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February 7, 2022 2:55 PM

Amended recommendation: employers require workforce to show proof of primary vaccination or at least twice weekly testing

This Sonoma County Health Order is no longer in effect. This content is provided for historical reference only.

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On December 28, 2021, Dr. Sundari Mase, Sonoma County Health Officer, issued a recommendation that all employers in the County consider requiring workers to provide proof of full vaccination for COVID-19, including a booster if eligible, or show proof of at least twice weekly COVID-19 testing.  However, at this time, testing availability is not sufficient to accommodate this recommendation. Therefore, Dr. Sundari Mase is issuing this interim amended recommendation until adequate amounts of testing supplies are available.

This recommendation is made in light of the emergence of the Omicron variant of SARS-CoV-2, the virus that causes COVID-19, and the imminent threat that it poses to the health of vulnerable residents and the capacity of the healthcare system.  Emerging evidence indicates that the Omicron variant is significantly more transmissible than prior variants of the virus, and that individuals who have had only their initial vaccine series and are eligible for the booster, are susceptible to the Omicron variant. However, initial evidence also shows that individuals who have received a booster shot increase their immunity to a level that confers more protection from all circulating SARS-CoV-2 variants, including the Omicron variant.  The CDC and the CDPH now recommend that all eligible persons receive a booster shot because immunity wanes several months after completion of the initial vaccine series. Individuals who have not received a booster shot are more likely to become infected and spread infection to others, and more likely to become seriously ill or die.

Dr. Sundari Mase recommends that employers should consider requiring employees to provide proof of full vaccination for COVID-19, including a booster if eligible.  Employees who are unvaccinated, as well as employees who have not received a booster (if eligible), should be required to wear FDA-cleared surgical masks or respirators in indoor work settings.

When testing supplies are available in adequate amounts, employees who are unvaccinated should show proof of at least twice weekly COVID-19 testing, or once a week testing if they work less than twice a week.  Employers should exercise discretion to determine if testing supplies are sufficient to prioritize unvaccinated staff until adequate supplies are available.

This recommendation is currently optional for most employers. Employers can play a critical role in ensuring a safe workplace environment and increasing vaccination rates among working-age individuals.  A vaccination policy benefits employers because the quarantine requirements are different for vaccinated and unvaccinated workers.  Currently, an employee who is not vaccinated must quarantine for at least 5 days if exposed to someone who tested positive, whereas fully vaccinated and boosted workers do not need to quarantine unless they have symptoms. Requiring documentation of COVID-19 vaccination, rather than self-attestation, is the best practice for employers to ensure workers are adhering to the appropriate workplace protections.  Additional employer resources are available from the California Department of Fair Employment and Housing.

On Dec. 23, 2021, Dr. Sundari Mase issued an order requiring all employers of fire, law enforcement, emergency medical service workers, pharmacies, dental offices and operators of temporary disaster shelters in Sonoma County to require personnel to get tested at least twice weekly for COVID-19 or produce satisfactory evidence that they have received a booster for COVID-19 (if eligible). Separately, an additional health order was issued for education workers with the same requirements.  The compliance date for surveillance testing of the non-boosted employees was extended until March 1, 2022, or earlier if adequate testing supplies are available; unvaccinated employees continue to be required to undergo weekly surveillance testing.

The COVID-19 vaccine is safe, convenient, and free regardless of immigration status or proof of health insurance. For information about finding a COVID-19 vaccine location, visit Sonoma County COVID-19 Vaccine Information – Sonoma County Emergency and Preparedness Information (socoemergency.org). For more information about free COVID-19 testing visit: COVID-19 Testing & Tracing in Sonoma County – Sonoma County Emergency and Preparedness Information (socoemergency.org).


Dr. Sundari R. Mase, MD MPH
Health Officer of the County of Sonoma