Skip to main content


Self-Certification of Employee Vaccination Status

July 27, 2021 24535


Employers looking to take advantage of the exceptions for social distancing, required testing, workplace exclusions and face coverings must have documentation showing employees are fully vaccinated, according to the Cal/OSHA Emergency Temporary Standards (ETS).

As defined in the ETS, a “fully vaccinated” employee* means the employer has documentation showing that the person received, at least 14 days prior, either the second dose in a two-dose COVID-19 vaccine series or a single-dose COVID-19 vaccine. Vaccines must be FDA approved or have an emergency use authorization from the FDA.

Further, effective no later than August 23rd, California issued an order requiring all health care workers in the state to either show proof of full vaccination against COVID-19 or be tested regularly. Employers in health care settings must verify that their workers are fully vaccinated against COVID-19. Dental staff who are not fully vaccinated or who cannot show proof of vaccination are subject to weekly COVID-19 testing and will be required to wear surgical masks, at minimum.

In lieu of obtaining a copy of the employee’s vaccine card, employees may show official proof of the vaccine or other similar health care provider documentation (see below) confirming the vaccine status to a designated representative of the business. If an employee provides a copy of their vaccine card, or other documentation employers should instruct employees to omit any medical information unrelated to their vaccine status.

Pursuant to the CDPH Guidance for Vaccine Records Guidelines & Standards, only the following modes may be used as proof of vaccination:

  1. COVID-19 Vaccination Record Card (issued by the Department of Health and Human Services Centers for Disease Control & Prevention or WHO Yellow Card) which includes name of person vaccinated, type of vaccine provided and date last dose administered); OR
  2. a photo of a Vaccination Record Card as a separate document; OR
  3. a photo of the client's Vaccination Record Card stored on a phone or electronic device; OR
  4. documentation of COVID-19 vaccination from a health care provider; OR
  5. digital record that includes a QR code that when scanned by a SMART Health Card reader displays to the reader client name, date of birth, vaccine dates and vaccine type. The QR code must also confirm the vaccine record as an official record of the state of California; OR
  6. documentation of vaccination from other contracted employers who follow these vaccination records guidelines and standards.

In the absence of knowledge to the contrary, a facility may accept the documentation presented as valid.

Facilities must have a plan in place for tracking verified worker vaccination status. Records of vaccination verification must be made available, upon request, to the local health jurisdiction for purposes of case investigation.

Workers who are not fully vaccinated, or for whom vaccine status is unknown or documentation is not provided, must be considered unvaccinated.

Employers must meet compliance obligations with respect to medical records and the protection of employees’ private and confidential information.

*Includes associates classified as independent contractors

Comments are only visible to subscribers.