EEOC Revises Guidelines on Vaccine Exemptions

November 1, 2021

Last week, the Equal Employment Opportunity Commission (“EEOC”) revised its guidelines on religious exemptions to employer vaccine mandates.

The Guidelines apply to employers’ obligations under Title VII of the Civil Rights Act of 1964.

They highlight the individualized, fact-specific nature of each request for an exemption from employer-mandated COVID-19 vaccinations.

Within the Guidelines, the EEOC provides new guidance on how employee requests for an exemption should be made, what an employer may ask its employee in response to a request, what constitutes a “sincere religious belief,” and what constitutes an “undue hardship.”

The EEOC also provided a copy of its own, internal “Religious Accommodation Request Form,” as an example for employers to use in connection with such requests. A copy of the agency’s template can be found here.

Gross Shuman’s Labor & Employment Practice Group is available to assist in addressing any questions you may have regarding these or any other COVID vaccine-related developments. Please contact Kevin Burke, Hugh Carlin, or Katherine Liebner for information relevant to your employment situation.