Some of Our Employees Are Fully Vaccinated for COVID-19—Now What?

Mar 17, 2021   Print PDF

By Krista Nelson Slosburg | Related Practice: Employment

With vaccines becoming more widely available, an increasing number of Americans are fully vaccinated for COVID-19. What does that mean for Washington employers? The Centers for Disease Control and Prevention’s March 8, 2021 Interim Public Health Recommendations for Fully Vaccinated People provides some guidance, but Washington employers must keep in mind current restrictions under Washington law and continue to adhere to those more specific requirements.

Person receiving shot

The CDC’s Interim Guidance

First, the CDC’s Interim Guidance is somewhat of a moving target and will be updated periodically based on levels of community spread, the proportion of the population that is fully vaccinated, and the rapidly evolving science on COVID-19 vaccines.

As of the date of this post, the CDC recommends that fully vaccinated people—those who received the second dose of the Pfizer or Moderna vaccine or a single dose of the Johnson & Johnson vaccine more than two weeks ago—may do the following:

  • Visit fully with other vaccinated people in doors without wearing masks or physical distancing;
  • Visit with unvaccinated people from a single household who are at low risk for severe COVID-19 disease indoors without wearing masks or physical distancing; and
  • Refrain from quarantine and testing following a known exposure if asymptomatic.

The CDC recommends that fully vaccinated people should continue to:

  • Take precautions in public like wearing a well-fitted mask and physical distancing;
  • Wear masks, practice physical distancing, and adhere to other prevention measures when visiting with unvaccinated people who are at increased risk for severe COVID-19 disease or who have an unvaccinated household member who is at increased risk for severe COVID-19 disease;
  • Wear masks, maintain physical distance, and practice other prevention measures when visiting with unvaccinated people from multiple households;
  • Avoid medium- and large-sized in-person gatherings;
  • Get tested if experiencing COVID-19 symptoms;
  • Follow guidance issued by individual employers; and
  • Follow CDC and health department travel requirements and recommendations.

Can Washington Employers Make Any Modifications to Their Safe Work Plans as a Result of the CDC’s Interim Guidance?

The short answer is no, we don’t recommend Washington employers make any significant modifications to their Safe Work Plans just yet, despite the CDC’s Interim Guidance, because current restrictions remain in place in our state and require compliance.

For example, while the CDC’s Interim Guidance allows fully vaccinated people to gather indoors without wearing masks or social distancing, masks and social distancing are still required under orders previously issued by Governor Inslee. Therefore, employers should continue to enforce mandatory mask rules among their employees, regardless of vaccination status. And in general, employers should continue to adhere to Washington’s more specific orders that set forth guidelines on measures like social distancing, even if employees are fully vaccinated.

What About Phase 3?

On March 11, 2021, Governor Inslee announced a statewide move to Phase 3 under the Healthy Washington: Roadmap to Recovery plan. The Governor’s office has not yet issued a full list of industry-level changes for Phase 3, though they are expected later this week. Depending on the guidance, employers may be able to make additional modifications to existing Safe Work Plans. Stay tuned for additional updates.

To see all of our COVID-related posts, visit our COVID-19 Resources page.