On September 9, 2021, President Biden signed an Executive Order (EO) to implement COVID safety protocols for Federal service contractors. While the EO did not identify specific safety protocols, it did direct a Federal task force (the “Safer Federal Workforce Task Force,” created by Executive Order in January 2021) to issue COVID-19-related workplace safety guidance for prime contractors and subcontractors in the near future. Specifically, the Task Force is charged with issuing contractor guidance by September 24, 2021, including definitions of relevant terms, specific workplace safety protocols, and applicable exceptions.

While the announcement of the new EO was somewhat overshadowed by the President’s concurrent vaccine mandate for all Federal workers, it is of great importance to Federal contractors and subcontractors. The EO is broadly worded; and while it does NOT apply to all contractors, it will impose new compliance obligations upon many.