OSHA vaccine-or-test rule drew employer-association template
The Occupational Safety and Health Administration received 3,162 nearly identical comments in late 2021 opposing the emergency temporary standard that required large employers to mandate COVID-19 vaccination or weekly testing. The campaign argued that the rule exceeded OSHA's authority over general public-health measures not specific to workplace hazards.
Campaign window
31 days · 3,162 comments detected
Shape of the campaign
Each red dot is one comment that matched the campaign's template text. Grey dots are unrelated submissions to the same docket. The clustering algorithm groups comments by semantic similarity, not by exact string match, so light wording changes don't hide the pattern.
Scale
The template
“I own a 130-employee manufacturing business. The OSHA vaccine-or-test emergency temporary standard is an unprecedented federal mandate that exceeds OSHA's statutory authority over workplace-specific hazards. COVID-19 is a general public-health risk that affects people at home, at the grocery store, and in the workplace alike. OSHA's authority is limited to occupational hazards. Congress, not OSHA, should decide whether to mandate vaccines for the broader public.”
Attribution
Who organized this?
The NFIB and allied business groups distributed template opposition letters through their small-business networks, arguing the ETS was an unconstitutional exercise of emergency authority over a non-workplace-specific health risk.
Attribution is based on publicly available evidence. It does not imply wrongdoing.
Migration analysis
Did the campaign's language make it into the final rule?
OSHA published the vaccine-or-test ETS despite the campaign's opposition. The campaign's framing did not appear in the operative ETS text — it appeared instead in the Supreme Court's January 2022 stay opinion, which is not part of the rule itself.
Phrase overlap is correlation, not causation. Many advocates and agency staff use the same vocabulary; matching language is not evidence the campaign drafted the rule.
Rule outcome
Did it influence the final rule?
The Supreme Court stayed OSHA's vaccine-or-test ETS in January 2022 (National Federation of Independent Business v. OSHA), finding that OSHA likely exceeded its authority. OSHA subsequently withdrew the ETS.
Rule outcomes are matters of public record. Astroturf does not claim the campaign caused or prevented the outcome.
> Technical details
curated-osha-2021-0007-f4fb0bca7bbb21dfDocket IDOSHA-2021-0007Finding slugosha-vaccine-or-test-rule-drew-employer-association-template-dd298eGeneratedManual (edited)