New Year, New Rules: Chicago and Cook County Will Require Proof of Vaccination to Enter Most Public Establishments as of January 3, 2022

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Hey Compliance Warriors!


Check out this interesting update by Yara Mroueh, Carly Zuba, and Devjani Mishra on December 23, 2021

Updated December 27, 2021: Cook County, Illinois has implemented Cook County Public Health Order 2021-11, imposing the same vaccine requirements as those implemented under Chicago’s Public Health Order, discussed below, including the same January 3, 2022 effective date.


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On December 21, 2021, Mayor Lori Lightfoot issued Public Health Order 2021-2, a vaccine mandate for certain public accommodations that is meant to help curb the spread of COVID-19 as the Omicron variant continues to surge.


Effective January 3, any individual age five and older will be required to show proof of full vaccination to dine indoors, visit gyms, or enjoy entertainment venues where food or drink are being served. The requirement exempts children under five years old and individuals entering an establishment for less than 10 minutes for the purpose of ordering and carrying out food, making a delivery, or using the bathroom.  This public health order will remain in effect until the risk of overwhelming the city’s hospital capacity has passed. 


Which Establishments are Covered?

Effective January 3, 2022, proof of full vaccination will be required to enter the following establishments:

  • Any establishment where food and beverages are served, including restaurants; bars; fast food establishments; coffee shops; tasting rooms; cafeterias; food courts; dining areas of grocery stores; breweries; wineries; distilleries; banquet halls; and hotel ballrooms.
  • Gyms and fitness establishments, including gyms; recreation facilities; fitness centers; yoga, Pilates, cycling, barre, and dance studios; hotel gyms; boxing and kickboxing gyms; fitness bootcamps; and facilities that provide indoor group fitness classes.
  • Indoor entertainment and recreation venues where food or beverages are served, including movie theaters; music and concert venues; live performance venues; adult entertainment venues; commercial event and party venues; sports arenas; performing arts theaters; bowling alleys; arcades; card rooms; family entertainment centers; play areas; pool and billiard halls; and other recreational game centers.

The vaccination requirement excludes houses of worship, K-12 schools, locations in O’Hare International Airport or Midway International Airport, locations in residential or office buildings (such as gyms or cafeterias) the use of which is limited to residents, owners, or tenants of that building, and food service establishments providing only charitable food services, such as soup kitchens.


What is Considered Proof of Full Vaccination?

Proof of full vaccination may be established through (1) a CDC COVID-19 Vaccination Record Card; (2) an official immunization record from the jurisdiction, state, or country where the vaccine was administered; or (3) a digital or physical photo of such a card or record, reflecting the person’s name, vaccine brand, and dates administered. Additionally, individuals over the age of 16 will need to provide identification with the same identifying information as the proof of vaccination, such as a valid photo ID. While covered entities are not expected or required to maintain copies of CDC Vaccination Record Cards, they are required to document verification and compliance with the Order. Such documentation should be in writing and must be available for inspection upon request of any city official authorized to enforce the Order.


To Whom Does the Mandate Apply?

The vaccination mandate applies to all patrons age five and older. While proof of vaccination will not be required for employees, unvaccinated employees will be required to provide proof of a negative COVID-19 test on a weekly basis and to wear a mask when interacting with patrons.

While the Order itself does not go into specifics regarding the weekly testing requirement, it does specify that all covered entities must comply with OSHA standards 1910.501(e) & (g) relating to employee vaccination status and testing, regardless of the number of their employees. Thus, covered establishments should review and comply with OSHA standards 1910.501(e) & (g) when it comes to determining employee vaccination status and setting up a weekly testing program for unvaccinated employees. 


What Else is Required of Covered Establishments?

All covered establishments must prominently post information informing patrons of the full vaccination requirement. Signage is required at each publicly accessible entrance of the establishment and at least one location inside that is conspicuous. Of importance, establishments will also be required to develop and keep records of their protocol for enforcing the vaccine requirement, and the Chicago Department of Public Health (CDPH) makes a sample available here. The CDPH also provides required signage, FAQs, and additional guidance to businesses and employers through its website.


Enforcement will involve progressive discipline, starting with warnings. Establishments failing to comply after a warning has been issued will be fined. Closure of the establishment is available as a penalty of last resort.


Public Health Order 2021-2 does not disrupt the city’s ongoing mask mandate, which remains in effect until further notice.


Your Breaking News on the subject will be right here at HelpDeskforHR.com.


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Lisa Smith, SPHR, SHRM – SCP

Certified EEO Investigator (EEOC)

Lead Support and Content Chief – HelpDeskforHR.com

“You cannot be audit-proof, but you can Be Audit-Secure.”


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