OSHA: Emergency Temporary Standard Update


OSHA has issued its emergency rule for healthcare workers; the goal is to reduce healthcare workers’ risk of contracting COVID-19 in the workplace.  The ETS was effective upon publication on June 21, 2021, and eligible employers must comply with most provisions by July 6, 2021.  Provisions such as physical barriers, ventilation, and training must be implemented by July 21, 2021.


  • Create a plan
  • Screen and monitor patients
  • Implement standards and transmission-based precautions based on CDC guidelines
  • Implement ventilation requirements
  • Require personal protective equipment (PPE)
  • Provide airborne infection isolation rooms
  • Instill physician barriers and social distancing
  • Clean and disinfect spaces
  • Provide daily health screening for employees
  • Quarantine when needed
  • Provide medical removal benefit protection
  • Train staff on COVID-19 procedures
  • Accommodate for vaccinations (time off to receive and recover if needed from adverse side effects)
  • Do not retaliate against employees who contract COVID-19
  • Keep records of COVID-19 incidents


  • Non-hospital ambulatory clinics
    • If all non-employees are screened prior to entry and not allowed entry if COVID-19 is suspected
  • Hospital ambulatory clinics in a well-defined space or home health
    • If all employees are vaccinated
    • Vaccine exception for documented medical or religious reasons
  • All healthcare entities can be exempt from the PPE, physical barrier, and distancing requirements if:
    • All employees are vaccinated and no persons with or suspected of having COVID are present. (does require screening)
  • Additional resources:  https://www.osha.gov/sites/default/files/publications/OSHA4125.pdf

Please visit  https://www.osha.gov/sites/default/files/covid-19-healthcare-ets-reg-text.pdf for more detailed information on the final rule – Subpart U- COVID-19 Emergency Temporary Standard (ETS).

If you have any questions, please reach out to our healthcare advisory team.