Signed Memo - Emergency Processing Request

U.S. Department of Labor

Office of the Assistant Secretary
for Administration and Management
Washington, D.C. 20210

Sharon Block
Acting Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget
725 17th Street, NW
Washington, DC 20503
Dear Ms. Block:
Pursuant to Office of Management and Budget (OMB) procedures established at
5 C.F.R. Part 1320, Controlling Paperwork Burdens on the Public, I request that the proposed
information collection, the Request for a Medical Exception or Delay to the COVID-19
Vaccination Requirement, OMB Control No. 1225-0NEW, be processed as an Emergency
Clearance Request in accordance with 5 C.F.R. §1320.13, Emergency Processing.
I have determined that this information must be collected prior to the time periods established
under Part 1320 of the regulations and that this information is essential to implement agencies’
health and safety measures included within recent Centers for Disease Control and Prevention
and Safer Federal Workforce Task Force Guidance. 1 Government agencies have an urgent need
to collect information for individuals applying for medical exemption to the COVID-19
Mandatory Vaccinations and this medical exemption form is necessary for DOL to determine
legal exemptions to the vaccine requirement under the Rehabilitation Act and Americans with
Disabilities Act. Applying regular Paperwork Reduction Act (PRA) clearance procedures is
likely to cause harm because of the threat of COVID-19 exposure and transmission. 2
Therefore, the Department of Labor (DOL) requests a 180-day emergency clearance/approval to
establish the Request for a Medical Exception or Delay to the COVID-19 Vaccination
Requirement allowing individuals to request a legal exception to delay or forego the vaccination
requirement due to a disability or medical condition. During the 180-day approval, DOL and the
Safer Federal Workforce Task Force will work to establish a regular clearance submission of this
information collection request under the PRA procedures. As this request for approval concerns
an urgent safety need, DOL is also seeking OMB’s approval to waive the need for the Federal

See generally Executive Order 14043: Requiring Coronavirus Disease 2019 Vaccination for Federal
Employees (September 9, 2021); Executive Order 13991: Protecting the Federal Workforce and Requiring MaskWearing (January 20, 2021); Executive Order 13994: Ensuring a Data-Driven Response to COVID-19 and Future
High-Consequence Public Health Threats (January 21, 2021). See also Executive Order 12196: Occupational Safety
and Health Programs for Federal Employees, as amended (February 26, 1980) (“The head of each agency shall . . .
[f]urnish to employees places and conditions of employment that are free from recognized hazards that are causing
or are likely to cause death or serious physical harm”).
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Moreover, I have determined that because of the nature of the public health emergency and the urgent need
for this collection, it is impracticable for OPM to consult in advance with interested agencies and members of the
public in order to minimize the burden of the collection of information pursuant to 5 C.F.R. 1320.13(c). OPM
estimates that this collection will entail minimal public burden (ten minutes per response). OPM will consult with
other agencies through the Safer Federal Workforce Task Force.
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Register Notices otherwise required by 5 C.F.R. 1320.5(a)(1)(iv) and 1320.8(d)(1) prior to
publication and implementation of this form.
We would appreciate if you could please provide an approval/disapproval determination of this
request to collect information under the emergency clearance by the close of business on
November 18, 2021.
Respectfully,

Rachana Desai Martin    
Assistant Secretary for Administration and Management

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