A Revised Economic Analysis for OSHA’s COVID-19 Vaccination and Testing Emergency Temporary Standard

In November 2021, the Occupational Safety and Health Administration (OSHA) issued a COVID-19 Vaccination and Testing Emergency Temporary Standard (ETS) mandating that employers with 100 or more employees require their workers to vaccinate or telework. OSHA performed an economic feasibility analysis that estimated the ETS would impose $5.2 billion in costs, including testing costs for exempt workers. This paper reviews and revises OSHA’s calculations to present a more thorough regulatory impact analysis than OSHA’s economic feasibility analysis. We find that, had the regulation gone into effect, OSHA’s ETS could have been expected to impose societal costs closer to $10.1 billion (excluding the healthcare sector), roughly double OSHA’s total cost estimate. OSHA could improve its regulatory impact analysis substantially by expanding it beyond economicfeasibility to include both societal costs and benefits.