OSHA’s COVID-19 Emergency Temporary Standard Publishes in the Federal Register, Triggering Compliance Deadlines for Healthcare Employers
Client Alert | 1 min read | 06.24.21
On Monday, June 21, 2021, OSHA’s COVID-19 Emergency Temporary Standard (the “ETS”), directed at healthcare employers, was published in the Federal Register. This publication triggers a number of deadlines for compliance with various aspects of the ETS, beginning 14 days from publication. Specifically, as of July 5, 2021, employers must adopt certain safety measures to “minimiz[e] employees’ exposure to COVID-19.” Required measures include developing and implementing a COVID-19 plan and workplace hazard assessment and ensuring the safety of workers by providing and requiring face masks (and personal protective equipment, if necessary), physical distancing, screenings for COVID-19 symptoms, and implementing cleaning and disinfection practices. Importantly, the ETS also requires that employers provide paid time off for employees to get vaccinated and recover from any side effects.
Many employers will have already implemented a significant portion of these safety measures or other policies as part of their own efforts to address COVID-19 hazards in the workplace. OSHA anticipates that, even for the employers who have not previously implemented any of the required standards, these measures can be implemented within the 14-day period as they “do not require extensive lead times to implement.”
For the measures that OSHA anticipates will take longer to address, employers have 30 days from publication to comply. By July 21, 2021, employers must install cleanable or disposable barriers outside of direct patient care areas, where physical distancing is not possible, ensure proper ventilation through HVAC systems and filter maintenance, and train workers regarding COVID-19 safety policies and virus transmission in the workplace.
For additional information, please see our prior alert at OSHA Releases Highly Anticipated Safety Rule for Healthcare Employers and Updated Guidance for All Employers.
Contacts
Insights
Client Alert | 3 min read | 10.24.25
On October 23rd, the U.S. Department of Energy (“DOE”) sent a letter to the Federal Energy Regulatory Commission (“FERC”) containing an Advance Notice of Proposed Rulemaking (“ANOPR”) with principles for all large load interconnections across the US, including those co-located with generating facilities.[1] Significantly, the Secretary of Energy states that the interconnection of large loads to the transmission system “falls squarely” within FERC’s jurisdiction, thus weighing in on a dispute that has been pending before FERC for over a year. This move appears to be a reaction to the continued pendency before FERC of the colocation dockets[2] and a technical conference on colocation held almost a year ago.[3]
Client Alert | 3 min read | 10.24.25
Client Alert | 3 min read | 10.23.25
Are You Ready for the Economic Crime and Corporate Transparency Act? Key Changes for Businesses
Client Alert | 8 min read | 10.23.25
Ransomware on the Rise: The Expanding Role of Legal Counsel in Incident Response




