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Risk Advisory: OSHA COVID-19 Enforcement Response Plan

May 29, 2020

Visit and bookmark the Oswald COVID-19 Resource Center.

On May 19, OSHA issued an update to their Coronavirus Enforcement Response Plan. The updated plan generally returns to a pre-COVID-19 inspection policy while making COVID-19 related cases a priority. The updated plan provides guidance for OSHA compliance safety and health officers (CSHO’s) for handling COVID-19 related complaints, referrals, and illness reports.

In geographic areas where community spread of COVID-19 has significantly decreased, OSHA will return to the inspection planning policy that OSHA relied on prior to the start of the COVID-19 health crisis.

In geographic areas experiencing either sustained elevated community transmission or a resurgence in community transmission of COVID-19, OSHA Area Directors will exercise their discretion to prioritize COVID-19 fatalities and imminent danger exposures for inspection. Particular attention for on-site inspections will be given to high-risk workplaces, such as hospitals and other healthcare providers treating patients with COVID-19, as well as workplaces, with high numbers of complaints or known COVID-19 cases.

In an effort to manage resources effectively, OSHA may utilize non-formal phone/fax investigations or rapid response investigations in circumstances where OSHA has historically performed on-site inspections; and in all instances the Area Director (AD) will ensure that CSHOs utilize the appropriate precautions and personal protective equipment (PPE) when performing inspections related to COVID-19.

This new memorandum rescinds OSHA’s prior April 13, 2020 Interim Enforcement Memorandum and will be effective on May 26, 2020 and will remain in effect until further notice.


  1. OSHA Interim Enforcement Response Plan Coronavirus Disease 2019
  2. EHS Today: OSHA Intensifies Coronavirus Related Policies Following Criticism

View our most up-to-date risk advisory alerts here.

Should you have any questions or needs, please contact us direct or learn more from our Resource Center.

Adam Thomas
Senior Casualty Loss Control Consultant

Jim Hedrick
Director Risk Management & Client Experience


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