Employers, Prepare Yourselves: OSHA to Begin Inspections to Ensure Compliance with COVID-19 Regulations

March 16, 2022

Over the next three months, the Occupational Safety and Health Administration (OSHA) intends to inspect healthcare facilities that have been issued Hazard Alert Letters to “verify and assess compliance actions taken” related to COVID-19 safety violations. A “healthcare facility” is any setting where an employee provides healthcare services or healthcare support services. Examples include hospitals, outpatient clinics, and private doctor’s offices.



Although this initiative will not create any new obligations upon healthcare employers, the current Healthcare ETS remains in effect, obligating healthcare facilities to maintain records of employees who have been positive for COVID-19 and report all COVID-19 related hospitalizations and deaths.

OSHA will accept continued compliance with the Healthcare ETS as one method of satisfying employers’ existing obligations under OSHA regulations.


Inspections for facilities selected as part of this initiative will fall into several categories: (1) follow-up inspections where a COVID-19-related citation or hazard alert letter (HAL) was issued; (2) follow-up or monitoring inspections for randomly selected closed COVID-19 unprogrammed activity (UPA); or (3) monitoring inspections for randomly selected, remote-only COVID-19 inspections where previous citations were issued.


Each inspection will include an assessment of COVID-19 mitigation strategies. The 22 states with approved State OSHA Plans are not required to implement this initiative. Massachusetts is a federal OSHA state, and therefore must abide. Connecticut, however, has an OSHA-approved state plan that only covers local and state government workers, not private sector employees.


Employers should remain cognizant of state and local vaccine mandates and other requirements that may impact COVID safety procedures. It is highly recommended that employers retain counsel to assess COVID-related safety measures to ensure full compliance with the latest OSHA regulations.


If you are a healthcare facility and would like more information on OSHA inspections or legal counsel in assessing OSHA compliance for your business, please contact the attorneys at The Royal Law Firm at (413)-586-2288.

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