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Federal closure: As the longest federal shutdown drags on, OSHA continues to operate with paltry staffing levels. With a few exceptions, which include hazardous situation inspections, workplace fatality inspections, whistleblower complaint reviews, and follow-up inspections of high severity, serious violation, and no abatement facilities, all other non-essential operations have been halted and most OSHA employees have been furloughed. Employers are reminded that the closure does not suspend any OSHA-related obligations, including compliance with safety and health standards and/or disputing citations within 15 business days.
deregulation: The 10/21/25 memorandum from the Office of Management and Budget's Office of Information and Regulatory Affairs (OIRA) laid out a path to increase deregulation efforts across the federal government, including OSHA. These efforts will be accelerated once the shutdown is resolved.
Heat stress standard: Despite the deregulatory efforts noted above, OSHA's proposed heat stress standard continues to move forward. In late June and early July of this year, OSHA hosted virtual hearings that gave stakeholders the opportunity to comment on the August 2024 proposed notice entitled “Heat Injuries and Illness Prevention During Outdoor and Indoor Work.” OSHA subsequently extended the deadline for submitting comments following the hearing on the proposed standard, which recently closed on October 30, 2025.
State law, heat stress legislation: As expected, some states have made efforts to adopt their own versions of a heat stress standard. Both Virginia and Pennsylvania introduced bills this year to set heat standards, but they have not yet been signed into law.
Further enhancements for rule authoring comments. On August 20, 2025, OSHA also extended the comment period on 20 proposed rules from September 1, 2025 to November 1, 2025. These extensions addressed, among other things, medical evaluation requirements in the respiratory protection standard, occupational exposure to COVID-19 in healthcare settings, and OSHA's interpretation of the General Duty Clause: Restriction on Inherently Risky Occupational Activities.
OSHA leadership: On October 6, 2025, David Keeling was confirmed by the Senate to serve as Assistant Secretary of Labor for Occupational Safety and Health and Head of OSHA. Minister Keeling brings extensive experience in workplace safety, including leadership roles at UPS and Amazon.
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