Quick Hits
- On September 14, 2026, Cal/OSHA released a discussion draft of a proposed rule that would require covered hospitals to screen individuals and their personal items at all unrestricted entrances, not just the specific entrances identified in AB 2975, with an exception for the ambulance entrance.
- Screening personnel would need at least eight hours of initial training covering an expanded curriculum, annual refresher training, and additional training when specified equipment, work practices, or hazards change. Trained personnel other than healthcare providers would need to operate and monitor screening devices whenever covered entrances are accessible to the public.
- AB 2975 requires the Occupational Safety and Health Standards Board to amend the standards by March 1, 2027, and requires a hospital compliance effective date no more than ninety days after adoption.
The draft would implement Assembly Bill (AB) No. 2975 and establish detailed requirements for hospital weapons screening, including screening at all unrestricted entrances, personnel training, and procedures for responding to detected weapons. Cal/OSHA is accepting comments through October 12, 2026.
The proposed amendments would add a weapons detection screening policy requirement to Title 8, Section 3342, California’s existing healthcare workplace violence prevention regulation. Proposed subsection (i) would apply to general acute care hospitals, acute psychiatric hospitals, and special hospitals.
Weapons Detection at All Unrestricted Entrances
AB 2975 identifies three screening locations: the hospital’s main public entrance, the emergency department entrance, and the labor and delivery entrance when separately accessible to the public. The discussion draft would go further, requiring a written policy providing for automatic screening of a person’s body and personal items at all unrestricted entrances, including those three locations.
The draft defines an “unrestricted entrance” as an entrance open to any individual without locks or access-control systems. It expressly excludes the ambulance entrance from proposed subsection (i).
For employers, this broader language could affect both equipment costs and staffing needs.
Screening Equipment and Limited Exceptions
The draft identifies several screening technologies, including walk-through metal detectors, x-ray and computed tomography screening systems, millimeter-wave screening systems, artificial intelligence-assisted weapons detection systems, and magnetic anomaly detection systems.
Consistent with AB 2975, handheld metal detector wands generally could supplement other weapons detection devices but could not serve as the sole screening equipment. The draft would preserve exceptions for qualifying small and rural hospitals; entrances with existing spacing limitations where other equipment would violate Title 24 standards; and hospitals exclusively providing extended hospital care to patients with complex medical and rehabilitative needs, including certain long-term care hospitals or inpatient rehabilitation facilities.
These exceptions concern the restriction on using handheld wands alone; they would not exempt qualifying hospitals from the screening policy requirements generally.
Personnel Assignments and Screening Coverage
Hospitals would need to assign appropriately trained personnel, other than health care providers, to implement the screening policy and monitor and operate devices at each covered entrance whenever it is accessible to the public.
Personnel Education and Training
The draft would retain AB 2975’s minimum of eight hours of training while specifying seventeen training topics. These include weapons and threat recognition, equipment operation and limitations, safe searches, de-escalation, implicit bias, disability awareness, emergency response, and applicable reporting and recordkeeping requirements. The curriculum would also address sharps and biological hazards encountered during searches and require practical exercises, hands-on equipment operation, and demonstration of competency.
Annual refresher training would be required, along with additional training when new equipment or work practices are introduced or a new or previously unrecognized weapons-screening hazard is identified. Employers would need to ensure that employees successfully completed the applicable training.
Employee and Health Care Provider Screening Exceptions
Hospitals could choose to exclude current hospital employees and hospital health care providers from screening when they enter wearing identification badges displaying their photograph, name, and title. The photograph requirement is an additional condition beyond the name and title language in AB 2975. The exclusion would be discretionary, not automatic.
Alternative Search and Screening Protocols
The written screening policy would need to address alternative searches and screening for patients, family members, or visitors who refuse device screening. Only personnel who completed the applicable training could search personal belongings at unrestricted entrances or confiscate weapons when hospital policy authorizes confiscation.
Response Protocols for Detected Weapons
Hospitals would need protocols addressing how they respond when a dangerous weapon is detected. An individual who triggers a screening device would have to be permitted to leave with the detected object and return without it. Entry could not be denied solely because the individual previously possessed that object.
Public Notification
The draft would require highly visible notices in conspicuous locations near unrestricted entrances where screening devices are used. The notices would advise that weapons screening occurs upon entry but that no person will be refused medical care pursuant to the federal Emergency Medical Treatment and Active Labor Act (EMTALA).
Next Steps
Cal/OSHA has requested comments on the discussion draft by October 12, 2026.
Although the draft does not establish a specific hospital compliance date, AB 2975 requires an effective date no more than ninety days after the amended standard is adopted. March 1, 2027, is the Occupational Safety and Health Standards Board’s adoption deadline, not a hospital compliance deadline or a guarantee of a full ninety-day implementation period.
Hospitals may wish to begin evaluating entrance configurations, equipment options, staffing models, and training programs while the proposal remains under development. They may also consider how a screening policy would integrate with existing workplace violence prevention plans and incident-response procedures. The discussion draft remains subject to change and does not replace employers’ current obligations under Section 3342.
Ogletree Deakins’ California offices and Workplace Violence Prevention Practice Group will continue to monitor developments and provide updates on the California, Healthcare, Workplace Safety and Health, and Workplace Violence Prevention blogs as additional information becomes available.
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