• TJC says that over 85 OSHA regulations are related to the Emergency Management, Environment of Care, Human Resources, Infection Prevention and Control, and Leadership standards chapters.
• Healthcare organizations may have well over 100 applicable OSHA standards found in 29 CFR 1903, 1904, 1910, and 1926.
• Hazards related to ergonomics, workplace violence, and infectious diseases may be cited under the General Duty Clause, section 5(a)(1) of the Occupational Safety and Health Act.

Healthcare work injuries and illnesses are not just a cost of doing business. The Occupational Safety and Health Administration (OSHA) sets and enforces regulations to help prevent workers from being killed or seriously harmed at work. You must provide your healthcare workers with a safe and healthful workplace free from recognized, serious hazards.

Because of the severity of some injuries/illnesses and the potential for a healthcare worker to suffer one, it’s critical to meet OSHA regulations and beyond. OSHA’s regulations have proven themselves, leading to a marked decline in worker injuries/illnesses in over 50 years.

Interestingly, The Joint Commission (TJC) says that over 85 OSHA regulations are related to the Emergency Management (EM), Environment of Care (EC), Human Resources (HR), Infection Prevention and Control (IC), and Leadership (LD) standards chapters. We know that TJC standards are performance-oriented, whereas OSHA is more prescriptive. That means to protect your workers, it’s important to meet applicable OSHA regulations. Complying with OSHA worker-safety and health regulations may have a positive effect on patient safety too.

Ninety-nine percent of healthcare establishments are private employers. If you’re a private employer, you’re covered by OSHA or its state-plan states. About half of the states have "state plans" that regulate state and local public employers OR both private employers and state and local public employers. These state-plan states have regulations that are identical to, equivalent to, or more stringent than federal OSHA. Federal government employers also fall under OSHA standards. Therefore, your healthcare organization likely has several OSHA standards to meet.

Which standards apply?

OSHA’s mission is “to assure America’s workers have safe and healthful working conditions.” While patient safety is not part of that mission, worker safety and health efforts can spill over into that space. For example, ensuring that workers have proper means of egress and fire protections relates to patient safety.

OSHA has about 1,600 pages of regulations covering general industry, the industry that includes healthcare. These regulations are complex, but healthcare employers must comply with all applicable requirements. You will need to review the following part numbers to determine which sections within them are applicable to your healthcare organization:

• 29 CFR 1903, Inspections, citations and proposed penalties;
• 29 CFR 1904, Recording and reporting occupational injuries and illnesses;
• 29 CFR 1910, Occupational safety and health standards for general industry; and
• 29 CFR 1926, Safety and health regulations for construction.

OSHA does not provide a list of healthcare-applicable standards, but the agency highlights the following ones for healthcare:

• 1910.34, Coverage and definitions for exit routes and emergency planning;
• 1910.35, Compliance with alternate exit-route codes;
• 1910.36, Design and construction requirements for exit routes;
• 1910.37, Maintenance, safeguards, and operational features for exit routes;
• 1910.38, Emergency action plans;
• 1910.39, Fire prevention plans;
• 1910.132, Personal protective equipment — General requirements;
• 1910.133, Eye and face protection;
• 1910.134, Respiratory protection;
• 1910.151, Medical services and first aid;
• 1910 Subpart S, Electrical;
• 1910.1030, Bloodborne pathogens;
• 1910.1047, Ethylene oxide;
• 1910.1048, Formaldehyde;
• 1910.1096, Ionizing radiation;
• 1910.1200, Hazard Communication; and
• 1910.1450, Occupational exposure to hazardous chemicals in laboratories.

Applicable regulations don’t stop there, however. Healthcare organizations may have well over 100 applicable OSHA standards. Again, you’ll need to review the Code of Federal Regulations (CFRs) to see which ones apply. In fiscal year 2024, OSHA cited healthcare and social assistance industry employers under nearly 60 different standards in Parts 1904, 1910, and 1926, along with section 5(a)(1) of the Occupational Safety and Health Act. The top 20 included:

1. 1910.1030, Bloodborne pathogens;
2. 1910.134, Respiratory protection;
3. 1910.1200, Hazard communication;
4. 1910.147, Control of hazardous energy (lockout/tagout);
5. 1910.303, General;
6. 1904.39, Severe injury reporting;
7. 1910.305, Wiring methods, components, and equipment for general use;
8. 1910.132, Personal protective equipment — General requirements;
9. 1910.151, Medical services and first aid;
10. 1910.157, Portable fire extinguishers;
11. 1910.37, Maintenance, safeguards, and operational features for exit routes;
12. 1904.41, Electronic submission of injury and illness records to OSHA;
13. 1910.22, Walking-working surfaces — General requirements;
14. 1904.29, Forms;
15. 1910.178, Powered industrial trucks;
16. 1910.1001, Asbestos;
17. 1910.36, Design and construction requirements for exit routes;
18. 5(a)(1), OSH Act General Duty Paragraph;
19. 1904.40, Providing records to government representatives; and
20. 1910.141, Sanitation.

Construction standards may apply too

When you experience construction or renovation activities, you will want to review 29 CFR 1926 to determine which ones are applicable for those operations. The term “construction work” means work for construction, alteration, and/or repair, including painting and decorating. It should be noted that Part 1926 applies to every place of employment where a worker engages in construction work.

That means you don’t need to be a construction company to fall under these regulations. Even healthcare employers can be caught under Part 1926 if their workers perform construction work. In addition, as a host employer, you may still be on the hook for protecting contract workers, if you are what OSHA calls an exposing, creating, controlling, or correcting employer, under the agency’s Multi-employer Citation Policy.

Healthcare employers were cited for the following construction standards in fiscal year 2024:

1. 1926.501, Duty to have fall protection;
2. 1926.1053, Ladders;
3. 1926.1101, Asbestos;
4. 1926.21, Safety training and education;
5. 1926.102, Eye and face protection;
6. 1926.405, Wiring methods, components, and equipment for general use;
7. 1926.453, Aerial lifts; and
8. 1926.503, Training requirements.

Worker safety and health beyond the OSHA regulations

OSHA’s reach can go beyond regulations. Hazards related to ergonomics, workplace violence, and infectious diseases may be cited. The citations point to section 5(a)(1) of the Occupational Safety and Health Act, which calls for worker protections from serious, recognized hazards. The bottom line is that all covered employers MUST, by law, provide workers with a safe and healthful workplace.

OSHA compliance officers follow the agency’s “Inspection Guidance for Inpatient Healthcare Settings,” which targets lifting-related musculoskeletal disorders, workplace violence, tuberculosis, bloodborne pathogens, and slip/trip/fall hazards. However, you can read it too in order to get clues on about OSHA looks for.