropriate and can be granted without imposing an undue hardship on Staffing 360 Solutions or posing a direct threat to you or others in the workplace. 

How to Request an Accommodation or Other Exemption
You may request a reasonable accommodation or other exemption from this policy by completing Staffing 360 Solutions Request for Exemption from COVID-19 Vaccination Policy Form and returning it to the Human Resources Department. The forms are available by emailing vaccinemandate@staffing360solutions.com. When submitting the completed form, please include all relevant information, including:

  • A description of the accommodation or exemption requested.
  • The reason for the requested accommodation or exemption.

Staffing 360 Solutions reserves the right to request additional documentation supporting the need for an accommodation or request for any other exemption. Staffing 360 Solutions will keep confidential any medical information obtained in connection with your request for a reasonable accommodation or other exemption.

DETERMINATIONS

Staffing 360 Solutions makes determinations about requested accommodations and exemptions on a case-by-case basis considering various factors and based on an individualized assessment in each situation. Staffing 360 Solutions strives to make these determinations expeditiously and in a fair and nondiscriminatory manner and will inform you after we make a determination. If you have any questions about an accommodation or exemption request you made, please contact the Human Resources Department at vaccinemandate@staffing360solutions.com.


CONFIDENTIALITY

Staffing 360 Solutions will make every attempt to keep all medical records, including vaccine cards and test results, confidential. Documents will be stored responsibly. In the course of ensuring your and our client employee safety in the work place, Staffing 360 Solutions will seek your consent to share copies of vaccine records or test results with the client. Consent to share vaccine records will ordinarily be sought from you during the onboarding process and/or at the request of the client during the course of the assignment.  At no time will Staffing 360 Solutions use the provided COVID-19 medical information outside the scope and intent of this policy, including the provision of medical coverage or care as it relates to health insurance plans or worker’s compensation. For questions regarding the confidentiality of COVID-19 vaccine cards or weekly test results, please email vaccinemandate@staffing360solutions.com.


POLICY ADMINISTRATION AND QUESTIONS

The Human Resources Department, in collaboration with the Safety and Compliance Departments, is responsible for administering and enforcing this policy. If you have any questions about this policy or about health and safety issues that are not addressed in this policy, please contact hr_us@staffing360solutions.com.

POLICY MODIFICATION

Government and public health guidelines and restrictions and business and industry best practices regarding COVID-19 and COVID-19 vaccines are changing rapidly as new information becomes available, further research is conducted, and additional vaccines are fully approved and distributed. Staffing 360 Solutions reserves the right to modify this policy at any time in its sole discretion to adapt to changing circumstances and business needs, consistent with its commitment to maintaining a safe and healthy workplace.

ENFORCEMENT AND NON-RETALIATION

Failure to comply with or enforce this policy may result in discipline, up to and including termination of employment.

Staffing 360 Solutions prohibits any form of discipline, reprisal, intimidation, or retaliation for reporting a violation of this policy or any other health and safety concern. Contractors also have the right to report work-related injuries and illnesses and Staffing 360 Solutions will not discharge or discriminate or otherwise retaliate against employees for reporting work-related injuries or illnesses or good faith health and safety concerns.
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Staffing 360 Solutions needs your full cooperation and compliance with this and other health and safety workplace policies to make them effective. Together, we can turn the tide against COVID-19 and create a stronger, healthier future for everyone.

ACKNOWLEDGEMENT OF RECEIPT AND REVIEW

I, _______________________ (contractor name), acknowledge that on _____________________ (date), I received a copy of Staffing 360 Solutions COVID-19 Vaccination Policy and that I read it, understood it, and agree to comply with it. I understand that Staffing 360 Solutions has the maximum discretion permitted by law to interpret, administer, change, modify, or delete this policy at any time with or without notice. No statement or representation by a supervisor or manager or any other employee, whether oral or written, can supplement or modify this policy. Changes can only be made if approved in writing by Human Resources. I also understand that any delay or failure by Staffing 360 Solutions to enforce any work policy or rule will not constitute a waiver of Staffing 360 Solutions right to do so in the future. I understand that neither this policy nor any other communication by a management representative or any other employee, whether oral or written, is intended in any way to create a contract of employment. I understand that, unless I have a written employment agreement signed by an authorized Staffing 360 Solutions representative, I am employed at will and this policy does not modify my at-will employment status. If I have a written employment agreement signed by an authorized Staffing 360 Solutions representative and this policy conflicts with the terms of my employment agreement, I understand that the terms of my employment agreement will control.