Important update on OSHA-mandated steps Ballad Health is taking to protect against COVID-19


The Occupational Safety and Health Administration (OSHA) announced a new rule on June 21 outlining steps that employers must take to protect workers from the risk of COVID-19.

The new Emergency Temporary Standards (ETS) applies to the healthcare industry, which has been hit hardest by the pandemic. For the first time in its history, OSHA is facing a new hazard that has taken the lives of nearly 600,000 people in the United States and infected millions more in just over a year. The purpose of the new rule is to keep healthcare workers safe from COVID-19, so they can continue providing critical care while slowing the spread of the disease.

To meet the federal mandate, Ballad Health is taking several steps that must be implemented by Tuesday, July 6. It’s important that you carefully review these guidelines and complete the necessary training to ensure compliance across the system.

Training requirements

Required team member training on the new OSHA guidelines will be in the form of a mandatory CBL that must be completed by all team members, contract employees and employed physicians by close of business on Wednesday, July 21. Failure to complete the CBL will result in suspension until the CBL is completed.

Response Plan

Ballad Health has revised our COVID-19 Response Plan to be compliant with these new OSHA standards. This plan can be found in the infection prevention folder in Policy Manager. All team members must know where this plan is and how to find it.

Click here to view Ballad Health’s updated COVID-19 Response Plan. 

Physical distancing and physical barriers

Physical distancing is still required. OSHA standards require that employers ensure their employees are separated from other people by at least 6 feet when indoors. In areas where physical distancing is not possible, physical barriers must be installed to provide protection to the employee. Our Facilities teams are already working with each facility to identify needed barriers, which will be installed as soon as possible.

Cafeterias must have tables spaced 6 feet apart, so we will be removing some tables in our cafeterias, resulting in limited seating capacity.

The ETS exempts fully vaccinated workers from physical distancing and barrier requirements when in well-defined non-clinical areas where there is no reasonable expectation that any person with suspected or confirmed COVID-19 will be present.

‘Badge buddies’ to indicate vaccination status

To comply with the OSHA standard, facilities must have a method to identify vaccinated vs. non-vaccinated employees, contractors and employed physicians.

Ballad Health will be requiring each such person to provide proof of vaccine. Those with proof of vaccine will be issued a blue “badge buddy” to hang behind their badge. Those who have chosen not to be vaccinated will be issued an orange badge buddy. This color-coded badge system has been added to the dress-code policy and failure to comply, or any attempt to falsify the badge, will result in disciplinary action, up to and including termination.

Meetings, meals and breaks

At any meeting where all attendees are fully vaccinated, physical distancing and masking is not required. If any attendee is not vaccinated, all attendees must remain 6 feet apart and masked.

At this time, Ballad Health will prohibit the serving of meals/food at meetings where it cannot be verified that all attendees are fully vaccinated. When eating in a break room or cafeteria, social distancing must be enforced if all in attendance are not fully vaccinated.

Team member screening

Team members, contract employees and employed physicians must continue to self-screen before each shift. By reporting to work, the team member attests that they are symptom-free that day.

Paper documentation of self-screening must occur until the team member has completed the mandatory training and attestation statement. Paper documentation of self-screening must be treated as a medical record and stored for 30 years (effective Tuesday, July 6).

Patient screening and management

Facilities should limit entry points to each facility and each entry point must have a screener. The screener will ask the appropriate screening questions (see previous CEOC guidance for screeners) and triage appropriately.

Other components of the ETS include:

  • Notification of exposure and quarantine – Team Member Health and Infection Prevention will immediately resume notification of exposure to any team member exposed to a patient with COVID-19 if the employee was not wearing a respirator. Exposed team members will be required to quarantine unless working in a clinical role in which quarantine is not possible because of staffing shortages. Quarantined team members may work from home when feasible.
  • Vaccination and PTO – Policies have been updated to ensure that employees may use PTO (paid time off) to receive the vaccine or to recover from any vaccine side effects.
  • Cleaning and disinfecting – Standard and transmission-based precautions, PPE, aerosol-generating procedures, cleaning and disinfection requirements are met with existing Ballad Health policies.

Your supervisor will be sharing a more detailed rundown of the OSHA requirements with you.

Thank you for helping us meet these mandated guidelines to ensure the safest possible workplace!