Today FAH submitted comments to the Occupational Safety and Health Administration (OSHA) on its request for comment regarding Occupational Exposure to COVID-19 in Healthcare Settings; Notice of Limited Reopening Comment Period (Notice).  FAH comments primarily focused on urging OSHA to align its requirements with guidance and recommendations issued by the Centers for Disease Control and Prevention (CDC), and the Centers for Medicare & Medicaid Services (CMS), noting that such alignment provides hospitals with flexibility post-rulemaking to implement best evidence-based practices and avoids duplication, confusion, and conflicts between federal agency requirements.

FAH comments also raised procedural concerns with OSHA’s request for public comment in its Notice, highlighting that the Notice discusses that OSHA may implement new provisions, including changes that may result after consideration of public comments, to protect against occupational exposure to COVID-19 in healthcare settings.  Yet, OSHA did not offer any proposed language for such provisions nor any regulatory impact in the Notice.  Thus, the FAH urged that OSHA ensure that stakeholders have the appropriate regulatory opportunity to review and comment on all such changes before they are finalized.

Read the entire letter here.