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All Your OSHA Weekly Testing Questions, Answered

Should we offer a weekly testing option? Where can we buy tests? These and so many more, answered!

Should we bother with weekly testing, or just mandate vaccination?

This is ultimately a question that’s up to your leadership team. Some of our clients feel that they’ll risk losing too many staff members if they require vaccination for all employees, and can’t afford that right now with staffing shortages. Others feel that a mandate is a simpler, cleaner option, and look to successful company-wide mandates at major airlines as an example where they didn’t actually lose many employees. Weekly testing for unvaccinated employees is a massive operational and financial undertaking, so your decision on this should carefully weigh the pros and cons of each. 

What is the real turnover rate for companies that mandate vaccination?

In a recent Mercer poll, 71% of employers who instituted a vaccine mandate saw no change in employee turnover. Less than 5% reported a significant increase. United Airlines says that 96% of its workforce met their September deadline for full vaccination, with fewer than 600 out of 67,000 employees refusing. There’s definitely some risk that mandating vaccination for all employees will create some small amount of turnover, with most estimates at or under 5% of the workforce. 


How can we track vaccination status?

The January 10th deadline to track vaccination status for all employees is a doozy. You’ll need to know and record the status of each employee in a way that can be reported to OSHA if they request it, and in a way that managers can easily enforce masks for all unvaccinated workers. ZHH has a Vaccination and Test Tracking solution that allows employees to upload their vaccination card, or their weekly test, with easy reporting for your team and for OSHA compliance.

Book a time to chat with us about our vaccination and test tracking system if you haven’t yet!


Are we responsible if employees upload fake cards or test results?

This is a complex legal question that you should run by your legal counsel. Here’s what the OSHA website says about this: 

 “[A]lthough employers are not required to monitor for or detect fraud, these same prohibitions on false statements and documentation apply to employers. If an employer knows that proof submitted by an employee is fraudulent, and even with this knowledge, accepts and maintains the fraudulent proof as a record of compliance with this ETS, the employer may be subject to the penalties in 18 U.S.C. § 1001 and 17(g) of the OSH Act.” 


What are best practices around enforcing masks for unvaccinated employees?

The OSHA guidance says that starting January 10th, employers must ensure that all unvaccinated employees are wearing masks in the workplace. To do that selectively, managers must be aware of the vaccination status of each employee and regularly enforce masks for unvaccinated folks. But given the current explosion of cases, our advice is to seriously consider requiring masks for ALL employees right now if you’re not doing so already, at least until this Omicron surge is under control. 

Where can we buy tests?

Bulk tests are currently actually a bit easier to find than individual tests, but we know that’s a moving target and could change at any minute. There are a few places you can try to buy rapid tests in bulk:

  • Insurers (Cigna) 
  • First aid suppliers (Cintas, Unifirst, and GreenGuard)
  • Major pharmacies and retailers (Amazon, Walmart, Walgreens, CVS)
  • Medical suppliers (Henry Schein, McKesson)

Be sure to document your attempts to purchase tests, since it can be used to show a “good faith effort” to comply if there are any delays or issues with acquiring tests. OSHA has said it won’t penalize companies that are making a good faith effort to comply during this time. 


What kind of tests should we buy?

Generally, you’re a beggar not a chooser right now, so any test you can get in adequate supply is a good test! There are some basic things to look for if you do have options, though.

  • Look for tests that show results in 15 mins or less!
  • Some take more than 15 mins for results. You don’t want 30 mins or 1 hour! 
  • Double check that they are authorized for emergency use by the FDA.
  • Be careful of scams. You can see a full list of authorized rapid tests here


Will we be able to get tests from the White House? Can we ask employees to order them from the government online?

On December 21st, President Biden announced that 500,000,000 tests would be available for free from the federal government through an online website, where individuals can order tests to be delivered by mail. There were very few details available, but we highly doubt that this website will allow bulk orders by businesses based on what we’ve heard so far. It’s possible that individual employees could order their tests from the website and have them delivered, then bring them to work, but we don’t know how long they’ll take, or how many a single person can order. We wouldn’t recommend banking on this as a reliable source by the first week of February, but we’ll keep a close eye on it as we hear more. 

How many tests should we buy?  

Most clients are moving forward and procuring a four- to eight-week supply with quantities calculated based on their projected unvaxxed employee population. We anticipate your weekly need for testing will decline over time. Some clients are requiring vaccination for all new hires, which will ultimately reduce overall testing needs. 

Who can proctor tests?  

Anyone with basic training in following the instructions in the test kit can proctor a test. It does not require medical training. 

What’s the best method to do tests on-site if we choose to do that?

We’ve already started doing regular testing in a few places that require it under local regulations, and gathered some best practices:

Designate managers or testing coordinators who are in charge of overseeing testing for each shift.

  • This might take up a significant amount of time, so some folks are actually hiring new people or scheduling additional shifts that are just for test coordination, to ensure that managers aren’t trying to juggle too many things at once. 
  • This testing coordinator should be masked during the testing process, and do their best to social distance as much as possible. 

Track your tests!

  • Employees only need one test per week (or within 7 days of a shift). You’ll need to keep track of their tests for both documentation purposes and so you’re not testing more than necessary. ZHH has a Vaccination and Test Tracking service that can help with this if you haven’t gotten that set up already. 

Where possible, do the testing outside. If not, do it in a manager’s office, the back of house, or somewhere away from clients. 

  • Outside or in a well-ventilated area is best! Away from guests or clients is important, as well. 

Minimize close contact between employees during the tests. 

  • Tests take 15 minutes for results. You want to minimize close contact during those 15 minutes so that if anyone tests positive, you don’t need to exclude everyone on shift.
  • If possible, have them outside, or as far apart as possible. 
  • Consider staggering shift start times, so that fewer people are testing at the same time. 

Have the employee write their name and the date on the outside of the test.

  • Use a permanent marker in clear, legible handwriting.
  • If you have an employee ID, it’s a good idea to have them write that, too!

Make the employees wait before heading in to work!

  • If employees start working first, and then test positive 15 minutes later, you run the risk of exposing the rest of the staff during that time. 
  • Most of our clients doing this now have moved to a system where employees wait for 15 mins, show the negative test to the manager, upload it into the system, and then start working. 
  • It’s also complicated for managers to input all of the information for multiple employees, whereas each employee knows their name and any employee ID number needed, which has proven to be easier in most cases. 

Use a timer!

  • Be sure to read the instructions. 
  • For tests with 15 minute results, it’s important to check later than 15 minutes but before 30 minutes after they were started, since anything longer than 30 minutes is no longer valid. You only have a short window to view and record the valid result. 

Employees should take a picture of their results and upload it to your system. 

  • Having employees do their own is quicker, but be sure to verify that they've successfully uploaded the picture since you'll need it for reporting and compliance. 

Confirm everyone’s results are negative!

  • The testing coordinator must confirm the results are negative, per the OSHA guidance. 
  • Rapid test positives can have extremely faint lines, so it’s key to train your coordinator to look for positive results.

Clear negative employees. 

  • Once confirmed, negative employees can get to work!

Expect to get positive results!

  • Train the manager or testing coordinator in what to do when that happens. 
  • The people testing are unvaccinated and therefore at the highest risk of getting COVID, so this will unfortunately happen regularly.
  • Positive employees should go outside immediately - and once safely away from everyone should still upload their positive results to the system!
  • Rapid test positives are highly accurate, so assume it’s a true positive and begin contact tracing immediately. 
  • If the positive employee carpools with anyone else on shift, arrange an alternative ride home for the other person. It’s important to get that person back home with minimal contact to others. 

Try it first!

  • Before going live with this for everyone, do a trial run! See what works and what doesn’t for your specific situation. Solicit feedback from employees and managers, and tweak your operating procedures accordingly. 

Not using ZHH's vaccination and test tracking system yet?

Book a time to chat with us about our vaccination and test tracking system to get started.

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Disclaimer: This post is meant for general information and educational purposes only and does not constitute, and is not intended as, any form of medical, legal or regulatory advice or a recommendation or suggestion regarding the same.  No recipient of this information should act or refrain from acting on the basis of this information without first seeking legal advice from counsel in the relevant jurisdiction.