OSHA Updates: What Safety Pros Need to Know Now

OSHA updates don’t usually happen all at once, but that seems to be changing. In the latest episode of The Risk Matrix podcast, hosts James Junkin and Dr. Martin broke down a wave of recent proposed changes published in the Federal Register. The scope and volume of these updates caught many safety professionals off guard, including the hosts themselves.

“OSHA regulations do not change very often,” Junkin said. “Usually they take years of conversation, public comment, and outreach.” But this time, dozens of changes appeared with relatively little fanfare, prompting some to dig into the fine print. Here’s a breakdown of the key proposed OSHA updates and what they could mean for safety professionals across industries.

Chemical Standards, Respirators, and Recordkeeping

Many of the proposed OSHA updates focus on chemical exposure standards and respiratory protection. Chemicals like butadiene, benzene, formaldehyde, and cadmium are all on the list. According to Junkin, one notable shift is the proposed flexibility in respirator selection. “OSHA is proposing to give some flexibility in respirator selection… a lot of the regulations say you must use a full-face respirator,” Junkin noted. The proposed changes could open the door to using half-mask respirators in some cases.

At the same time, OSHA is considering removing the medical evaluation requirement from the Respiratory Protection Standard (1910.134). Currently, employees must be medically cleared to wear a respirator through a licensed healthcare provider. Dr. Martin explained, “They seem to mention that having those medical evaluations has not shown any indication that they prevent medical emergencies.”

If passed, this change would put even more pressure on companies to ensure workers are truly fit to wear respirators, whether a form gets filled out. “The burden will be on the respiratory protection program administrator,” Martin emphasized. “Just because you can put someone in a half-mask doesn’t mean you should.”

OSHA Updates to Illumination and Construction Safety

One update that stood out to both hosts involves illumination requirements on construction sites. As it stands, OSHA requires natural or artificial lighting in certain areas of a job site. The proposed change? Eliminate that requirement altogether.

Why? OSHA claims there is no significant reduction in risk by maintaining this requirement. But the hosts weren’t so sure. “That’s a really interesting one,” Junkin said. “I think the rationale is that during work, the lighting is already there. But there are civil liability issues when a site isn’t well-lit.”

Subtle Yet Significant: Recordkeeping Changes

Another proposed rollback involves OSHA 300 logs. OSHA had previously floated the idea of adding a column for musculoskeletal disorders (MSDs). Now, it looks like they’re backing away from that. “OSHA seems to be wanting to withdraw that proposal,” Martin said. This wouldn’t eliminate the need to record MSDs, just that they won’t require a separate tracking category.

Junkin added a real-world example: a company with zero injuries was still cited and fined $2,500 for failing to submit electronic OSHA 300 logs. “They didn’t understand the rules, and they still got cited,” he said.

Updates to the General Duty Clause Spark Debate

Perhaps the most controversial of the OSHA updates is a proposed change to the general duty clause. This clause has traditionally been used when no specific OSHA standard applies, but there’s still a recognized hazard.

The proposal suggests limiting its use in inherently risky industries like professional sports or entertainment. This stems from a court case involving SeaWorld, where an orca trainer was killed and OSHA cited the park under the general duty clause. Judge Brett Kavanaugh, in a dissenting opinion, argued that some risks in certain jobs can’t be avoided and are assumed.

Dr. Martin summed up the concern: “Just because OSHA can’t cite you doesn’t mean you’re not negligent under civil law.” Many in the entertainment industry rely on the general duty clause as a safeguard when specific standards are lacking. The change could remove a key layer of accountability.

Why These OSHA Updates Matter Now

These proposed changes didn’t come out of nowhere, but their timing is noteworthy. “I think a lot of this is directly related to the implications of what happened in the Chevron ruling,” Junkin said, referring to a recent Supreme Court decision that may limit federal agencies’ rulemaking powers.

That means OSHA might be moving quickly to formalize its authority before more limitations take hold. It also explains the volume of changes happening at once.

What Safety Professionals Should Do Next

If these updates caught you by surprise, you’re not alone. “It behooves us to stay current in our practice,” Martin urged. “Make sure you’re checking the Federal Register, the OSHA website, and even just Googling ‘OSHA news’ now and then.”

Most importantly, get involved. Each proposed update includes a public comment period. If you support or oppose these changes, or think something’s missing, this is your chance to say so. As Junkin put it, “Once it becomes part of the standard, it doesn’t matter what James or Dr. Martin thinks. It’s the law.”

Final Thought

Whether you’re managing construction crews, overseeing chemical exposure programs, or administering respiratory protection policies, these OSHA updates could affect your work. Don’t wait for the rule to hit your desk. Be proactive, stay informed, and make sure your voice is heard during the public comment period.

To see the full list of proposed updates, visit the Federal Register and search “OSHA.”