OSHA Emergency Temporary Standard (ETS)

Is anyone else struggling with the new OSHA ETS protocols and the irony of the tighter regulations, just after the mass public is relaxing all of their own? We have already received so much push back from parents regarding our restrictions, (mask wearing, screening at the door, limiting family members, COVID tests, etc…). Just as we were reducing and scaling back our own processes, allowing us to get closer to a safe, but more “normal” work environment, OSHA issued their new standards. This drops us back into last year. We definitely want to be safe and in compliance, but is this jumping the shark?

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Yes, feel your pain, as I am sure most folks that see this post do as well. Dr. Berman sent an email to Practice Managers@listserve.aap.org on 6/22/21 sharing that SOAPMites and PPMAers were working on a model draft plan for pediatric offices that should address all components that the ETS requires. Fingers crossed the draft is shared before July 6 and provides you, and all of us, with more clarity on this *#@%.

Thank you for the feedback and the comradery!

This is a great topic and I’m glad you brought it into the forum. I would love to get additional information as it becomes available.

Thank you!

Thank you for starting this topic…I’m glad to hear we are not alone, but then frustrated to say that! I finally sent a blast email to our parents reminding them that per OSHA guidelines we, as a healthcare facility, have separate rules we must adhere to and to please help us stay in practice by following our simple rules.
I spoke with a nurse who worked for a large, corporate-owned facility and was told that patients complained to OSHA that they saw staff with their mask just below their nose and then the facility was fined $10k per day! We, as small private-owned practices cannot afford that but I don’t know if our parents really know they could be the reason OSHA gets called!
I look forward to hearing more about the plan that is being worked on!

For those of you who aren’t SOAPM members, here’s the text (and attachment (93.6 KB)) of the AAP’s effort related to the OSHA changes. You can participate in the webinar even if you aren’t a SOAPM member.

If you get a moment, thank @SKB for this!


The Occupational Health and Safety Administration (OSHA)’s new emergency temporary standards (ETS) for health care employers become effective next Tuesday, July 6. The compliance deadlines that go into effect next week include the need for a COVID-19 plan, patient screening and management, documentation of standard and transmission-based precautions, PPE (including a mini-respiratory protection program), aerosol-generating procedures, physical distancing, cleaning, vaccination, implementation of paid leave requirements, anti-retaliation, recordkeeping, and reporting. The need for physical barriers, ventilation, and training goes into effect July 21 .

If you see sick patients in your office with fever and cough, you are most probably not exempt. Small practices (below 10 employees) do not have to have a plan in writing, but they are not exempt from developing or executing a plan. Even practices where all staff are 100% vaccinated against COVID are only exempted from some of the rules.

Read the text of the new standard here: https://www.osha.gov/sites/default/files/covid-19-healthcare-ets-reg-text.pdf

Read the entire interim final rule in the Federal Register here: https://www.federalregister.gov/documents/2021/06/21/2021-12428/occupational-exposure-to-covid-19-emergency-temporary-standard


SOAPM will be hosting a webinar about the new OSHA emergency temporary standards on Wednesday, July 14, 2021 at 7 pm Central time. Topics will include what the temporary standards contain, whether they apply to you, Our faculty will be Sarah J. Butson JD and Shireen T. Hart JD of law firm Primmer Piper Eggleston & Cramer. A registration link will be sent to SOAPM and PPMA soon (save the date now). If you register but don’t attend, you’ll still get a link to the recording.

If this topic is important to you, I’ll hope you’ll register – registration count is a proxy metric for “how important is this to SOAPM members?”

Ms. Butson and Ms. Hart will be taking questions at the end of the webinar, but they would like to read questions submitted ahead of time so they can shape the presentation around what’s on people’s minds! To be sure that your question makes it to them, please send your ETS-related questions for the webinar to SOAPMEducation@gmail.com by Monday, July 12 at 5 pm Central time. Please send it to the SOAPMEducation@gmail.com email address; the attorneys are not subscribed to SOAPM and won’t see a message if you send it to SOAPM, Elisha, etc.


The AAP has submitted an official comment letter to OSHA about the ETS, which I have attached here (“Final-- AAP OSHA ETF Letter.pdf”) Thanks to the AAP Federal Affairs dynamic duo of Stephanie Glier and Nick Wallace and our amazing AAP President Lee Beers MD FAAP for their rapid action on our behalf.



If you have not yet commented on the ETS, please do so by going to Federal Register :: Occupational Exposure to COVID-19; Emergency Temporary Standard and clicking the “Submit a Formal Comment” button. The AAP’s letter has some great comments and talking points to reinforce.

As we reflect on our freedom this Independence Day weekend, remember that public discourse and debate about our law is a tremendous blessing we should not take for granted. The fact that we can comment on regulations without fear of reprisal is one of the best things about our democracy. Please exercise your privilege and provide feedback to the federal government.


You may download a Word draft that your practice may freely use and adapt at Color-Coded SOAPM OSHA COVID-19 Template.docx - Google Drive

A number of awesome SOAPMites and PPMAites contributed to this document: Sandy Herron, Katie Schafer, Jenn Armstrong, David Allen, Tanya Fitts, Marcy Hardart, Natsha Pereira , and Glenn Schlundt. Official legal review was provided by Sarah Butson and Shireen Hart of Primmer Piper Eggleston & Cramer.

I am also creating a series of hope-they’re-not-overly-annoying informal video walkthroughs of how a practice might complete the draft.

The first video (about 16 ½ minutes) is at Part 1 of "How to Use the SOAPM OSHA COVID-19 Template Plan to Get Your Pediatric Practice Compliant with the OSHA ETS" on Vimeo

If you find this stuff useful, then please:

  • Let the above SOAPMites know you appreciate their hard work! This document would NOT have happened without them. Writing something that folks pick apart takes skill AND bravery!
  • Consider a contribution to the AAP Friends of Children fund. A good legal review takes money. AAP has very graciously agreed to reimburse attorney review fees for this project (thank you, Mark Del Monte!) and, rather than being reimbursed back dollar-for-dollar, is inviting contributions to the Friends of Children Fund. To donate, visit https://services.aap.org/en/philanthropy/friends-of-children-fund/
  • Ask others to join SOAPM, PPMA, and/or the AAP. We know that these resources will find their way outside of SOAPM and the AAP. We ask that, if you share them with nonmembers, that you also include an invitation to join SOAPM/PPMA and the AAP. You know how it bugs the tar out of you when parents whose kids are NOT part of your practice still want to call you for telephone advice, or whatever, and you’re like “Well, if you could just join our practice, we could do that for you, safely”? If Elisha gets all kinds of email inquiries from non-AAP members about these documents, it’s kind of hard when folks can’t even cough up a measly $30… To join, go to https://services.aap.org/en/community/aap-sections/administration-and-practice-management/ and click one of “Join SOAPM,” “Pediatric Practice Management Alliance (PPMA)”, or “Join SOAPM and AAP,” as appropriate.
  • Attach this message when you share these resources.

The video set that runs through the sample OSHA plan is now available at

…which is a little easier to navigate than just trying to find each video numerically using the search feature, I think.

Folks may find it useful to read the draft plan and watch/listen to the videos more-or-less simultaneously. The videos address practical questions like:

  • How do I translate these CDC “wear-just-a-surgical-mask-in-this-situation vs. wear-respirator-eye-protection-gown-and-gloves in these other situations” into a clear chart for my staff to follow?
  • How can I document that erecting individual cubicles for each of my receptionists is infeasible based on my office space?
  • What do I do with unvaccinated staff for, well, everything?
  • What parts of the ETS am I exempt from if some or all of my staff are vaccinated?

It really is possible for folks to write COVID OSHA plans for their practices that are reasonable, thoughtful, and compliant with the guidelines. You can’t get it all done in 45 minutes, but you can do it. (And I’m coming from a small country practice perspective.)

I can’t find where to sign up for the webinar for tonight? Is there a link? Thanks.

I am having the same issue as @libby1. I can not find where to signup for the webinar tonight. Can anyone help please? @SKB @Chip and I did become a member:-). Thanks.

Here is the registration link again below.

Please note, if you cannot attend the webinar but would like to watch the recording, the best way to do that is to register for the webinar anyway using the below link.

You will AUTOMAGICALLY get a link to the recording if you register, even if you don’t attend .

Register Now!

SOAPM 2021 ‘Fireside’ Webinar:

The OSHA ETS : What’s A Pediatrician To Do?

DATE: Wednesday, July 14, 2021

TIME: 8:00 pm Eastern 7:00 pm Central 6:00 pm Mountain 5:00 pm Pacific


Click on this link to register: AAP SOAPM ‘Fireside’ Webinar – The OSHA ETS: What’s a Pediatrician To Do?

Event password: OSHA_ETS

Thank you Dr. Berman!


Thank you!

Will the recording of last nights webinar be made available?
Thanks again!

You can now find the recording, slides, and corresponding resources on the SOAPM Collaboration Site page at: Section on Administration & Practice Management (SOAPM) Newsletters Webinars (aap.org). See the 3rd column “Webinars”, and click on “OSHA COVID-19 ETS”.

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It is not letting me access the recording. Do you have to be a member of SOAPM?

Yes, we respectfully ask that at least one physician in your practice or one administrator should be a member of SOAPM ($30/year) or PPMA ($75/year) to support the cost of Elisha’s hard work and maintaining the archives!

Great, how do you sign up for SOAPM?

From above in the thread:

To join, go to https://services.aap.org/en/community/aap-sections/administration-and-practice-management/ and click one of “Join SOAPM,” “Pediatric Practice Management Alliance (PPMA)”, or “Join SOAPM and AAP,” as appropriate.


That is all.