2026 Look Ahead: Occupational Health and Safety

Setting the Landscape for 2026

Looking back at 2025, the Occupational Safety and Health Administration (OSHA) continued to move forward with its proposed rule for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings, published a series of over two dozen proposed deregulatory rulemakings, and updated its site-specific targeting (SST) program. The deregulatory rulemakings are aligned with Executive Order 14192, “Unleashing Prosperity Through Deregulation,” which directs agencies to streamline regulatory obligations by repealing outdated or redundant standards, with the intent of reducing compliance costs and fostering economic growth. While the deregulatory rulemakings may tempt some employers to take their foot off the gas and reduce their focus on Health and Safety (H&S) compliance programs, taking a closer look at OSHA’s actions may make them think again before they decide to pump the brakes. We encourage you to be mindful of OSHA-related enforcement topics that are likely to be a priority in 2026.

Heat Injury and Illness Prevention

According to the Bureau of Labor Statistics, from 2011 to 2022, 479 U.S. workers died from excessive heat in the workplace. It is estimated that there were 33,890 heat-related injuries resulting in days away from work. With heat leading to a substantial amount of injury and death in the workplace, OSHA published a Notice of Proposed Rulemaking (NPRM) for Heat Injury and Illness Prevention in Outdoor and Indoor Settings  on August 30, 2024. An informal public hearing on the proposed rule concluded on July 2, 2025. The post-hearing comment period for individuals who submitted a Notice of Intention to Appear (NOITA) ended on October 30, 2025. Post-hearing comments are available for viewing through the following link: Hearing Transcripts. A compilation of questions OSHA asked of witnesses during the hearing and a list of common questions are also available for reference.

With OSHA moving towards final rule development in 2026, now is the time for employers to take action to ensure that they are not caught off guard when the rule is promulgated. We expect the final rule will outline the requirements for Heat Illness and Injury Prevention Plans (HIIP), employee monitoring, emergency response, heat injury and illness controls, and training.

Even if a final rule is not issued, because of the General Duty Clause¹ and the recognition that employee injuries and illnesses resulting from working in areas with elevated temperature are possible, employers are strongly encouraged to evaluate their workplace to identify those areas where employees may be exposed to environmental risk factors (e.g., excessive heat, humidity, elevated heat indices, etc.). Based on the results of this evaluation, employers should amend their existing Illness and Injury Prevention Plan (IIPP) or prepare a separate HIIP that establishes tailored exposure prevention methods, monitoring schedules, engineering controls, training, emergency response procedures, and employee training. OSHA’s Heat NPRM Fact Sheet is a great reference tool for employers looking to figure out where to get started. Employers can also review existing state heat injury and illness prevention requirements, such as California OSHA’s (Cal/OSHA) Heat Illness Prevention in Indoor Places of Employment regulation.

Deregulatory Rulemaking

In July 2025, OSHA announced a series of Deregulatory Rulemaking actions to modernize and streamline existing regulations. They published a final rule that removed OSHA’s requirement to consult with the Advisory Committee on Construction Safety and Health (ACCSH) before issuing, modifying, or removing construction safety standards. On July 1, 2025, the new rule took immediate effect, streamlining the administrative process and reducing delays in construction rulemaking. OSHA also proposed 25 rulemakings targeting changes to numerous existing standards including:

• General Duty Clause: specifically suggesting that it should not be used to regulate hazards that are “inherent and inseparable” from certain high-risk or professional activities where risks cannot be eliminated without fundamentally changing the nature of the work.
• Respiratory Protection: removing the mandatory medical evaluation requirement for filtering facepieces and loose-fitting Powered Air-Purifying Respirators (PAPRs) concluding the physiological burden is minimal for most healthy workers. The medical evaluation will continue to be required for tightfitting respirators and for if symptoms arise.
• Substance Specific Respirator Requirements: various proposed rules revise substance-specific respirator requirements to allow different types of respirators to be used and better align with OSHA’s respiratory protection standard.
• COVID-19 Exposures in Healthcare: OSHA is proposing to remove its COVID-19 Emergency Temporary Standard and its associated recordkeeping and reporting provisions from the Code of Federal Regulations
• OSHA 300 Log Musculoskeletal Disorders: OSHA is proposing to withdraw its proposal to amend the OSHA 300 Log by adding a column that employers would use to record work-related musculoskeletal disorders.

Employers should continue to monitor OSHA’s deregulatory campaign in 2026 as we expect OSHA to continue down this path and issue final rulemakings throughout 2026-27. Stay tuned for additional articles as the deregulatory campaign continues.

Injury and Illness Recordkeeping

In April of 2025, OSHA released directive CPL 02-01-067, updating its site-specific targeting SST program. The directive shapes how OSHA selects workplaces for inspection, focusing on establishments with high Days Away, Restricted, or Transferred (DART) rates, DART rates that were trending upward in calendar year (CY)2023, failure to submit 300A data in CY2023, and unusually low DART rates, to verify data integrity. Since January 2024, certain high-hazard employers have been required to electronically submit OSHA Forms 300, 300A, and 301 via the Injury Tracking Application. We expect the recent trend and focus on utilizing injury and illness recordkeeping data to pinpoint high hazard industries and establishments will continue in 2026.

What Should Employers Do to Get Ahead? 

Employers should continue to monitor these developments, stay tuned for new rulemakings, and take action to stay ahead. Wondering where to start? Here is a list of actions you can take:

• Get ahead of a potential heath injury and illness prevention final rule by creating or updating your heat injury and illness prevention plan.
• Stay on top of deregulatory rulemakings. Determine how these changes affect your current regulatory obligations and where you can shift your focus.
• Review your injury and illness recordkeeping practices. Are your OSHA logs completed and submitted on time, and are your DART rates headed in the right direction?

ALL4 will continue to actively review OSHA’s news releases and rulemakings and will keep you informed of the latest developments through future articles and webinars. Navigating OSHA regulations can be overwhelming, but you don’t have to do it alone. Our team at ALL4 specializes in helping employers evaluate compliance, reduce risk, and build successful health and safety programs. For more information on the topics discussed in this article, you can review our website for past articles or contact John Kelleher at jkelleher@all4inc.com or (774) 249-3497.

¹General Duty Clause is found in Section 5(a)(1) of the Occupational Safety and Health Act of 1970. It states that: “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”