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OSHARulemakingOSHA-2020-0004

COVID-19 Emergency Temporary Standard Rulemaking

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American Health Care Association (AHCA/NCAL) filings
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American Health Care Association (AHCA/NCAL) filed 5 comments on this docket between Jul 9, 2021 and Nov 3, 2025. 198 other organizations filed here. The comment window closed 269d ago.

What American Health Care Association (AHCA/NCAL) filed (5)

Nov 3, 2025· Comment from American Health Care Association and National Center for Assisted Living (AHCA/NCAL)· OSHA-2020-0004-3059

Dear Acting Assistant Secretary Laihow, The American Health Care Association and National Center for Assisted Living (AHCA/NCAL) is the nation's largest association of long-term and post-acute care providers. Our members provide essential care to millions of individuals in more than 15,000 nursing homes, assisted living communities, and centers for individuals with intellectual and developmental disabilities. AHCA/NCAL aims to improve lives by delivering solutions for quality care. We appreciate the opportunity to comment on OSHA's proposed rule, which would remove the COVID-19 Emergency Temporary Standard (ETS) and its associated recordkeeping and reporting provisions from the Code of Federal Regulations. AHCA/NCAL is supportive of the removal of these reporting provisions to help streamline reporting requirements for both the federal government and healthcare providers. Specifically, AHCA/NCAL supports the removal of 29 CFR 1910 subpart U that are still in effect (specifically 29 CFR 1910.502(q)(2)(ii), (q)(3)(ii)-(iv), (r)), and the remaining portion of 29 CFR 1910 subpart U. During the pandemic, OSHA's Emergency Temporary Standard aimed to help protect healthcare workers from COVID-19 hazards. We have come a long way since then, and fortunately, the threat of COVID-19 has greatly diminished. Long term care providers are committed to preventing, monitoring, and treating COVID-19 and other respiratory virus illnesses among their residents and staff. However, we are no longer in the throes of a pandemic. The Public Health Emergency (PHE) for the COVID-19 pandemic ended in May 2023. Maintaining the ETS and its associated reporting more than two years later is no longer appropriate. Moreover, these COVID-19 reporting requirements are duplicative. Healthcare facilities will continue to record any work-related injuries or illnesses (i.e. COVID-19) if they meet the criteria for recordability as required in 29 CFR 1904.7. We encourage OSHA to finalize eliminating this duplication, in support of President Trump's Executive Order 14192, "Unleashing Prosperity Through Deregulation" (90 FR 9065, Feb. 6, 2025). Removing unnecessary and duplicative requirements also helps support patients over paperwork. In the proposed rule, OSHA notes an estimated annual cost savings of $215,746.96 from the removal of these provisions for nursing care facilities and assisted living facilities for the elderly. While creating government efficiencies is important, creating opportunities for enhancing care is essential. By relieving nursing homes and assisted living providers of this reporting requirement, staff can devote more time to delivering high-quality care. Thank you for considering these comments. Please feel free to reach out to Hawley Hunt at hhunt@ahca.org with any questions or for more information.

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May 11, 2022· Comment from American Health Care Association/National Center for Assisted Living (AHCA/NCAL)· OSHA-2020-0004-2162

Filed on regulations.gov — full text not in the inline record.

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Apr 22, 2022· Comment from American Health Care Association and National Center for Assisted Living· OSHA-2020-0004-2034

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Aug 20, 2021· Comment from Porter, Clifton; American Health Care Association and National Center for Assisted Living (AHCA/NCAL)· OSHA-2020-0004-1331

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Jul 9, 2021· Comment from Porter, Clif and Tittle, Scott; American Health Care Association and National Center for Assisted Living (AHCA/NCAL)· OSHA-2020-0004-1080

Filed on regulations.gov — full text not in the inline record.

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Abstract

Emergency Temporary Standard

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Co-filers (198)

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