Scope and application

Under 1910.502(a)(1), this standard applies to all settings where any employee provides healthcare services or healthcare support services unless an exemption applies. Employers should treat any workplace where employees deliver or support healthcare (for example, hospitals, long‑term care, ambulance services, clinics, patient transport) as within scope unless one of the specific exclusions in 1910.502(a)(2) applies. See also the definition of "healthcare services" in 1910.502(b).

Under 1910.502(a)(2), the standard does not apply to several specific settings and activities listed in that paragraph. These exclusions include: the provision of first aid by an employee who is not a licensed healthcare provider; dispensing prescriptions by retail pharmacists; certain non‑hospital ambulatory care settings that screen out people with suspected/confirmed COVID‑19; well‑defined hospital ambulatory care or home healthcare settings where all employees are fully vaccinated and non‑employees are screened and excluded if suspected/confirmed COVID‑19 is present; healthcare support services performed off‑site (e.g., off‑site laundry, billing); and telehealth services performed outside direct patient care settings. See 1910.502(a)(2) and its subparagraphs 1910.502(a)(2)(i)–(vii).

Under 1910.502(a)(2)(i), the standard does not apply to the provision of first aid by an employee who is not a licensed healthcare provider. That means routine first aid given by non‑licensed staff is excluded from this standard's scope. For the exact exclusion, see 1910.502(a)(2)(i).

Under 1910.502(a)(2)(ii), the standard does not apply to the dispensing of prescriptions by pharmacists in retail settings. Retail pharmacy prescription dispensing is therefore excluded from this healthcare standard. See 1910.502(a)(2)(ii).

Under 1910.502(a)(2)(vii), telehealth services performed outside a setting where direct patient care occurs are not covered by this standard. So providers delivering care remotely from locations that do not involve in‑person patient contact fall outside the rule’s scope. See 1910.502(a)(2)(vii).

Under 1910.502(a)(2)(iv) and (v), well‑defined hospital ambulatory care areas and home healthcare settings can be excluded from the standard when all employees are fully vaccinated, non‑employees are screened prior to entry, and people with suspected or confirmed COVID‑19 are not permitted to enter or are not present. Employers relying on these exemptions must meet those conditions. See 1910.502(a)(2)(iv) and 1910.502(a)(2)(v). Note also that OSHA clarifies employers are not precluded from extending exemptions to employees who cannot be vaccinated when reasonable accommodations keep them from COVID‑19 hazards (see the paragraph immediately following 1910.502(a)(2)).

Under 1910.502(a) and the following explanatory paragraph, an employer who reasonably accommodates an employee unable to be vaccinated in a way that does not expose the employee to COVID‑19 hazards (for example, telework or working in isolation) may still qualify for the exemptions in 1910.502(a)(2)(iv) and 1910.502(a)(2)(v). Employers should document how accommodations remove the employee from COVID‑19 exposure to rely on those scope exemptions. See 1910.502(a).

Under 1910.502(a)(3)(i), when a healthcare setting is embedded within a non‑healthcare setting (for example, a medical clinic inside a manufacturing facility or retail store), the standard applies only to the embedded healthcare setting and not to the remainder of the physical location. Employers should clearly define and document the boundaries of the embedded healthcare area. See 1910.502(a)(3)(i).

Under 1910.502(a)(3)(ii), when emergency responders or other licensed healthcare providers enter a non‑healthcare setting to provide healthcare services, the standard applies only to the provision of healthcare services by that employee—not to the entire non‑healthcare workplace. The employer should ensure appropriate protections for those healthcare activities. See 1910.502(a)(3)(ii).

Under 1910.502(a)(4), paragraphs (f), (h), and (i) do not apply to fully vaccinated employees in well‑defined areas where there is no reasonable expectation that any person with suspected or confirmed COVID‑19 will be present. Employers relying on this must ensure the area is well defined and that the absence of suspected/confirmed cases is reasonable. See 1910.502(a)(4).

Under 1910.502(c)(1)–(3), the employer must develop and implement a COVID‑19 plan for each workplace (workplace‑type grouping is allowed when workplaces are substantially similar), designate one or more workplace COVID‑19 safety coordinators to implement and monitor the plan, and, if the employer has more than 10 employees, keep the plan in writing. The safety coordinator(s) must have authority to ensure compliance. See 1910.502(c)(1), 1910.502(c)(2), and 1910.502(c)(3).

Under 1910.502(c)(2), if an employer has more than 10 employees, the COVID‑19 plan must be written. Employers with 10 or fewer employees may have a plan that is not written, but written plans improve clarity and consistency. See 1910.502(c)(2).

Under 1910.502(c)(3)–(4), the employer must designate safety coordinator(s) who have the authority to ensure compliance with the COVID‑19 plan, and must conduct a workplace‑specific hazard assessment to identify COVID‑19 hazards. The assessment is the basis for the plan’s controls. See 1910.502(c)(3) and 1910.502(c)(4)(i).

Under 1910.502(c)(4)(ii), to be exempt from providing controls in a well‑defined area under 1910.502(a)(4) based on employees’ fully vaccinated status, the COVID‑19 plan must include policies and procedures to determine employees’ vaccination status. Employers should document the method used to verify vaccination. See 1910.502(c)(4)(ii).

Under 1910.502(c)(5), yes — the employer must seek the input and involvement of non‑managerial employees and their representatives, if any, in the hazard assessment and the development and implementation of the COVID‑19 plan. Involving frontline employees helps identify practical hazards and workable controls. See 1910.502(c)(5).

Under 1910.502(c)(6), the employer must monitor each workplace to ensure the ongoing effectiveness of the COVID‑19 plan and update the plan as needed. Monitoring can include workplace inspections, review of illness reports, employee input, and adjustments for changes in public health guidance or workplace conditions. See 1910.502(c)(6).

Under 1910.502(c)(7) and (c)(7)(ii)(A), each employer whose employees share the same physical location must effectively communicate its COVID‑19 plan to other employers at that location, coordinate to ensure all employees are protected per the standard, and adjust plans to address hazards presented by other employers’ employees. In practice, this means sharing procedures, coordinating schedules/areas, and ensuring that controls protect all workers on site. See 1910.502(c)(7) and 1910.502(c)(7)(ii)(A).

Under 1910.502(b), only the listed medical procedures are considered aerosol‑generating procedures: open suctioning of airways; sputum induction; cardiopulmonary resuscitation; endotracheal intubation and extubation; non‑invasive ventilation (e.g., BiPAP, CPAP); bronchoscopy; manual ventilation; medical/surgical/postmortem procedures using oscillating bone saws; and specific dental procedures such as use of ultrasonic scalers, high‑speed handpieces, air/water syringes, air polishing, and air abrasion. Employers should treat these procedures as higher risk for airborne transmission and use appropriate controls. See 1910.502(b).

Under 1910.502(b), a facemask (surgical/medical procedure mask) is not a respirator; respirators are NIOSH‑certified or EUA‑authorized devices such as filtering facepiece respirators, elastomeric respirators, or PAPRs. The rule explicitly states that face coverings, facemasks, and face shields are not respirators. See 1910.502(b).

Under 1910.502(b), "fully vaccinated" means 2 weeks or more after receiving the final dose of a COVID‑19 vaccine. Employers must use that definition when applying vaccination‑based policies or exemptions in the rule. See 1910.502(b).

Under 1910.502(b), "screen" means asking questions to determine whether a person is COVID‑19 positive or has COVID‑19 symptoms. Screening is used in several scope exemptions (for example, to ensure non‑employees with suspected or confirmed COVID‑19 are not permitted entry) and in workplace controls where required. See 1910.502(b).

Under 1910.502(c), surgical masks are generally regulated by FDA as Class II devices under 21 CFR 878.4040; employers should be aware that masks described as "surgical" or "medical procedure masks" may fall under FDA regulatory requirements in addition to OSHA considerations. See 1910.502(c).

Under 1910.502(a) Note 1 and Note 2, nothing in the standard is intended to limit state or local government mandates or guidance that go beyond and are not inconsistent with the rule, and employers are encouraged (but not required by this rule) to follow CDC public health guidance even when the standard does not require it. Employers must comply with any applicable state or local orders that are more stringent. See 1910.502(a).

No — as of the memorandum dated February 5, 2025, OSHA announced an immediate enforcement stay and will not enforce the COVID‑19 recordkeeping and reporting requirements in 29 CFR 1910.502 (including the COVID‑19 log and reporting COVID‑19 fatalities and hospitalizations) until further notice. However, OSHA will continue to enforce applicable recordkeeping requirements under 29 CFR Part 1904. See OSHA’s enforcement stay memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05 and the standard at 1910.502.

Under 1910.502(c)(7)(ii)(B), delivery people, messengers, and other employees who only enter a workplace briefly to drop off or pick up items are exempt from that requirement. See the specific provision at 1910.502(c)(7)(ii)(B).

• This means workers who make very short visits (brief drop-offs/pick-ups) are not covered by that paragraph’s obligations.
• If a worker stays longer or performs other duties, the exemption would not apply and the employer should follow the applicable protective measures in the standard.

Under 1910.502(c)(7)(iii), the employer must notify the controlling employer when its employees are exposed to conditions at that location that do not meet the requirements of the standard. See 1910.502(c)(7)(iii).

• Notification should explain the deficiencies so the controlling employer can address them.
• Employers must also protect employees who enter private residences or locations controlled by persons not covered by the OSH Act and have procedures for withdrawal if protections are inadequate (also in 1910.502(c)(7)(iii)).

Under 1910.502(d)(1), an employer in a setting where direct patient care is provided must limit and monitor points of entry to the setting. See 1910.502(d)(1).

• Limiting and monitoring entry helps control who enters, enables screening, and reduces potential exposure risks.
• Employers should use practical measures (staffed checkpoints, signage, controlled doors) to implement this requirement.

Under 1910.502(d)(2) and (d)(3), employers must screen and triage all clients, patients, residents, delivery people, other visitors, and other non-employees entering the setting, and implement patient-management strategies in accordance with CDC recommendations incorporated by reference. See 1910.502(d)(2) and 1910.502(d)(3).

• Employers are encouraged to use telehealth where appropriate to reduce entries.
• Follow CDC’s “COVID-19 Infection Prevention and Control Recommendations” as incorporated by reference in 1910.502(d)(3).

Under 1910.502(f)(1)(ii), employers must ensure a facemask is worn by each employee over the nose and mouth when indoors and when occupying a vehicle with other people for work purposes. See 1910.502(f)(1)(ii).

• This requirement applies to indoor workspaces and shared work vehicles.
• The facemask must meet the definition in paragraph (b) of the section as required by 1910.502(f)(1)(i).

Under 1910.502(f)(1)(i) and 1910.502(f)(1)(iii), employers must provide facemasks that meet the section’s definition and provide enough so employees change them at least once per day, whenever soiled or damaged, and more frequently as necessary. See 1910.502(f)(1)(i) and 1910.502(f)(1)(iii).

• Employers must supply a sufficient number of facemasks so employees can comply with the change-frequency rules.
• Change a facemask immediately if it becomes soiled, damaged, or when workplace conditions (e.g., patient care) require more frequent changes.

Under 1910.502(f)(1)(iii)(A)–(F), the standard lists specific exceptions where an employee need not wear a facemask indoors, including: when alone in a room; while eating or drinking if at least 6 feet from others or separated by a barrier; when wearing respiratory protection per [1910.134]; when seeing a person’s mouth is necessary and conditions don’t permit a clear facemask; when employees cannot wear facemasks due to certain medical disabilities or religious beliefs (with face-shield alternatives as appropriate); and when facemasks present a hazard (e.g., arc flash, heat stress) and alternative protection and distancing are used. See 1910.502(f)(1)(iii).

• When exceptions apply, employers must still provide alternatives (for example, face shields) and ensure additional protections such as distancing when required.
• The employer should document and implement measures for each exception consistent with the standard.

Under 1910.502(f)(1)(iii)(E), employers must allow exceptions for a narrow subset of persons with disabilities who cannot safely wear a facemask and, when feasible, ensure those employees wear a face shield for their protection. See 1910.502(f)(1)(iii)(E).

• Employers must follow applicable laws such as the Americans with Disabilities Act when evaluating accommodations.
• If a face shield is feasible, the employer must ensure it is used and cleaned per 1910.502(f)(1)(iv).

Under 1910.502(f)(1)(iv), when a face shield is required or otherwise required by the employer, the employer must ensure that face shields are cleaned at least daily and are not damaged. See 1910.502(f)(1)(iv).

• Daily cleaning is the minimum; increased cleaning frequency may be necessary based on use and contamination risk.
• Damaged face shields must be replaced to maintain effective protection.

Under 1910.502(f)(2)(i)–(ii), employers must provide a respirator to each employee and ensure it is used in accordance with [1910.134], and must provide gloves, an isolation gown or protective clothing, and eye protection to each employee, ensuring use in accordance with Subpart I. See 1910.502(f)(2)(i) and 1910.502(f)(2)(ii).

• Respirator use must follow OSHA’s Respiratory Protection Standard at 1910.134.
• The other PPE must meet requirements in Subpart I (personal protective equipment) and be supplied to employees for suspected or confirmed cases.

Under 1910.502(f)(3) and 1910.502(g), employers must provide a respirator in accordance with [1910.134], gloves, an isolation gown or protective clothing, and eye protection during aerosol-generating procedures, limit the number of employees present to only those essential, perform the procedure in an existing airborne infection isolation room (AIIR) if available, and clean and disinfect surfaces and equipment after the procedure. See 1910.502(f)(3)(i), 1910.502(f)(3)(ii), and 1910.502(g).

• Use of respirators should follow fit-testing and program requirements in 1910.134.
• After the procedure, employers must clean/disinfect per 1910.502(g)(3).

Under 1910.502(f)(4)(i), yes—the employer may provide a respirator to the employee instead of a facemask as required by paragraph (f)(1). See 1910.502(f)(4)(i).

• If a respirator is provided and used, the employer must ensure respirator use complies with the Respiratory Protection Standard at 1910.134, including fit-testing and training as applicable.

Under 1910.502(h)(1)–(2), employers must ensure employees are separated from all other people by at least 6 feet when indoors unless the employer can demonstrate such distancing is not feasible for a specific activity, and momentary exposures while people are moving (e.g., passing in hallways) are exempt. See 1910.502(h)(1) and 1910.502(h)(2).

• If 6-foot distancing is not feasible, the employer must ensure employees are as far apart as feasible.
• The standard gives examples (telework, spacing, barriers, staggered schedules) to help employers meet distancing obligations.

Under 1910.502(i), employers must install cleanable or disposable solid physical barriers at each fixed work location outside direct patient care areas where employees are not separated from others by at least 6 feet, except where not feasible; the note specifies barriers are not required in direct patient care areas or resident rooms. See 1910.502(i).

• Barriers should be sized and located to block face-to-face pathways (see 1910.502(j) note and related text).
• Pass-through spaces at the bottom are allowed for exchanging objects.

Under 1910.502(j)(1), employers must follow standard practices for cleaning and disinfection of surfaces, resident rooms, and medical devices and equipment in patient care areas in accordance with CDC recommendations incorporated by reference. See 1910.502(j)(1).

• Follow the CDC’s “COVID-19 Infection Prevention and Control Recommendations” and CDC’s “Guidelines for Environmental Infection Control” where applicable.
• Use appropriate disinfectants and cleaning intervals based on CDC guidance and the type of surface or equipment.

Under the note to 1910.502(f)(2), when there is a limited supply of filtering facepiece respirators, employers may follow the CDC’s “Strategies for Optimizing the Supply of N95 Respirators.” See 1910.502(f)(2) note for the reference to the CDC strategies.

• Those CDC strategies include options like extended use, limited reuse, and prioritizing respirator use for higher-risk procedures, but employers must still meet OSHA respirator program requirements in 1910.134.
• Employers should document their approach and ensure worker protection remains effective.

Under 1910.502(d)(2), yes—this provision does not apply when emergency responders or other licensed healthcare providers enter a non-healthcare setting to provide healthcare services. See 1910.502(d)(2).

• The exemption recognizes the different operational needs of emergency and licensed providers responding in non-healthcare environments.
• Employers should still consider relevant infection-control practices appropriate for the situation.

Under 1910.502(f)(2), when an employee provides a face shield that meets the definition in the section, the employer may allow its use and is not required to reimburse the employee for that face shield. See 1910.502(f)(2).

• Employers may still choose to provide or reimburse for PPE but the standard does not require reimbursement if the employee supplies an acceptable face shield.
• Ensure any employee-provided face shield meets the employer’s protection and cleaning requirements (see 1910.502(f)(1)(iv)).

Under 1910.502(i), barriers may have a pass-through space at the bottom for objects and merchandise, and under 1910.502(j)(1) employers must follow CDC-recommended cleaning and disinfection practices in patient care and related areas. See 1910.502(i) and 1910.502(j)(1).

• The pass-through should be sized to allow objects while still reducing face-to-face exposure.
• Clean and disinfect surfaces on and around barriers and pass-through openings per CDC guidance referenced in 1910.502(j)(1).

As of the memorandum dated February 5, 2025, OSHA announced it will not enforce the COVID-19 recordkeeping and reporting requirements under 1910.502(q) and 1910.502(r) until further notice. See OSHA’s memorandum at COVID-19 recordkeeping enforcement stay.

• OSHA will continue to enforce recordkeeping requirements under 29 CFR part 1904, but not the COVID-19-specific log and reporting provisions of 1910.502 for the time being.
• Employers should still maintain appropriate records under other applicable OSHA rules and monitor OSHA communications for any change in enforcement status (see the memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05).

Yes — employers must use MERV‑13 or higher filters if the HVAC system is compatible, and if not compatible they must use the highest-efficiency filter that the system can support and keep filters maintained and replaced as needed. See the requirement in 1910.502(k)(1)(iii) that all air filters be rated MERV‑13 or higher if compatible, and the maintenance requirement in 1910.502(k)(1)(iv) that filters be maintained and replaced as necessary to ensure proper HVAC performance. Also note that the standard does not require installing new HVAC systems or AIIRs to comply with these provisions (see Note 1 to paragraph (k)).

The employer must clean and disinfect any areas, materials, and equipment the COVID‑19 positive person likely contaminated when the employer is aware that the person was in the workplace within the last 24 hours. This is required by 1910.502(j)(2)(ii), and the cleaning and disinfecting must be done in accordance with CDC’s "Cleaning and Disinfecting Guidance," which is incorporated by reference in the standard (1910.509). Employers should follow manufacturers’ directions for cleaners and pay particular attention to rooms and items the infected person occupied or touched.

The employer must, within 24 hours of learning a person who was in the workplace is COVID‑19 positive, notify: employees who were not wearing a respirator and other required PPE and were in close contact with that person; other employees who were not wearing required PPE and worked in the same well‑defined portion of the workplace where that person was present during the potential transmission period; and other employers whose employees meet the same exposure conditions. See 1910.502(l)(3)(i) and the specific notification requirements in 1910.502(l)(3)(i)(A)–(C). The notification must state that the employee was in close contact with someone who is COVID‑19 positive and must include the date(s) of contact but must not include any employee’s name or contact information, per 1910.502(l)(3)(ii).

Yes — if an employee meets the criteria in paragraphs (l)(2)(ii)–(iv), the employer must immediately remove the employee and either keep them removed until return‑to‑work criteria are met or keep them removed and provide a COVID‑19 PCR test at no cost. If the PCR test is negative, the employee may return to work immediately; if positive, the employer must follow the removal requirements in [1910.502(l)(4)(i)]. If the employee refuses the test, the employer must keep the employee removed consistent with the option to keep them removed until return criteria are met, but the employer is not obligated to provide medical removal protection benefits for that employee. See 1910.502(l)(4)(ii)(B) and its subparts 1910.502(l)(4)(ii)(B)(1)–(3).

Employers with more than 10 employees on the effective date must establish and maintain a COVID‑19 log that records each instance the employer identifies an employee as COVID‑19 positive, including the employee’s name, contact information, occupation, work location, last day at the workplace, test/diagnosis date, and symptom onset date — and the log entry must be made within 24 hours and kept as a confidential medical record. Those employers must also provide employees (and authorized representatives) access to the written COVID‑19 plan and COVID log entries as described in 1910.502(q)(2)(ii) and 1910.502(q)(3). However, OSHA has issued an enforcement memorandum stating that, effective immediately and until further notice, OSHA will not enforce the COVID‑19 recordkeeping and reporting requirements in 29 CFR 1910.502, including the obligations to establish and provide a COVID‑19 log and to report COVID‑19 fatalities and hospitalizations under 1910.502(r). See OSHA’s enforcement memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05.

Yes — for the OSHA injury and illness forms required by 29 CFR part 1904 (OSHA Forms 300, 300A, and 301), employers may use electronic or software‑generated equivalent forms so long as they meet the equivalency requirements in 29 CFR 1904.29 and can produce equivalent forms when needed, as explained in OSHA’s April 29, 2025 Letter of Interpretation. See 1904 and OSHA’s Letter of Interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29. The Healthcare ETS’s COVID‑19 log at 1910.502(q)(2)(ii) does not prescribe a specific file format, and employers may reasonably maintain records electronically so long as they meet the confidentiality, content, and access requirements in the ETS. Be aware, though, that OSHA issued a memorandum stating it will not enforce the ETS recordkeeping and reporting requirements at this time; see https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05.