LA County Proof of Vaccine Requirements Take Effect

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Ervin Cohen & Jessup LLP

Today, October 7, 2021, Los Angeles County Public Health Officer Order’s vaccine requirements go into effect. These requirements were first announced as an executive order of the Public Health Officer and were ratified by the Los Angeles County Board of Supervisors on September 15, 2021.

Under these requirements, proof of vaccination or a negative test result will be required to enter outdoor mega-events, and proof of at least one dose of the COVID-19 vaccine will be required to enter or work in indoor portions of bars, lounges, nightclubs, breweries, wineries and distilleries in L.A. County.

Beginning on November 1, 2021, operators of mega-events are required to cross-check proof of vaccination or a negative COVID-19 test against a photo identification and cannot simply look at vaccination cards. Notably, the County’s overview for covered businesses does not specify that other businesses cross-check proof of vaccine against photo identification but further guidance may be forthcoming.

Beginning on November 4, 2021, bars and similar establishments throughout L.A. County will be required to verify full vaccination of all patrons and employees prior to entry to indoor portions of their establishments. Customers who do not provide proof of vaccination may only be seated or served in outdoor portions of the facility.

The Order “strongly recommends,” but does not require that restaurants and other food facilities reserve the indoor areas of their establishments for individuals who are able to present proof of full vaccination against COVID-19 prior to entry.

While the City of Los Angeles passed a more stringent and expansive ordinance covering a large number of indoor public spaces on October 6, 2021, that mandate will not go into effect until November 4, 2021. Therefore, the County rules will apply between today and November 4, 2021, to both the City of Los Angeles and the rest of Los Angeles County. After November 4, 2021, Los Angeles City and the rest of the County will have different rules so businesses based in the City of Los Angeles will have to follow the stricter standard. To be clear, the city ordinance will apply only to the City of Los Angeles; the county’s order will apply to all unincorporated areas of the County of Los Angeles, as well as incorporated areas that do not have their own health departments (only the cities of Los Angeles, Pasadena and Long Beach presently have health departments). 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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