OSHA Directive describes procedures for conducting inspections under the new COVID-19 ETS

Posted July 2, 2021

A new OSHA Directive describes the procedures for conducting inspections under the COVID-19 Emergency Temporary Standard (ETS). The Directive, written to help OSHA Compliance Safety and Health Officers understand what to look for during an inspection, can also assist healthcare employers in preparing for a COVID-19-related inspection.

The June 21, 2021, COVID-19 ETS requires healthcare employers to reduce transmission of COVID-19 in the workplace. These employers must take steps control COVID-19 hazards, which may include screening, physical distancing, controls for aerosol-generating procedures, physical barriers, personal protective equipment, cleaning and disinfection, ventilation, employee health screening and medical management, vaccination, training, anti-retaliation, recordkeeping and reporting.

The Directive provides uniform inspection and enforcement procedures for OSHA CSHOs to follow in enforcing the ETS for workplace exposures to the SARS-CoV-2 virus. Of note, all COVID-19-related inspections will include a review of the employer’s COVID-19 plan and related documents. Other areas of review will include verifying that the employer conducted a hazard assessment; determining whether the employer has administrative and engineering controls in place; assessing compliance with the respiratory protection program; and reviewing employee training records.

CSHOs will issue citations for violations of the ETS if the employer has not developed or implemented a COVID-19 plan for each worksite or if a facility is missing required parts of the plan.

This article was written by Lisa Neuberger of J. J. Keller & Associates, Inc.