2025 Look Ahead: Occupational Health and Safety 

Looking back on 2024, the Occupational Safety and Health Administration (OSHA) proposed federal rules for heat safety and emergency response workers, increased enforcement around Process Safety Management (PSM) programs, and updated recordkeeping and reporting requirements. As we look ahead to what 2025 will bring with the transition to a new administration, we can expect a move to scale back federal regulatory oversight on workplace safety issues, however OSHA will continue to play a vital role in ensuring workplace safety across industries. There will still be essential compliance requirements for OSHA-regulated facilities in 2025. Heading into 2025, OSHA is focusing on several key areas to enhance workplace safety that could result in the need to update your facility’s programs. 

OSHA’s 2025 Focus 

 1. Heat Injury and Illness Prevention

OSHA has extended the public comment period for its proposed rule aimed at protecting workers from extreme heat exposure in both indoor and outdoor settings until January 14, 2025. An informal public hearing on this proposed rule is scheduled to begin on June 16, 2025. This rule aims to reduce heat-related injuries and fatalities in the workplace (both indoor and outdoor), focusing on physically demanding industries such as construction, manufacturing, and agriculture, especially in areas prone to extreme heat.

Key Employer Requirements included in the proposal are: 

• Preventative Measures: Scheduled rest breaks, hydration, and access to shaded or cooling areas would be mandatory.

• Heat Hazard Identification: The employer must conduct regular heat risk assessments to monitor workplace temperatures.

• Emergency Planning: Employers would be required to develop a Heat Injury and Illness Prevention Plan (HIIPP) and Heat Emergency Response Plans.

• Training and Education: An annual training on heat safety would be required and employers must develop programs to help new and returning workers acclimate.

• Recordkeeping: Employers must retain records of heat-related incidents and conduct regular audits of the safety measures in place.

Exemptions would apply for workers in more “sedentary” positions or at workplaces kept under 80 degrees Fahrenheit. If finalized, employers will be required to develop a plan to evaluate and control heat hazards in their workplace. It would clarify employer obligations and the steps necessary to effectively protect employees from hazardous heat. The ultimate goal of this rulemaking is to prevent and reduce the number of occupational injuries, illnesses, and fatalities caused by exposure to hazardous heat.  

2. More Stringent Lead Regulations – New CalOSHA Lead Standards 

Workers in jobs like renovation, demolition, steel welding, and battery manufacturing are especially vulnerable to lead exposure. Prolonged exposure to lead can cause memory loss, fatigue, high blood pressure, and even kidney disease. Effective January 1, 2025, California OSHA (CalOSHA) will enforce more stringent lead exposure regulations to enhance worker safety. The Permissible Exposure Limit (PEL) has been drastically decreased from 50 micrograms per cubic meter (μg/m³) to 10 μg/m³ and the Action Level (AL) from 30 μg/m³ to 2 μg/m³. The rule is effective January 1, 2025, with no implementation period. The intent is to minimize the risk of lead poisoning and lower workers’ blood lead levels. 

To comply with the new regulations, employers must:  

• Perform Exposure Assessments and Monitoring: Employers who do not perform an employee exposure assessment and determine actual employee exposure must provide interim protection that consists of respiratory protection, protective work clothing and equipment, medical surveillance, training, and posted warning signs. Employee exposure levels would dictate the frequency of monitoring. 

• Develop a Medical Surveillance Program: If employees may be or are exposed at or above the AL, the employer must institute a medical surveillance program. All medical examinations and procedures required by the program will be provided at no cost to employees, and at a time and place that is reasonable and convenient for employees. 

• Medical Removal Protection: Employees who have exposure at or above the AL based on blood tests must be temporarily removed from work. Such employees will have “medical removal protection benefits,” and will not lose earnings, seniority, and other employment rights.  

• Other Requirements: Triggering the AL also requires employers to provide respirators and protective work clothing and equipment, institute hygiene and housekeeping practices, offer training, and maintain monitoring and medical records for at least 40 years. 

As California sets pace with these new regulations (Title 8, Section1532.1 and 5198), many are curious about how Federal OSHA will respond. While federal regulations typically follow a different process, California’s stringent standards may serve as a benchmark. Federal OSHA and other state programs could consider adopting similar measures, especially if the California model proves successful in reducing lead exposure and enhancing worker safety. However, any federal changes will involve a comprehensive review process, which can take time.  

3. Emergency Response Rulemaking 

OSHA is developing a proposed rule to ensure that workers involved in emergency response activities receive adequate protection from the hazards they are likely to encounter. The proposed rule would replace OSHA’s existing Fire Brigades standard, 29 CFR 1910.156. The standard, which was originally promulgated in 1980, covers only a subset of present-day emergency responders (firefighters) and has only had minor updates since it was first published. 

The new proposed standard will include protections in line with national consensus standards to cover a broader range of first responders exposed to hazards during and after emergencies. Key proposed updates include the following: 

• Changing protective clothing and equipment requirements. 

• Expanding and updating job hazards faced by today’s first responders. 

• Requiring employers to obtain baseline medical screening for all emergency responders. 

• Ensuring continued medical surveillance for responders when they are exposed to the byproducts of fires and explosions more than 15 times annually. 

Volunteers will also be further addressed in the rulemaking. Some states with OSHA-approved State Plans regard firefighters and other volunteers as employees under state law. Regardless of whether these volunteers are considered employees under federal law, such states must treat them as it does other emergency response workers interdependent of any final standard resulting from this rulemaking. 

The focus of the Emergency Response proposed rule is to provide basic workplace protections for workers who respond to emergencies as part of their regularly assigned duties. Notably, the scope of protected workers under the proposed rule would be expanded to include workers who provide technical search and rescue, and emergency medical service. This will include first responder employees who are trained and responsible for responding to any facility emergencies. 

4. Process Safety Management Enforcement 

The PSM standard (29 CFR 1910.119) aims to prevent or minimize catastrophic chemical releases that could endanger workers and the environment. PSM compliance targets facilities with highly hazardous chemicals and is critical for ensuring operational safety, especially in industries dealing with toxic, reactive, and flammable substances. Over the past year, OSHA has intensified its focus on updating and enforcing PSM regulations to align with evolving risks in the chemical industry, by publishing a Directorate of Enforcement (CPL-02-01-065) in January 2024. These updates are being driven by several key factors and will be a focus of enforcement in 2025: 

• Chemical Incidents: A series of significant industrial chemical incidents has prompted renewed attention on the safety of processes involving hazardous chemicals. OSHA has recognized the need for more oversight and more robust safety mechanisms. 

• Modernization of the PSM Standard: OSHA is currently reviewing the PSM standard to modernize it and address gaps related to evolving industry practices. This is part of OSHA’s long-term regulatory agenda, which includes several potential revisions:
  • Expanding coverage to include reactive chemicals not currently listed.
  • Clarifying the definition of “retail facilities,” which are currently exempt.
  • Revisiting requirements for facility siting and the use of more advanced technologies in hazard analysis and process monitoring.
  • Strengthening mechanical integrity requirements, particularly for aging equipment.
• Safer Technology and Alternatives Analysis (STAA): The Risk management Program (RMP) 2024 Rule updates require implementation of STAA at RMP Program Level 3 facilities with NAICS codes of 324 (petroleum and coal products manufacturing) and 325 (chemical manufacturing). Implementation of a requirement for facilities to conduct a STAA. This would compel facilities to evaluate and implement inherently safer design and technologies (ISD/IST) where feasible, helping to mitigate the risks of chemical incidents. 

• Worker Participation: OSHA is emphasizing greater worker involvement in PSM processes. This could include expanding the scope of employee training and participation in incident investigations and hazard reviews to ensure a more comprehensive approach to safety. These updates were codified in the 2024 RMP update rule. 

• Emergency Preparedness: Updated guidelines may also increase the importance of emergency planning and response, ensuring that facilities are well-prepared for potential incidents and can minimize impacts on both employees and nearby communities. Again, this was updated in the 2024 RMP update rule. 

With OSHA’s renewed focus on PSM modernization and increased enforcement, it is crucial for facilities handling highly hazardous chemicals to stay vigilant and adapt to upcoming regulatory changes. Regular updates to PSM programs, along with enhanced worker participation and hazard analysis, are key to maintaining safety and avoiding costly penalties. 

5. Combustible Dust 

Combustible dust is a significant safety concern for OSHA, as it poses a serious risk of explosions and fires in various industrial settings. OSHA’s role includes enforcing existing standards, developing new regulations, and promoting awareness to protect workers. 

Most guidance and standards pertaining to combustible dust are published by the NFPA, the International Fire Code, and adopted by State and Local Fire Codes. OSHA will typically focus enforcement on other standards such as electrical, housekeeping, or the General Duty Clause. OSHA previously launched and still maintains the Combustible Dust National Emphasis Program (NEP) to target facilities that handle materials prone to dust explosions.  

OSHA continues to prioritize the mitigation of combustible dust hazards through several key initiatives: 

• Revised National Emphasis Program (NEP): In January 2023, OSHA updated its NEP on combustible dust to enhance inspections of facilities that generate or handle combustible dusts prone to fire, flash fire, deflagration, or explosion hazards. This revision included adding industries such as Commercial Bakeries (NAICS 311812) and Printing Ink Manufacturing (NAICS 325910) to the program, reflecting a heightened focus on sectors with significant combustible dust risks.  

• Collaboration with NFPA on Standard Consolidation: OSHA is closely monitoring the NFPA’s efforts to consolidate multiple combustible dust standards into a single, unified code—NFPA 660. Scheduled for release in late 2025, NFPA 660 aims to streamline and clarify safety requirements across various industries, thereby enhancing compliance and safety measures related to combustible dust.  

• Educational Initiatives: OSHA continues to offer training programs to educate employers and workers about combustible dust hazards. For instance, the OSHA #7120 Introduction to Combustible Dust Hazards course is scheduled for June 2, 2025, providing comprehensive insights into identifying and mitigating combustible dust risks.  

Employers are required to protect their employees from the hazards of combustible dust and insurance companies will be requiring evaluations and assessments with the consolidation of the NFPA standards. Employers must also implement engineering controls, establish housekeeping practices, train employees, and develop emergency procedures to address the hazards and risks associated with combustible dust. 

What Should Employers Do to Get Ahead? 

Employers should stay informed about these developments and adjust their safety programs accordingly to ensure compliance and protect their workforce. Completing an applicability assessment and gap analysis of current practices to future (proposed) requirements is the recommended proactive approach to assessing impacts and maintaining a safe and healthy workplace. 

ALL4 will be actively reviewing OSHA enforcement, news releases, and final rules when published. We will be hosting webinars and publishing articles as new information develops. We also have extensive experience with OSHA compliance and are available to support your environmental, health and safety (EHS) compliance and management programs. Take a look at our website for upcoming and past articles detailing each of the items discussed above. For more information about how ALL4 can help support your EHS programs, contact Victoria Sparks at vsparks@all4inc.com or (859) 447-9156.