While employers with less than 100 employees won’t have mandated vaccination or testing requirements per the upcoming Emergency Temporary Standard, several owners have similar requirements for their facilities and project sites. Those requirements are leading some contractors to implement their own vaccination policies and it is within your right as an employer to do so. And, while it is strongly encouraged that you communicate with your local union, note that a contractor's vaccine policy in not a mandatory subject of bargaining. Here are some common questions and answers regarding vaccination policies: Q: Can contractors implement a COVID-19 Vaccine Policy? A: Yes. Keep in mind that the policy must be fairly implemented and must be made clear to your employees. Q: Do contractors have to collectively bargain to implement a COVID-19 Vaccine Policy? A: No. However, it is strongly encouraged that you communicate with your local union to discuss your intentions. Q: Can the union file a grievance for a contractor implementing a COVID-19 Vaccine Policy? A: It’s not expected that you will find language in your CBA that would allow a grievance to be valid concerning a contractor’s right to implement a COVID-19 vaccine policy. The IUPAT has communicated to FCA that they will discourage local unions from filing grievances against a contractor who implements a fair vaccine policy. ECA’s partners at the Finishing Contractors Association has provided sample policies to assist contractors, a Mandatory Vaccination Policy and a Non-Mandatory Vaccination Policy. Click here to learn more and download.