Although courts have yet to weigh in on the issue, guidelines from the US Equal Employment Opportunity Commission and other regulatory agencies indicate that employers may implement vaccine passports if they perform a workplace assessment and determine that limiting entry to the vaccinated is a necessary health and safety measure to prevent an imminent risk. Employers must also ensure that their passport policies comply with anti-discrimination and privacy protection requirements. Here’s a Model Policy that you can adapt for use at your own lab, depending on the workplace-specific circumstances involved.
Compliance Tool: Model Mandatory Excluded Provider Screening Policy
A written policy helps establish your right to do excluded persons checks and take appropriate actions if they come back positive.