COVID-19 VACCINATION POLICY
I. Purpose
It is mission-critical that the Environmental Leadership Program (ELP) strives to create spaces that are transformative, community-building, and safe for all involved. Together we commit to keeping ourselves and each other as safe and healthy as possible, knowing our health and well-being is bound up with the well-being of those in our communities. Our values call us to think about those most vulnerable in our programs and to act from that place, for our staff, their families and loved ones, and our entire ELP community. We recognize that some communities are disproportionately affected by the COVID-19 pandemic, consistent with a long history of disadvantage and privilege that carries unequal impact. We commit to bringing an equity lens to the development and implementation of COVID-related policies, including consideration of who is most benefited or burdened by policies and practices.
Consistent with its duty to provide and maintain a workplace that is free of recognized hazards, ELP has adopted the COVID-19 Vaccination Policy to safeguard the health and well-being of ELP employees, subcontractors, participants, and their families. This is part of our accountability to play a responsible role in protecting the community from infectious conditions that may be mitigated through an effective vaccination program. (This policy is one component of larger work to mitigate risk for our staff, program participants, and partners.) This policy is based on guidance provided by the Centers for Disease Control and Prevention (CDC) and public health and licensing authorities, as applicable. As an organization with staff and programs based across the country, ELP’s policies are subject to state and local laws, as well as the policies of our retreat center partners. This means that in some cases additional requirements may exist on top of ELP’s organization policy. As we navigate these continually fluid times of the COVID-19 pandemic, it is important to be grounded in clear and equity-centering policies to ensure the safety of our most vulnerable and most impacted communities.
II. Scope/Applicability
This policy applies to all employees. It also applies to any participants or subcontractors who will be working closely with ELP staff in in-person settings. It does not apply to vendors or visitors.
III. Policy
All ELP employees, with both exempt and nonexempt employment status, are required to be fully vaccinated from COVID-19. Those who are unable to receive the vaccine must obtain an approved medical or religious exception from the requirement. Anyone with an approved exception must wear an approved face-covering throughout the in-person event and must provide proof of a negative PCR test result taken no more than 72 hours prior to any in-person event or setting in lieu of being vaccinated. (Please note that face coverings may also be required for an in-person gathering by the venue, regardless of vaccination status. The venue or ELP may request that all participants wear face coverings in certain circumstances, in alignment with recommended CDC guidelines.)
ELP employees that have received a COVID-19 vaccination will need to provide proof of complete vaccination to Human Resources. Proof of vaccination is defined as a copy of their vaccination card with their full name and date(s) of vaccination. Subcontractors and participants will need to present their proof of vaccination, as described above, to the program director they are working with and Human Resources. Any staff requesting a Medical or Religious Exception must submit a request form and related documentation to Human Resources and their Program Director as soon as possible after vaccination deadlines have been announced.
For purposes of this Guidance, people are considered vaccinated if they have received COVID-19 vaccines currently approved or authorized for emergency use by the U.S. Food and Drug Administration (Pfizer-BioNTech, Moderna, and Johnson & Johnson [J&J]/Janssen COVID-19 vaccines) or COVID-19 vaccines that have been listed for emergency use by the World Health Organization (e.g., AstraZeneca/Oxford)
IV. Vaccine Administration
Employees are responsible for scheduling and obtaining all recommended doses of an approved COVID-19 vaccine as listed in the above policy. You may get the vaccine during your regularly scheduled work hours. ELP will pay employees for time spent getting the vaccine if done during your regular work hours. Any time off needed as a result of experiencing temporary side effects/adverse reactions to the vaccine will not be docked from an employee's sick leave.
V. Request for Exceptions
Religious Accommodation
The Equal Employment Opportunity Commission says employers must provide reasonable accommodations for workers who have sincerely held religious beliefs — unless doing so poses an undue hardship. ELP may provide an exception to employees with sincerely held religious beliefs, observances, or practices that conflict with receiving a COVID-19 vaccine. Religious exception requests by staff may be made by completing the Religious Exception Request Form, which will be reviewed by their supervisor and Human Resources.
Religious exception requests by subcontractors and participants may be made by completing the Religious Exception Request Form, which will be reviewed by their program director.
Medical Reasons
ELP may provide an exception to employees, subcontractors, or participants who have medical documentation from a physician of health considerations that prevent them from receiving the COVID-19 vaccine. Medical exception requests by staff may be made by completing the Medical Exception Request Form, which will be reviewed by their supervisor and Human Resources. Medical exception requests by subcontractors and participants may be made by completing the Medical Exception Request Form, which involves documentation from the person’s medical provider.
ELP reserves the right to request additional documentation supporting the need for a religious or medical exception. ELP will keep confidential any medical information obtained in connection with your request for exception.
Requirements Upon Receiving exception
If you receive an approved medical or religious exception you will be required to follow ELP and ELP-contracted venue protocols for unvaccinated individuals. These will be provided to you.
Determinations
ELP will review each request for a medical or religious exception and will make a determination expeditiously and in a fair and nondiscriminatory manner on a case-by-case basis based on a clear and consistent process. Requestors will be informed of the exception determination, and may be contacted if questions arise during the review process. Exceptions are not guaranteed.
VI. Policy Modification
Government and public health guidelines and restrictions, as well as business and industry best practices regarding COVID-19 and COVID-19 vaccines, are changing rapidly as new information becomes available, further research is conducted, and additional vaccines are approved and distributed. ELP reserves the right to modify this policy at any time in its sole discretion, in order to adapt to changing circumstances and business needs, consistent with its commitment to maintaining a safe and healthy workplace.
VII. Non-Retaliation
ELP prohibits any form of discipline, reprisal, intimidation, or retaliation for reporting a violation of this policy or any other health and safety concern.