Summary of Key Point:

People don’t follow words; they follow actions. A leader’s behavior creates the foundation of the team’s culture. If you expect accountability, trust, and excellence, you must embody those values yourself. By consistently demonstrating the behaviors you want to see, you establish trust and set clear expectations without relying solely on directives or policies.

Application in Your Life:

Leadership by example means embracing the habits and attitudes you wish to see in others. For example, if you want your team to prioritize safety, ensure you’re always following safety protocols yourself—even when it’s inconvenient. If you value open communication, regularly share your own thoughts and listen actively when others speak. Over time, your actions become a benchmark for the team, shaping their daily decisions and attitudes.

Reflection Points:

1. How closely do my actions align with the values I talk about?
2. Are there instances where I’ve sent mixed signals through my behavior?
3. What’s one small change I can make today to better model the values I expect from my team?

Teaching Approach:

• Explain the Concept: Use the “parent-child” analogy—children watch their parents’ actions more closely than they listen to their words. In the same way, team members internalize the behavior their leader demonstrates.
• Activity: Ask participants to identify a specific behavior or value they want their team to adopt, such as punctuality, attention to detail, or respectful communication. Then have them outline one practical way they will consistently model that behavior in their daily work.
• Follow-Up: Encourage participants to track their efforts for a week and note any changes in their team’s behavior, sharing observations in the next meeting. This can lead to a group discussion on what worked, what was challenging, and how modeling behaviors can create lasting cultural shifts.

Summary of Topic:
The Johari Window is a tool that helps individuals understand themselves better through feedback and self-disclosure. It’s divided into four quadrants:

1. Open Area (known to self and others) – What you’re aware of and others see too.
2. Hidden Area (known to self but not others) – What you choose not to share.
3. Blind Spot (not known to self but known to others) – What others see but you don’t realize.
4. Unknown Area (not known to self or others) – What hasn’t yet been discovered.

The goal is to expand the Open Area by giving and receiving feedback, fostering trust, and promoting personal growth.

Application in Your Life:
Identify a trusted colleague or mentor and ask for constructive feedback. Start by sharing something about yourself (reduce the Hidden Area) and ask for insights into how you’re perceived (reduce the Blind Spot). Over time, this transparency improves communication and strengthens relationships.

Reflection Points:

1. What’s one piece of feedback I’ve received that helped me see my blind spots?
2. How can I create a safe environment for open feedback with my team?
3. What steps can I take to increase the Open Area and improve my self-awareness?

Teaching Approach:

• Explain the Concept: Use a simple analogy—like cleaning a foggy mirror, honest feedback helps us see ourselves more clearly.
• Activity: Have participants pair up and share one strength they feel confident about and one area they’d like feedback on. Then, discuss how the Johari Window helps them expand their Open Area.
• Follow-Up: Encourage them to seek feedback regularly and track how it impacts self-awareness and performance over time.

From the Federal Register:

OSHA issued the healthcare ETS under section 6(c) of the Act (29 U.S.C. 655(c)) ( Occupational Exposure to COVID-19; Emergency Temporary Standard,86 FR 32376 (June 21, 2021), codified at 29 CFR 1910.502, 1910.504-.505, and 1910.509). Under section 6(c)(3) (29 U.S.C. 655(c)(3)), an ETS initiates rulemaking proceedings under section 6(b) and the ETS "as published shall also serve as a proposed rule for the proceeding."

When the COVID-19 pandemic started in 2020, OSHA initially responded to COVID-19 in the workplace by creating guidance documents and using its existing enforcement tools. The agency pursued a two-pronged strategy: (1) enforcing existing standards such as those for Personal Protective Equipment (PPE), Respiratory Protection, and Bloodborne Pathogens, as well as the General Duty Clause of the OSH Act (29 U.S.C. 654(a)(1)), and (2) working proactively to assist employers by developing guidance documents addressing how to reduce occupational COVID-19 hazards.

On January 21, 2021, President Biden issued Executive Order 13999 directing OSHA to consider whether "any emergency temporary emergency standards on COVID-19" were necessary (86 FR 7211). On June 21, 2021, the agency promulgated the COVID-19 ETS applicable to healthcare. Because, under the OSH Act, this ETS also served as a proposal for a final standard, OSHA received 481 unique public comments on the ETS during the first open comment period between June 2021 and August 2021 (Docket OSHA-2020-0004).

Following the issuance of the ETS, OSHA received petitions urging the agency to adopt a permanent standard to protect healthcare workers from COVID-19 from the American Nurses Association, the International Association of Fire Chiefs, the Service Employees International Union (SEIU), and National Nurses United (NNU) (Document ID 1518; 1519; 1521; 1522; 1524; 2175). Over forty unions and organizations supported the NNU petition urging OSHA to adopt a permanent standard for COVID-19 in healthcare establishments and issue a separate, broader Infectious Diseases standard.

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On December 27, 2021, OSHA announced on its website that it would be unable to finalize a COVID-19 standard for healthcare "in a timeframe approaching the one contemplated by the OSH Act" and since the end of December 2021, OSHA has not enforced the ETS beyond the recordkeeping and reporting requirements in 29 CFR 1910.502(q) and (r). Instead, OSHA has relied on existing standards and the General Duty Clause of the OSH Act (29 U.S.C. 654(a)) to protect workers in workplaces previously covered by the ETS. OSHA emphasized in the website announcement that the agency "continues to work expeditiously to issue a final standard that will protect healthcare workers from COVID-19 hazards and will do so as it also considers its broader infectious disease rulemaking."

On January 5, 2022, several labor organizations, including NNU, filed a petition with the United States Court of Appeals for the District of Columbia Circuit seeking a writ of mandamus compelling OSHA to issue a permanent COVID-19 standard for healthcare within 30 days and to continue enforcement of the ETS in the meantime. On August 26, 2022, the court issued a decision denying NNU's petition in part and dismissing it in part for lack of jurisdiction, while also noting that the ETS would continue to serve as a proposed rule for the rulemaking proceedings (In re National Nurses United,47 F.4th 746, 754 (D.C. Cir. 2022)). The court determined that while the OSH Act created an obligation for OSHA to follow the issuance of an ETS with a notice and comment rulemaking process, "that process may result in a determination that no permanent standard is necessary."

While the NNU case was ongoing, OSHA continued its efforts to finalize a permanent COVID-19 standard for healthcare. However, after the ETS comment period closed on August 20, 2021, the available COVID-19 scientific literature, approaches to controls, and CDC guidance evolved significantly, based in part on the emergence of the Delta and Omicron variants. OSHA determined that it needed to re-open the record to ensure that the agency relied on the best available evidence and that the public could provide and comment on new data and information. On March 23, 2022, OSHA published a Federal Register notice announcing a limited re-opening of the comment period for 30 days (until April 22, 2022) and public hearings beginning on April 27, 2022 (87 FR 16426, March 23, 2022).

The re-opening of the comment period and the hearing and post-hearing comment period allowed OSHA to revise and provide notice of potential changes to policy options and regulatory provisions to reflect up-to-date science, control approaches, and perspectives, as well as supporting analyses required for a final standard. At the closing of the comment period on April 22, 2022, OSHA had received approximately 250 additional comments.

The public hearings were held April 27-29 and May 2, 2022. Participating stakeholders included labor organizations, workers, employers, industry/trade groups, professional associations, public health experts, and concerned individuals, with some 39 organizations or individuals presenting their perspectives in the hearings (Document ID 2153; 2156; 2168; 2171). The presiding Administrative Law Judge permitted stakeholders to submit post-hearing comments and briefs until May 23, 2022. OSHA received nearly 150 additional comments from stakeholders during the post-hearing comment period. Over the three different comment periods, OSHA received 873 timely public comments on this rulemaking.

OSHA submitted a draft final COVID-19 rule to the White House Office of Management and Budget (OMB) on December 7, 2022. On April 10, 2023, President Biden signed House Joint Resolution 7 into law, which terminated the national emergency related to the COVID-19 pandemic. While the draft remained under review at OMB, OSHA developed an Infectious Diseases standard for healthcare workers.

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Basis for Terminating the Rulemaking

OSHA always intended for an infectious diseases standard for healthcare workers to supplant any COVID-19 standard, and a COVID-19 standard would be an interim measure pending the completion of the infectious diseases standard. OSHA concludes that the most effective and efficient use of agency resources to protect healthcare workers from occupational exposure to COVID-19 and other infectious diseases is to focus on completing an Infectious Diseases rulemaking for healthcare rather than a disease-specific standard.

In addition, even if OSHA were to finalize a separate COVID-19 standard at this time, the agency would need to conduct an additional review and possibly supplement the record before issuing a final rule to ensure the rule reflects the most current science. For example, guidance from the Centers for Disease Control and Prevention and other experts has changed since OSHA submitted its draft rule to OMB. Moreover, focusing on a separate COVID-19 standard would likely consume agency staff time and other agency resources in a way that would inhibit the promulgation of a more broadly protective Infectious Diseases healthcare standard. For these independently sufficient reasons, OSHA is terminating this rulemaking. The agency will have a more significant impact by adopting a standard protecting healthcare workers from occupational exposure to infectious diseases, including COVID-19 and future variants.

Final Thoughts...

According to critics, OSHA attempted to use its rulemaking authority to influence public health policy in the workplace. While many still argue the pros and cons of this approach, one thing is clear: emergency temporary standards may not always equate to the need for permanent standards, especially when the hazard itself is likely temporary. 

What do you think? Be sure to join in on the conversation by sharing your comments.

Blaine J. Hoffmann, MS OSHM has been in the occupational safety & health industry for over 28 years and author of Rethinking SAFETY Culture and Rethinking SAFETY Communications. Blaine is the producer and host of The SafetyPro Podcast and founded the SafetyPro Podcast community site.