Some of the comments received by the Occupational Safety and Health Administration (OSHA) on its Emergency Temporary Standard, (ETS)1 on COVID-19 in healthcare, include the following:

“This standard is too late. Healthcare facilities responded and served the public as well as possible for the past year and a half, and, once we got the pandemic stabilized, move[d] to mass vaccination processes since December. Now you are requesting to require written documentation and changes to processes that we utilized to survive the pandemic, i.e., increasing masking, screening of patients and visitors, and barrier requirements, at a moment where most healthcare organizations are starting to transition back. … I work in an organization that has a very high vaccination rate and yet some of the standards suggested in this proposal we may not meet, and at this point in our pandemic efforts [are] a waste of time and energy to a labor pool that has already gone above and beyond.”

Deb Renner, private citizen

“I am a pediatrician in a mid-sized private practice in Central Florida. … This is quite onerous. Several of the mandates are not entirely clear, further complicating the ability to implement them. After 16 months of providing a safe environment for our staff and patients and having zero cases of COVID among our staff from the workplace, I am now going to be held to a standard of having to pay employees who stay home, perhaps for weeks on end, while actively and currently struggling to fill open positions that no one wants since many are getting stimulus subsidies. … This timeline is much too short and will be unnecessarily challenging to implement. It is unclear why when the vaccination numbers are rising, and cases are decreasing (especially compared to some past time periods) that there is such an urgency for implementation of something on this grand a scale. … We want to be safe for our patients, their families, our staff, and our families. We just need more time and more clarification, but especially more time.”

Ayanna Rolette, MD, private citizen

“I am a practice administrator of a pediatric office in Cary, NC. I supervise 29 individuals that provide pediatric primary care. Because we do not deny access to children with suspected/confirmed COVID-19 from treatment at our practice, the ETS applies to our workplace and our employees.

“I am concerned that this will reduce children’s access to care. It is very easy to make the COVID ETS not apply to you if you simply refuse to see any child who might have COVID symptoms and instead refer them to the ER. … Finally, I feel that this is at least 12 months late in establishing. The pandemic is in drastic decline and 93% of my staff are vaccinated against COVID 19. I find this whole order to be too much, too late. It needs to be revoked immediately.”

Michael Payne, private citizen

“The Wisconsin Hospital Association (WHA) has received multiple comments from hospital leaders stating that the compliance steps to implement the OSHA rule will be viewed by healthcare workers as a huge disappointment and unnecessary continued burden on their daily jobs. After months of continuous mask wearing, daily screenings, social distancing, and other CDC recommended protocols, workers in healthcare settings, like workers in all industries, are ready for post-crisis normalcy. Unfortunately, just as other industries are removing COVID-19 restrictions and returning to work, implementation of the ETS will create new barriers to healthcare workers’ return to normal, safe infection control practices. The ETS could also have the unintended effect of stymieing efforts to convince reluctant healthcare staff to receive a COVID vaccine. One key incentive for reluctant health are staff to be vaccinated has been the anticipation of a return to normal infection control procedures for vaccinated staff. Maintaining a more stringent standard that is different from CDC, removes that incentive.”

Eric Borgerding, WHA President & CEO


1. 86 Fed Reg 32376 (June 21, 2021).