Confused about the new OSHA testing rules for unvaccinated?


A few options but if using Rapid Tests, the tests must be:

- Observed by the employer OR

- via a Certified Telehealth Proctored session (There are a few companies enabling this)

The rule applies to any companies with 100 or more people…

In these companies, employees must be vaccinated or test weekly.

A hefty fine of $14,000 can be placed upon companies out of compliance

So here are the testing options and pros/cons

First off, that $14k fine is PER individual out of compliance, and possibly per infraction (though Im not positive about the per infraction part).

For the testing:

The test used can be a PCR or a rapid test and can be performed under observation at work or w a (simple) virtual proctor at home.

If lab PCR, swab must be shipped to the lab and reported back to individual and employer. Surely labs will set up programs for this.

These PCR lab tests will likely be costly and if delayed, won’t offer all too much to actually limit spread.

An important consideration…

Importantly for employers considering a lab PCR test, PCR tests can stay positive for weeks or longer after transmission is complete

So if the goal is to keep employees working safely, w minimal interruption, PCR can have this negative consequence of staying pos too long

There are quite a few PCR service companies that will help set up PCR based testing for employers. But these will likely be pricier than rapid tests. The latter, I argue, are absolutely the more appropriate tool for this sort of public health testing

If using Self Rapid tests, the tests must be observed. This means that people can come to work and use the test under employer supervision OR the test can be performed at home under virtual telehealth proctor guide

Speaking with many companies, Ive heard very few with interest in turning themselves into laboratories and having people test themselves w observation on site.

Indeed this just doesn’t make sense - particularly if a goal is to not have infectious people showing up at work.

So another option, I would argue is the best option, is a rapid home-test with verified proctored use & results/reporting

By far the most experienced for this is eMed

eMed has been working w Abbott/CDC for almost a year and is the original approach that led to Abbotts EUA

Through this mechanism, the testing and verification/observation is much less expensive and effort is taken entirely off of the employer - no testing on site. (Good for travel & schools for test-to-stay too)

eMed is most experienced & has most capacity, but others too

Azova has worked w Ellume and Lucira to enable virtual proctored sessions for travel. I am admittedly less familiar with their exact protocol

Other telehealth proctored testing companies will likely pop up as a result of OSHA

It’s Important is to see which have the tests

A problem that will arise is going to be a limit of tests available in the US

A good thing is that FDA has recently authorized an additional group of rapid tests and this will drive up supply and down costs.

For businesses looking to stay in compliance, may start looking

I’ll keep updating this thread as information evolves…

1) this goes into effect January 4.

2) just today a federal
Court has put a temporary halt on the law going into effect. OSHA and Biden admin feel confident that this law is lawful and will continue.

I’m not a lawyer

Also, if looking to use an over the counter test w a proctor - the test must be associated w a verified proctoring company (ie eMed or Azova)

Unless set up before hand, you generally can’t just go buy OTC tests, pass them to employees and tell them to get them Proctored


• • •

Missing some Tweet in this thread? You can try to force a refresh

Keep Current with Michael Mina

Michael Mina Profile picture

Stay in touch and get notified when new unrolls are available from this author!

Read all threads

This Thread may be Removed Anytime!


Twitter may remove this content at anytime! Save it as PDF for later use!

Try unrolling a thread yourself!

how to unroll video
  1. Follow @ThreadReaderApp to mention us!

  2. From a Twitter thread mention us with a keyword "unroll"
@threadreaderapp unroll

Practice here first or read more on our help page!

More from @michaelmina_lab

1 Nov
I truly dislike the term "Natural Immunity"

There is no such thing as artificial immunity

A vaccine drives a NATURAL immune response

The question is simply "how do you want to start building that immunity?" Through a risky infection or via a safe vaccine

Me? I choose vaccine.
Vaccines are one of the most holistic interventions we have in medicine and public health.

Vaccines utilize our natural evolved processes to provide our immune system with an Education.

They aren't a pill that kills pathogens by distributing to all our tissues...

Vaccines are perhaps the most natural thing we do in medicine to protect ppl from infections

Vaccines are small proteins that get taken up naturally by our immune cells.

The immune cells do exactly what they evolved to do naturally. Vaccines don't force anything.

Read 7 tweets
1 Nov
“I will plan to return to work in person at the conclusion of the ten day quarantine following a negative rapid test..."

Great use of a rapid test!

Importantly she’s not using a PCR test bc she’d still remain PCR pos, potentially for weeks.

Why is this important?

Bc imagine that she did not test early and isolate and got a PCR positive AFTER the day her isolation would have ended.

SHE would have to START an isolation that day, for ten days, even though she was NO LONGER INFECTIOUS


Let’s say in this scenario that @PressSec was not in contact w @POTUS when she was actually infectious bc Biden was in Europe.

But then they were in contact AFTER the infectious period, and just before she got the 1st (in this scenario) positive PCR test

Read 7 tweets
31 Oct
Kids will now get vaccinated

Millions have unfortunately already been infected - we can’t undo that

Let’s not ignore it but use it to our benefit

Data shows Infxn + 1 dose Is as good as 2 dose in uninfected

Here’s a simple strategy to conserve vax and reduce burden

When kids show up to get their first dose of a vaccine, they are simultaneously offered an antibody test. The sample for the antibody test can be a simple mouth swab of the gums (or a blood draw - but I prefer a swab of gums personally since it’s painless and easy.

Now that the kid has their first vaccine AND a sample for antibody test, there will be 3-4 weeks to confirm if the child has antibodies to COVID.

This long period of time offers tons of flexibility to ensure a highly accurate result is obtained - I’ll give examples below

Read 14 tweets
30 Oct
Recognizing a need for boosters in vulnerable when it comes to Delta & recognizing their benefit - which thus far seems high (even if turns out to be temporary)…

Why are we still vaccinating w mRNA sequence of the now obsolete Wuhan strain when we know the sequence for Delta.
This is only half sarcastic as a question.

Is it purely bc full trials haven’t been completed? Is it bc we don’t agree w an added benefit of using a sequence matching the most common and destructive variant?

My opinion is there would be benefit (or at least equivalency)
If we continue to Reenforce a response to the 1st virus, we may find ourselves stuck in that version of a response when we do want to make an update to the vaccine later on. Better to stay current.

Also, we know Delta has evasive mutations vs original immune response
Read 4 tweets
30 Oct
A common question today:

Q: “Can I get a flu vaccine at same time as a Covid vaccine?”


The immune system evolved to be able to respond to MANY targets simultaneously. Similar to parallel processes on a computer, the immune system has enormous parallel capability.
For example, in my research largely pre-COVID, we profile immune responses to pathogens and vaccines.

In a single vaccine or infection, the immune system responds to an enormous array of different “epitopes” on even one pathogen or vaccine.

When we add additional vaccines to the mix, it simply adds an extra set of epitopes (the parts of the vaccine or pathogen that the immune system recognizes) and our amazing immune systems don’t miss a beat

Read 4 tweets
29 Oct
Another EUA for a molecular home test!

At the start of the pandemic,
was one of the first to understand that we needed to get widespread access to rapid accurate and inexpensive Covid tests…

He came up with a prototype, put together a team of microbiologists & engineers and set out to develop a molecular (PCR like) test that could be used in the home, quickly…

Fast forward 18 months and
@DetectTest is an FDA authorized rapid molecular home test.

It’s an incredible feat going from 0 to EUA in 18 months. (Most molecular test companies existed for years preCOVID)…

Read 5 tweets

Did Thread Reader help you today?

Support us! We are indie developers!

This site is made by just two indie developers on a laptop doing marketing, support and development! Read more about the story.

Become a Premium Member ($3/month or $30/year) and get exclusive features!

Become Premium

Too expensive? Make a small donation by buying us coffee ($5) or help with server cost ($10)

Donate via Paypal Become our Patreon

Thank you for your support!

Follow Us on Twitter!