10 March 2022

OSHA Announces COVID-19 Focused Inspection Initiative in Hospitals and Other Healthcare Facilities

***The information in the client alert below has been updated.  Please visit for the most current  client alert on this subject.***

On March 7, 2022, OSHA announced its plans for a focused, short-term inspection initiative directed at hospitals and other healthcare facilities that treat or handle COVID-19 patients. With this initiative, both federal OSHA and state occupational safety and health agencies, like MIOSHA, will increase their presence in healthcare facilities over the next three-month period (March 9, 2022 to June 9, 2022).

The initiative will focus on the following healthcare facilities: general medical and surgical hospitals, psychiatric and substance abuse hospitals, nursing care facilities, and assisted living facilities for the elderly.  Healthcare facilities with previous COVID-19 citations, inspections, or complaints will be targeted with this initiative, but random inspections of healthcare facilities are also possible.  In short – healthcare providers should prepare for an increase in COVID-19 related inspections and enforcement activity from OSHA and MIOSHA over the next three months.

With these focused inspections, OSHA and MIOSHA will assess a healthcare facility’s COVID-19 mitigation strategies by determining whether previously cited COVID-19 related violations have been corrected or are still in the process of being corrected, and they will also assess a facility’s adherence to applicable OSHA standards such as respiratory protection and hazard communication.  These inspections will also verify the existence and effectiveness of all control measures – including verification of the existence of staff vaccination protocols that may be required by CMS. Importantly, where OSHA or MIOSHA determines that staff vaccination-related deficiencies exist, OSHA will refer such deficiencies to CMS for potential enforcement activity.

As OSHA stated when it announced its decision to withdraw the non-recordkeeping portions of the Healthcare ETS, OSHA will continue to accept compliance with the terms of the Healthcare ETS as satisfying a covered employer’s obligations under the general duty clause, the respiratory protection and PPE standards.

OSHA’s announcement can be found here:

If you have any questions about whether your facility might be subject to a targeted inspection or how to prepare, please contact the authors.