The Postal Service is asking for a 120-day temporary exemption from the Occupational Safety and Health Administration’s vaccine-and-testing mandate for large employers, citing workforce challenges during its busiest season.

USPS, in a letter dated Tuesday, told OSHA it would be “nearly impossible” to meet the deadlines outlined in its Emergency Temporary Standard (ETS) under normal circumstances, but found them especially taxing to meet during its peak season, which runs from mid-October through January.

“Simply put, the Postal Service does not currently have adequate resources to meet the current ETS deadlines — especially during peak season,” USPS wrote in its letter.

USPS said implementing the ETS “is likely to result in the loss of many employees,” either through workers leaving the agency or facing discipline for non-compliance. The agency predicted the biggest drop-off in staffing would occur among temporary employees brought on to handle a surge in mail and packages during its peak season.

Between Thanksgiving and New Year’s Eve, USPS delivered 13.2 billion letters, cards and packages, more than the 12.7 billion it handled during the same period of time in 2020.

“While the impact to our service could be devastating any time of year, requiring the Postal Service to absorb what could inevitably be a dramatic loss of employees at a time when the labor market is extremely tight and in the middle of the Postal Service’s peak season would have a potentially catastrophic impact on our ability to provide service to the American public when demand is at its highest,” USPS wrote.

USPS spokeswoman Darlene Casey said the agency is seeking temporary relief “because it wants to ensure that its ability to deliver mail and packages is not hindered amid the current disruptions in the nation’s supply chain.”

“The Postal Service will continue to enforce the existing extensive COVID-19 mitigation program to protect our employees and customers nationwide against the effects of COVID-19,” Casey said.

Aside from workforce challenges, USPS said it would need additional time to finalize policy and training materials around the OSHA mandate, purchase the necessary supplies and hold collective bargaining negotiations with its unions around discretionary elements of implementing the requirements.

USPS isn’t covered under the Biden administration’s vaccine mandate for the federal workforce, but the agency falls under OSHA’s mandate for companies with 100 or more employees.

OSHA’s mandate requires employees who are not fully vaccinated to wear face masks and be subject to weekly COVID-19 tests. The agency is providing some exceptions, the Associated Press reports, including for those who work outdoors or only at home.

OSHA said last month it would not issue citations tied to its coronavirus vaccination mandate before Jan. 10, and would not issue citations to companies who fall short of its COVID testing requirements before Feb. 9.

Unlike private-sector businesses, USPS, as a federal entity, has privacy, security, and record-keeping obligations under the Privacy Act. The law sets rules around how agencies can collect, use and disseminate information about individuals in the systems of records they maintain.

USPS says the necessary procedural and administrative steps to ensure its systems of record continue to uphold the Privacy Act will take no less than three months to complete.

USPS told OSHA it is analyzing its record-keeping systems with the intention of creating a process to track vaccination status, testing results and related accommodations for its workforce of more than 650,000 employees.

Meanwhile, the agency is determining whether it will need additional IT infrastructure to ensure the data is stored securely. However, USPS warns obtaining this information from such a large pool of employees will be a “prodigious undertaking.”

“By virtue of being a massive, unique, and complex agency, it can be very difficult and time-consuming to make even modest changes to policies and procedures that impact the working conditions of its employees. This is especially true when the collection and use of medical information is involved,” USPS wrote.

USPS is also in the process of negotiating with its unions over how it would implement the vaccine and testing mandate.

USPS is drafting a COVID-19 vaccination, testing and face-covering policy using a template provided by OSHA, and is exploring options to prepare for required collective bargaining negotiations with its unions around discretionary items within the ETS.

USPS said it may also need to update its timekeeping and payroll systems to provide mandatory paid leave to get vaccinated, test and recover from any side effects of vaccination.

USPS is also asking OSHA for an interim order that would it to use its “alternate means of protection, on a temporary basis, while the courts determine the legality of the ETS.”

USPS in August brought back its mandatory mask policy for all employees — regardless of their vaccination status — if they interact with the public or cannot social distance in the workplace.

Other mitigation practices include a liberal leave policy for COVID-19-related absences and daily updates to its workforce in the form of stand-up talks, articles and other advisories.

Federal courts have blocked OSHA from implementing the mandate, but an appeals court later reinstated it. The Supreme Court will hear oral arguments over the OSHA mandate case on Friday.

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