Navigating OSHA’s Regulatory Landscape: Updates & Emphasis Programs

Hello everyone.

The Occupational Safety and Health Administration, also known as OSHA, continually updates their standards and regulatory requirements.

It’s imperative to remain informed, trained, and prepared to meet current OSHA requirements and maintain workplace safety.

On behalf of McGriff, I would like to take this opportunity to thank each of you for joining us today as we discussed navigating Osha’s regulatory landscape, updates and emphasis programs.

My name is Lesonya Wilder and I will be your host for the call today.

There are just a couple of housekeeping points that I would like to share with you before we get started.

This is a live session and you are in listen mode only.

If you have any questions at any time during the presentation, feel free to utilize the chat box or the Q&A box to type in your questions and we will address them during the Q&A segment.

If time doesn’t permit us to answer the questions after the presentation, we will be sure to capture them and provide the responses afterwards.

Now it brings me great pleasure to introduce to you our speaker for the hour, Nick Reynolds.

As a risk Control consultant for McGriff, Nick works closely with clients to evaluate risk exposure and develop strategies, processes and safety programs to reduce their total cost of risk.

Nick has more than 20 years’ experience in the safety industry and has worked as a risk control manager for two regional insurance agencies where he was responsible for establishing their risk control departments.

He has assistant clients with many safety initiatives including but not limited to lost trend development, the creation of customized accountability programs, OSHA and dot compliance, the development of return-to-work programs, and ergonomic evaluations.

Nick earned his bachelor’s degree in Environmental Health from the University of Georgia.

Nick has earned the Certified Safety Professionals CSP designation from the Board of Certified Safety Professionals.

He also earned the Truist Performance award in 2022.

So without further ado, I will turn it over to Nick to kick off the presentation.

All right, thank you, Lesonya.

Thanks for that warm, warm introduction and welcome everybody.

Thank you guys for attending.

I’m going to go ahead and just kind of turn my camera off so you guys can focus on the presentation.

So today’s session is titled Osha’s Regulatory Updates and New Resources.

We’ll walk through what OSHA has been doing.

We’ll walk through what’s changed, what’s coming, and we’ll also talk about the tools and resources that’s going to be available to help you stay ahead of of any changes.

Like Lesonya said, my name is Nick Reynolds and I am a McGriff Risk Control consultant.

And my job and our team’s job is to help clients like you guys and gals navigate the regulatory landscape and not just understand the rules, but help build practical strategies around those.

So without further ado, let’s let’s get into it.

So before we dive in, I want to make sure that we take a quick look at what we’re going to cover today.

First, we’re going to walk you through some of the latest OSHA standards updates.

What’s changed in the last 12 months?

Next, we’ll talk about Osha’s national Emphasis Programs, or NEPS for short.

We’ll cover federal Osha’s top 10 most cited violations, and we’ll touch on some updated penalty levels and reductions.

We’ll also look at what employers can realistically expect from OSHA over the next 12 months.

We’ll talk about enforcement trends, rulemaking activities, and where we think the agency is headed in the next 12 months.

And finally, we’ll wrap it up with some practical resources where to go stay current on OSHA activity, how to track regulatory changes and how McGriff can help you support you along the way.

First thing we’re going to talk about is some of the general OSHA standard updates that have taken place since our last one done almost 12 months ago.

And the first one on this is going to be Osha’s site-specific targeting inspection program, SST for short.

And this was on April 8th of 2025.

OSHA updated its Site Pacific targeting program, and this is their primary tool for scheduling planned inspections at companies with more than 20 employees.

OSHA also expanded its Severe Violator Enforcement Program, or SVEP.

This program concentrates Osha’s resources on employers who willfully or repeatedly violate safety laws, who simply refuse to fix what they’ve been told to fix before.

And under the expanded criteria, now all OSHA standards are going to be in scope rather than just a limited of them or the high hazard industries like before.

So this means any employer, any industry can end up on the SVPSVEP list.

So here’s how the SESST inspection program works.

So basically OSHA is going to collect all your Form 3O300A data.

So your, your, your OSHA logs, the 300A and they’re going to use it to build inspection list under this revised directive.

They’re looking at calendar years 2021 through 2023.

And when they’re doing this, there are four basic triggers that they’re going to use based on this data that they’re getting.

The first one is if your DART rate or your total recordable incident rate.

Dart rate is your days away from restricted or days away from work restricted to transfer.

If the DART rate or the TRTRIR is elevated in 2023 compared to your industry average, you can wind up on on that list #2 they’re looking at lost trends.

If your rates were at or above the 2022 industry averages and continued climbing every year from 2021 to 2023, you can wind up on the list as well.

And the surprising 1 is unusually low rates.

They’re looking at loss or I’m sorry.

If your rates are suspiciously low, they could reach out to you just to verify if you’re under reporting or not.

And then the last one, if you don’t submit your 300A data for 20/23 at all, then you’re automatically on the non-responder list.

So if you haven’t submitted your 300A data for the 2025 year, we advise you going ahead and doing it as soon as possible.

More on the site-specific targeting.

So basically this is pretty simple.

Your OSHA log should be treated as an enforcement trigger.

You need to make sure that they’re accurate.

You need to make sure that they’re submitted on time.

You got to make sure you understand what the story these numbers are telling you because the OSHA is also targeting companies that have open inspections and have also missed the 2026 March 2nd deadline for submitting your 2025 OSHA logs.

And with your accurate timing, with your accurate and timely record keeping, everything starts here.

And just as a reminder, if you haven’t submitted them, please go ahead and do so.

The deadline was March 2nd.

So if you haven’t done it, I would go ahead and do that.

The other one is they’re analyzing your lost trends.

So just don’t collect your, your lost data, right?

So these are some recommended actions.

You just don’t want to just put the information on there and, and turn around.

You need to look at it.

You need to look at your injury history over the past three years and ask yourself what type of accidents are you seeing?

Are they concentrating a specific department shift job task?

Are they going up, down, or are they holding steady?

Sorry, sorry, I was reading some on the chat box.

And if you can’t answer these questions, then it’s going to be hard to get a clear picture.

So lean on your McGriff, McGriff team.

We can help you connect the dots.

We can analyze your lost data and visualize it in a way that makes patterns immediately obvious, obvious.

We can develop OSHA benchmarking reports that compare your DART and your TIR rates directly against your peers in the industry.

We know what the common causes of losses look like in your industry.

And we can tell you what we’re seeing across our book of business in that same industry and then even tell you what the best performance or best performers in that category are doing differently.

And then we can help you shift from that tracking the tracking of the lagging indicators or basically, you know, number of claims to leading indicators like how many near misses were reported or how many safety observations were completed.

Want to make sure that you guys are getting ahead of them before they happen.

And then finally, safety inspections, inspect, inspect, inspect.

Regular safety inspections.

They’re one of the most effective ways to identify hazards before they actually do become injuries.

And these documented inspections, they demonstrate due diligence, they show a pattern of proactive hazard identification, and then they can be a very powerful defense if OSHA ever does come knocking at your door, and we did back in January.

So if you guys are looking For more information on OSHA record keeping and reporting requirements, just make sure you reach out to your rigorous representative because we can send you the recording of one that was done back in January of earlier this year.

Moving on, next one is going to be the Osha’s revised hazard Communication standard.

Now this one took effect in January or July 19th of 2024.

But the important thing here to remember and the reason why we’re talking about it now is the compliance timelines stretch all the way out to 2028 and updates to the hazard communications standard.

They’re basically making sure that your workers have a better, clear, more accurate information about the chemicals they work with every day.

And so these updates we’re talking about today’s discuss the rules for how chemicals get classified.

So on January 15th of 2026, OSHA extended the compliance deadlines across the board by four months.

And that four month extension applied to all other compliance dates as well.

Well, they basically just did this to give us more time and, and the community anytime to review necessary guidance materials before they they take effect.

So some key dates, May 19th of 2026.

This is where chemical manufacturers and importers and distributors, they’ve got to go in and examine every chemical they produce or import, determine based on a specific criteria what hazard classes and categories apply to it using the new updated criteria in the standard.

November 20th, 2026.

So it’s coming up, employers must update their hazard communication written program.

They got to update their labeling and they actually have to go in and provide new training based on the new hazard classifications that that have come out.

November 19th, 2027, chemical manufacturers and importer and importer and distributors, they’ve got update their mixtures using these new updated classifications.

And then finally May 19th, 2028, this is for the employers again to go back in and make sure they’re, if they’re using mixtures that they’ve updated their written programs, they’ve updated their labeling and then making sure that they’re providing adequately good, good training.

And just some recommended actions just that you guys can start doing now.

First, audit your safety data sheet inventory.

Do you know exactly what chemicals you have on site?

Do all the chemicals that you have have a current safety data sheet?

Are those safety data sheets accessible All right?

Second, make sure you’re reaching out to your chemical suppliers now to ask them where they are in the process of updating their labels, their SDA S s in compliance with the global harmonization this revision 7 standards.

When updated SDS has arrived, make sure you have a process in place to review them.

Make sure you’re updating your inventory and flag any changes that may require any additional training.

Third, pull out your written hazard communication program and review it.

When was the last time it was updated?

Does it reflect the current chemical inventory?

Does it reference the correct vision or version of the standard?

This is a living breathing document, right?

So it needs to stay updated anytime that they change and make changes to the regulatory stuff.

And finally, I I wouldn’t wait until October to start thinking about training time can get away from us and the employer deadline for updating these things is in November.

And then that sounds like a a pretty far off.

But if you have multiple locations, if you got a large workforce, if you have high employee turnover building and rolling out this program, it can can take some time.

Next is going to be walking working surfaces.

And OSHA issued a notice of proposed rulemaking to eliminate the compliance deadline that has been on the books since 2016.

And this one’s actually going to be one of these positive changes that OSHA has made.

So just a little background.

Back in November of 2016, Osha’s walking working surfaces standard included provision that required employers to go in and retrofit all fixed ladders that were over 20 feet tall, 24 feet tall with either a personal fall arrest system or a ladder safety system.

The deadline to do that was in November 18th of 2036.

Well, for many employers, I mean, if they had a dozen ladders across their entire footprint, this was a pretty significant expense because you’re talking about replacing all of these things.

So what OSHA is now proposing is to eliminate that retrofit deadline entirely.

The reason why they’re doing this is these fixed ladders are they’re, they’re very durable and can last anywhere from 50 to 70 years depending on the environment they’re in.

And it it’s forcing employers, or was forcing employers to retrofit ladders that were still sound and fully functional by deadline, that didn’t make practical sense.

So now OSHA is just proposing that employers upgrade their ladders at the natural end of their service lives, and which was in there already being replaced anyways.

Now, to be clear, this does not change the effect of new fixed ladders.

If you install a new fixed ladder, you have to have personal fall arrest system or you have to have this ladder safety system.

This change, like I said, only affects the retrofit deadline.

So this is still a proposed rule.

It’s not a final rule until OSHA finalizes it, the original 2036 deadline technically remains on the books, so make sure you pay attention to that.

Stay tuned with it.

I wouldn’t make any major decisions based on the proposal just yet.

Employers with exposure, just make sure you keep a close eye on it as it moves through the rule making process.

Now let’s kind of shift from federal to state-run plans.

It’s important to remember that these state-run plans, they are very, very active.

And in some cases, they’re moving faster than the federal agency.

And right now, we have 2 notable developments to kind of talk about, one out of California and one out of New York.

The one out of Cal OSHA, it’s the third party walk around rule.

And so on February 13th, 2026, Cal OSHA proposed a new walk around rule that’s going to allow third parties, including union organizations, attorneys, anybody else to participate in these Cal OSHA workplace inspection.

Now, it does mirror the federal one that’s currently in place and has been in place since 2024 as far as this is concerned right now, they did a public hearing that was done on April 1st of 2026.

And right now they’re in the process of going through and and reviewing all the comments and they’re going to use the feedback to decide do they want to finalize it, Do they need to revise it, or are they just going to review or withdraw the rule entirely?

New York, NY is implemented.

On January 3rd of 2026, the New York City Council enacted legislation amending site safety training requirements for construction workers and supervisors specifically on department of building permitted sites.

And this abatement or amendment rather mandates new training specifically covering 3 very important topics, really mental health awareness of alcohol and substance abuse and suicide risk and prevention.

The law took effect somewhere around May of 2026, so if you have any construction operations on DOB permitted sites in New York City, then this is already in place and already taking effect.

Some more on some state plan updates.

I want to make sure I’m addressing some things that are moving across some of the other states.

We have two of them that important state level trends I want to make sure I cover.

It’s heat stress and workplace violence, 2 very big ones that are getting a lot of federal push as well.

When it comes to heat stress regulation.

Several states haven’t waited for federal OSHA to to come up and act.

So while the federal heat stress rulemaking has been slow moving states like California, Colorado, Minnesota, Oregon, Washington, MD, Nevada, they are having, they already have mandatory heat illness prevention rules on the books and and more states are following.

So it’s not just going to be those.

So if you have any operations in any of these States and you’re already subject to enforceable heat stretch requirements regardless of what happens at the federal level.

So you’re going to have to comply anyways if you’ve fallen in one of those states.

These rules are also covering it’s, it’s not just outdoor environments.

You also have to, they’re also taking into account indoor work environments.

So if you have workers in warehouses, kitchens, laundries, foundries, bakeries, or any other facility without adequate climate control, you may be in the scope even if your employer never steps, even if your employees never step foot outside.

So make sure you’re understanding which states you operate in, know whether they have a heat rule and if it applies.

And make sure your program meets the specific requirements of each jurisdiction.

Because a one-size-fits-all approach isn’t going to work because there’s 7 total.

States have a variation of these things.

Some address just indoor, some just addressed outdoor, some do both.

Some much supply to certain industries.

So make sure you’re understanding what specific state that you are operating in.

Workplace violence.

Federal OSHA continues to rely on the primarily on the General Duty Clause to cite employers for workplace violence hazards.

However, states are kind of stepping in to fill those gaps with very specific and very enforceable requirements.

Now they are kind of focused on the healthcare and social service sectors.

But as we’re going to talk about a little bit later in here, they’re they’re branching out from those and many states are adopting or expanding these workplace violation, workplace violence prevention requirements for healthcare and social services.

But the common elements that all of them have, are you doing hazardous assessments?

Do you have a written workplace violence prevention plan?

How are you doing employee training?

And then do you have a workplace violence prevention committee?

So now while healthcare and social services, like we said, have been the primary focus, the trend is expanding.

So anything in retail, education, public facing service industries, they’re increasingly being pulled in the scope as the states broaden their workplace violence prevention requirements.

OK.

This one I get a lot of questions on all the time, especially being down here in the South and working with other clients across the country.

This is one that’s been very closely watched and one that everybody’s kind of anticipating.

And they’ve been working towards this formal rule for several years, but right now we do not have a final rule yet.

They did hold an informal public hearing middle of last year, probably about 12 months ago.

They followed that up with a post hearing comment period that closed in October, and since then OSHA has completed both the advanced notice to propose rulemaking and even the Small Business Regulatory and Fate Enforcement Fairness Act process.

This rulemaking, it is still moving forward, but we do not have a notice yet of proposed rulemaking or even a final rule if and when it’s finalized.

The standard would apply to pretty much all employers conducting outdoor and indoor work across general industry, construction, maritime, agriculture, basically wherever OSHA has jurisdiction.

During the comment process, the a lot of the feedback was from some of the employers and they actually urged OSHA to kind of keep the standards simple, focusing on just some of the core requirements, which, you know, water, rest, shade and training.

And this can the concern is, is that an overly complex standard is just going to create more compliance burdens that are difficult to manage across more diverse workforces.

So while this rulemaking continues, heat and injury, illness and illness remains an active national emphasis program, which we’re going to talk about, but later, which means basically ocean inspectors, they’re already going out and targeting heat, heat hazards Right now they’re using the general duty clause as their enforcement tool and we’ll get more in the specifics of that a little bit later in the presentation.

So while we anticipate a federal heat standard, it is coming.

What it, what it’ll look like and, and what it’ll entail is, is pretty much uncertain at this point.

So one thing to keep in mind and one thing that I would encourage everybody to do is just to go ahead and start building a good strong heat illness prevention program now.

So you’re ahead of the curve.

As we move on to national emphasis programs, I think it is important to make sure we all understand exactly what is a national emphasis programs.

Basically an NEP is a temporary target enforcement initiative that OSHA uses to direct the inspection resources towards specific high hazard industries or workplace hazards of some sort of national significance.

Like we all remember silica, combustible dust, things of that nature and and these NE PS it’s pretty much what drives the Osha’s program inspections, which means inspectors.

They can show up at your door without a complaint, without a referral, or without an incident triggering the visit.

The most immediate and direct impact of an NEP is this.

If your business falls within a targeted NAICS code or a specific industry sector, you are on Osha’s radar for a program inspection.

And OSHA can and does select establishments for inspection based solely on their industry classification.

So if you’re in one of these covered industries, you need to operate as if an inspector can walk through your door at any time.

And some things to keep in mind too.

So if they go out there and any violations they find during these NEP inspections, they’re cited under OSHA standards.

And if they show up specifically for an NEP related inspection and they observe other hazards that are unrelated to the NEP, they can and will expand the scope of that inspection beyond financial penalties of those.

There’s also the reputational dimension part of this that is becoming more and more relevant.

Citations become part of public record.

Anybody can go on osha.gov and find out who had it, an inspection and the results of that inspection.

So for businesses with with clients contracts or insurance considerations, A citation history can affect those relationships, can affect your ability to get a contract or find good, good premiums for your insurance.

And then one final point for those of you who are operating in states with OSHA approved state plans, those 26 state plans, they are required to adopt the same NE PS or have some some comparable programs in place.

So in some cases state planned versions of these NE PS they’re actually more stringent than the than the federal version.

But moving on to our first NEP, this is going to be probably arguably the most impactful for the broadest range of employers right now and that’s going to be the Osha’s heat injury and illness prevention in EP.

Now this was originally issued back in April of 2022 and since then it’s been revised and expanded.

And the revised program uses OSHA and Bureau of Labor Statistic data from calendar years 2022 through 2025 to figure out and to help them direct inspection priorities to the 50 plus high risk industries with covering both indoor and outdoor settings.

So this is not just construction or agricultural, this is warehouse, this is manufacturing, this is bakeries.

Anything that can have an indoor environment where it can generate heat like that is going to be in the scope.

Heat related inspections, this is something that is was caught my attention.

Heat related inspections have increased from about 200 per year to now to about 2400 per year.

So this means that they’re not treating this as some little niche enforcement policy.

They are this is they’re actively inspecting these programs and OSHA just recently expanded it to April 10th, 2020, thirty a 2031.

So this isn’t going away anytime soon.

And everybody needs to start treating these heat illness prevention as a permanent fixture of their safety programs, not just something that you know, it’s a seasonal concern.

One thing to keep in mind about how NEP works in practice is it’s specifically this one.

Compliance officers, they’re going to conduct random inspections focused on heat hazards and high risk industries on days that the National Weather Service has issued a heat advisory or warning.

So this means on those hottest days of the year when your workers are most at risk, ocean inspectors are also out conducting inspections.

So if heat is not already high on your priority or in your safety program, it really should be.

And next is we’re going to be talking about how to get basically what OSHA is looking for next.

And they, they do this by looking at 11 specific questions that they have.

And so when they arrive at your facility, they’re working from a structured checklist that actually has all these 11 questions that they’re asking.

The first thing that they’re asking, they want to know whether you have a heat and heat illness prevention program and not only whether it exists, but also do the employees know about it.

Notice how OSHA says written or verbal.

So they’re not really saying that you have to have one documented.

However, you know us in the safety profession, we would always recommend you go ahead and document it because it’s going to be your strongest defense.

The next one, this one gets it whether you have a system in place to actually know when conditions are dangerous.

So how are you monitoring this, right?

Monitoring is just not looking at the heat app on your phone.

It is also looking at exertion levels.

So OSHA wants to see that you’re tracking heat index or temperatures at the work site and that you’re also factoring in exertion level.

So how much activity, physical activity are they doing?

Is it light, is it moderate, or is it heavy?

Next one is water.

Osha’s guidance for cool water.

This is pretty simple, just making sure that they’re easily accessible.

All right, they do have some recommendations, and you can find some recommendations on how much water to drink.

NIOSH, CDC, they all have some good resources on that.

But usually the general rule of thumb is 1 quart of water per employee per hour.

And that’s what OSHA is going to want to start seeing beyond or OR next.

We have scheduled rest breaks.

They want to know whether workers are allowed to take additional breaks for hydration when they need them.

I make sure that your supervisors understand that hydration breaks are not optional extras.

They’re the core component of your heat safety program.

And separate from hydration breaks, OSHA is also looking for structured scheduled breaks that give workers an opportunity to recover from heat exposures.

The frequency and duration of those breaks, they need to be tied to heat conditions and the physical demands of the work.

So basically, on a mild day, your normal break schedule may be sufficient, but on days with a high heat advisory, it may require frequent change or frequency changes in your breaks in your program.

It needs to define what those what those changes look like.

Next is access to shade and OSHA expects that shaded areas are available that and that workers can use them during breaks, especially when they feel overheated.

And then for indoor workers, the equipment is just going to be providing a cool down area.

Maybe that’s an air conditioned building or a room, or maybe it’s an area that has adequate ventilation where they can kind of go in there and recover.

More on what they’ll ask.

So another one is your acclimation, right?

And this is a very critical element of the heat and injury prevention program.

New workers and workers returning from time off.

They haven’t built up the tolerance needed to work safely in high conditions.

So they’re going to want to know if you have a structured acclimation plan.

Training is going to be another big part of this.

Training is where a lot of employers, they might have gaps, not because you haven’t done the training, but maybe it doesn’t cover what the the elements of OSHA is looking for.

So it’s not enough just to tell workers to drink water and take breaks.

OSHA compliance officers, they can verify with employees that they understand these principles.

So having more frequent regular toolbox talks, having a refresher training at the start of the hot season and getting supervisors on board for reinforcement, that’s very important.

And then finally, it’s accountability.

Ocean wants to know that somebody owns the program.

I’m sure some of you, some of you on the call have heard if everyone is responsible, then no one is responsible.

So they’re going to want to see that you have a named individual or individuals at multiple locations or a larger location.

They want to see who is responsible for monitoring conditions, making decisions about work modifications, ensuring water and shade are available, and responding when a worker shows symptoms.

That person needs to be known to employees, they need to be trained for the role, and they need to be empowered to act.

Now let’s move on to specific recommended actions for developing a heat safety plan.

And this is taken straight from from OSHA.

So one have a plan, you need to develop a plan that includes monitoring, acclimitization work, rest schedules, a buddy system has protocols for emergencies and first aid.

And then you have to communicate that plan to supervisors and employees.

Next you have to have a you have to designate someone to oversee the heat safety program.

So identify someone trained or to be trained in heat hazards, heat illness symptoms and heat controls.

If possible try and select somebody or train multiple multiple people to make sure that you always have a designated heat safety representative on site.

The third one provide training on heat illnesses.

Ocean wants to see that this training covers some pretty specific things.

One, train them on how to recognize the signs and symptoms of heat exhaustion and heat stroke and other heat related illnesses.

Train them on how and to whom workers should report symptoms including their own right.

You also need to make sure that you’re training on basic first aid response.

Train them on how to contact emergency personnel.

The importance of hydration.

Hydration on this one is important to do before the work begins, during the work, and then even after the work.

So it’s making sure that you train the employees that if you know that you’re going to be working pretty heavily the next day, you need to start hydrating the night before sometimes.

And supervisors need this training too, right?

Because they’re the ones out there responsible for watching for signs and symptoms and, and enforcing these policies.

Next one is acclimatization.

Like we said, this is for new and returning employees.

You want to gradually increase their workload an exposure by following what we call the 20% rule.

So this, so you basically begin on the first day, you’re just going to put them at 20% exposure and then increasing by no more than 20% each following day.

Sometimes depending on where you are on the full actualization, it could take up to 14 days or longer.

Next one is modify your work schedules or your work practices so to help reduce heat exposure.

This could mean maybe you’re shifting heavy outdoor work to earlier in the morning when the heat index isn’t so high or or so hot.

You may be rotating workers throughout high heat tasks so no sequel employee is just continually exposed to it or adjusting workloads on those extreme hot days.

You can use that heat safety index app that Osha’s got and you can actually see what the next day is going to be.

So you can kind of plan out your tasks.

Number six, allow for rest breaks.

They need to be long enough to allow workers enough time to recover from heat, from heat the given the temperature, humidity, given their action level and other conditions.

The tricky part is, is there’s there’s no magic number OSHA is going to cite you for.

They’re not going to say oh, you gave them an 8 minute break when instead you should have given them a 10 minute break.

But what they are looking for is just basically evidence that your break schedule is responsive to the changing conditions.

So maybe on a mild day, your normal break schedule may be fine.

On a day with a high heat advisory, that’s going to need to change.

Maybe you need to add in more frequent breaks, allow for a longer recovery time and and breaks taken in a cool and shade of location.

So that needs to be built into the decision making process into your program.

Make sure you’re documenting it and make sure your supervisors know how to apply it.

Now there is a NIOSH, which is the National Institute for Occupational Safety and Health.

They actually have a guide on work rest schedules that we can give you guys the access to this if you guys want.

So just just let us know #7 Identify the heat hazards.

Hazard identification is recognizing heat hazards and the risk of illnesses due to those high temperature, high humidity, exposure to full sun, and other thermal exposures.

The work demands.

What clothing and PPE are they wearing and other personal risk factors that they may have.

8 Check the temperature.

You want to make sure that you’re checking the temperature in the space before work.

For outdoor work, you can use that I OSHA NIOSH heat safety tool app that I was referencing.

For indoor work, use a combination thermometer or hydrometer.

It’s it’s one that measures humidity levels or you can use what OSHA uses and that’s a wet bulb globe temperature to make sure you’re identifying the heat index inside of that work area #9 Monitor for heat symptoms.

You have to establish a monitoring system for the signs and symptoms of heat illnesses.

Also, you need to make sure that you’re training workers to monitor each other #10 designate the break area and make sure you are encouraging hydration.

Conversations about hydration need to include hydrate before work, during work and after work and then have workers dressed for heat.

They should wear hat outside, loose fitting clothing, breathable whenever possible.

And then the last one, have a plan for when things do get spicy.

Have an emergency plan in place for each work site and make sure you’re communicating it to the supervisors and the workers.

If you need any help with these, please don’t hesitate to reach out to your Griff representative.

We, we can help you determine your exposure areas, we can let you know where your gaps are in the program and we can provide you with some sample written programs.

It even provides you with some training resources such as handouts or access to one of our online training platforms.

The next NEP we’re going to cover this is one of the ones that is it’s most severe and life altering injuries can happen in manufacturing environment, which is amputations.

So OSHA is going to be really focused on this one.

This NEP had an original effective date going back to June 27th of 2025, but it has been extended for another five years.

So this is going to be going driving ocean inspections and manufacturing until June of 20-30.

The goal is pretty simple, identify and reduce or eliminate amputation hazards in industrial and manufacturing workplaces.

If your facility has machinery or equipment such as presses, conveyors, slicers, grinders, mixers, packaging equipment, you’re going to fall on the scope of this some recommended actions.

We want to make sure we cover these two.

The first one is conduct a regular machinery audit.

You need a systematic process in place for inspecting every piece of machinery and equipment on a regular schedule to confirm that the guards are still in place, intact, and that their functioning is designed.

The next one, I mean ensure all guards are in place and functional.

It seems very simple and very obvious, but believe it or not this is one of the most frequently cited violation OSHA fines under this NEP cause guards get removed from maintenance and they never get put back or they get damaged and then they aren’t replaced or workers will find a way around them because they slow down production.

Whatever the reason is, a missing or non functional guard is an immediate citation and a serious injury.

Waiting to have blackout tag out is another major pillar of this one.

OSHA requires written equipment specific lockout, lockout tag out procedures for every piece of machinery that requires servicing.

Some things to consider on this one.

When did you last review your lockout tag out policy?

Have you added new equipment since they were written and have any of the processes changed?

Next one is training.

This one is required.

OSHA looks at all three levels of training.

They’re going to look at your new hire training to make sure that employees are getting trained on the importance of these before they’re exposed to it.

They’re looking at refresher training to make sure that you’re continually reinforcing the safe habits of working with machine guards.

And then remedial training.

It’s required when you have a worker that maybe keeps on bypassing them or they’re not following procedures or they’re involved in an incident.

And then the last point is don’t forget about your supervisors.

This one is, is the difference between a program that works and one that just looks good on paper is making sure that you’re training your supervisors.

They’re your first line of defense.

They’re on the floor every day.

They see where the guards are missing, when they’re missing, when workers are bypassing them, when lockout tag outs not being followed.

So make sure that you are training them on this, training them on the machine guarding and lockout tag outs.

The supervisors need to understand that correcting unsafe conditions and behaviors is part of their job.

It’s, it shouldn’t be a disruption to production.

It’s pretty important.

Some additional ones are we got 3 here, combustible dust, fall prevention, protection and warehousing and distribution center operations.

The combustible dust, the reason why this one’s on here today is it was implemented back in 2007, but it is still open until further notice.

There’s there’s they’re still having a lot of these combustible dust instances, which is why it’s staying open.

Fall prevention and protection, you know, they remain the leading cause of fatalities and construction and even more serious injuries in cross general industry.

And so Osha’s fall prevention and this protection NDP, it’s been active since 2023.

And again, there’s no expiration dates and this one covers construction and general industry workplaces.

And then you have warehousing and distribution.

Osha’s warehousing and distribution targets full range of hazards found in these forklifts, powered industrial trucks, material storaging, walking, working services and ergonomics.

And this is set to expire on July 13th of 2026.

At the time of this, no issue was updated.

All right, want to make sure we go over some of the top 10 most standards or most cited standards and this was just released like last week.

So this is all pretty new.

If if you look on this list, some things to note, fall protection, general requirements, the number one that has been the top of the list for the 15th straight year.

And if you look at some of these things, fall protection ladders, scaffolding and fall protection training, they’re all related to fall exposure.

So four of these things are related to 4 exposures.

The other thing on this one is five are from general industry and five are for construction.

So they’re kind of spreading it across your penalty levels.

The good news here is there’s been no change, no adjustment in 2026.

Every year they they adjust and typically they didn’t do it this year.

Just to go over a few of these things like your common posting requirements or, or common posting violations.

That’s like failing display your OSHA poster, not posting OSHA citations or notices in the workplace your serious violations or I’m sorry, your other than serious violations, these are your technical or administrative violations like paperwork errors or minor safety deficiencies.

Your serious violations.

These are the ones that are directly related to hazards that could cause a serious harm or injury or death.

Failure to abate violations this penalty it is designed to incentivize timely correction of hazards to make sure that they’re for ongoing compliance.

They do this by they can impose daily fines for each day that the violation remains uncorrected after the abatement date.

Your willful violations.

This was where the employer knew about the violation and intentionally disregarded the OSHA standards.

These carriers these carry the highest penalties and then you have repeated violations.

This indicates a pattern of non-compliance and fines are increased and they’re pretty severe to make sure that people are incentivized for compliance.

So some good news on penalties don’t like just throwing out the bad news, but the good news here is, is this is they’ve updated penalty reductions for small businesses.

Now they do have a previous OSHA history reduction is 20%, so that history pertains to your history with OSHA.

So if you haven’t had any previous history, then you can get a 20% reduction.

They have a 25% reduction for good faith.

In order to get this one, you got to have some core elements, leadership and worker participation.

You have to have hazard identification assessment, you have to have hazard prevention and control measures.

You have to have safety and health education and training and you have to have in program evaluation and improvement.

So you got to show all those things to get the good faith.

And then you get into the size reductions for employers that have 1 to 25, you can get as much as a 70% reduction.

Then it goes down 26 to 130% reduction.

Then it goes down furthermore 100 to 100 or 101 to 200 and 5010%.

And then once you get over 251 employers, there is no reduction for for size of the company.

And then lastly, they have a quick fix penalty reduction that’s 15% and that’s applied after other adjustments for history in good faith.

Now reminder Osha’s instant by instance policy that’s now applicable to any OSHA standard, the general duty clause and record keeping violations.

This allows your the penalties to be assessed per employee, per machine and per location rather than just grouping them all together.

So what to expect in the next 12 months under this current administration?

So everything we’ve pretty much covered so far has just focused on enforcement, inspections, citations, penalties, any PS.

But there’s another side of OSHA that that doesn’t get that much attention.

And then that’s their compliance assistance role.

OSHA implemented the OSHA Cares initiative and it’s built around the idea that the agency’s goal isn’t just to go out and cite employers.

It’s to help employers build stronger safety programs before something does go wrong.

The OSHA Cares expands the agency’s customer service and on site compliance assistance resources.

It’s giving employers access to tools, training and support to help them meet the requirements and to protect our workers, the OSHA Cares.

It’s also complements other existing programs such as the Voluntary Protection Program, DPP or the SHARP, which is a safety and health achievement recognition program where those focused on exemplary safety and health management systems.

This OSHA Cares is designed to provide assistance to businesses, especially small to medium size, to help them meet the federal workplace safety requirements through a proactive approach.

And they’ve got it broken up into a couple different categories.

There’s there’s really eight key solutions under this initiative and they arranged from worker assistance to cooperative programs.

The first one is is worksite assistance.

OSHA is expanding their access to compliance assistance during enforcement visits by they’re starting to train compliance officers to give assistance in real time, providing essential tools and resources to help develop or enhance your safety and health programs.

They’re supplying guidance on OSHA standards and initiatives, and they’re trying to build a relationship of solutions and trust.

And then you have the safe and sound where they’re saying a safe workplace is a sound business.

Basically this is a year round campaign that’s encouraging companies to establish proactive safety programs.

And then you have your workers rights.

This is something that we’re all familiar with.

This is helping employers and employees.

No one understand their rights for safe workplace, which are basically a right to a safe workplace, right to training, right to refuse dangerous work, and that’s just to name a few.

They are improving their small business resources.

They have safety and health resources specifically designed for these small business, such as compliance guides and Small business Safety and Health Handbook.

They’re providing more training opportunities and they’re using their training institute education centers or their OT is.

It’s basically a national network of nonprofit organizations authorized by OSHA to deliver safety and health training for all levels of workers.

Then you have your cooperative programs.

OSHA offers a no cost cooperative programs through which trade professional organizations, businesses, industry groups, unions to the like can work cooperatively with OSHA to help prevent fatalities, injuries and illnesses in the workplace.

And then they have more employer resources.

They’re committed to meeting employers where they are and empowering them to build strong safety cultures.

And this could be done using compliance assistant, specialist, on site consultation programs and even the OTI education centers.

And then the last one that’s safety champions.

And I, I got more on that on the next slide.

And this is one of the more interesting things to come out of OSHA Cares initiative.

It’s it’s brand new program.

It just got launched in March 16th and it represents A meaningful shift in how OSHA is engaging with employers.

It aims to move towards a solution business model and basically helping them fix issues, not just site them.

They have this in basically 7 core elements and these 7 core elements, reason why they have these in there because you you’ll find this a lot throughout the OSHA web page.

This is what they use for their small business stuff.

But basically they’re looking for, is there a visible commitment from the top?

Are employees actively involved in safety?

Is there a systematic process for finding hazards?

How are you at eliminating and reducing identifying hazards?

Make sure everyone knows what they need to know.

So doing the proper training, regularly assessing what’s working and what isn’t.

So you got to evaluate your program and then communication coordination.

This is particularly important for host employers or large employers, contractors and staffing agencies.

Let’s see here Safety Champions program it’s they’re in a much stronger position if if you enter this safety champions program, you’re in a much stronger position if OSHA ever does show up for an inspection because it’s showing that sign of good faith and a genuine commitment to safety.

If you want to sign up and learn more about it, you can find more about this on ocean.gov.

Next one is trenching and excavations.

This was effective on 10/1/2000 and 18 it it’s open until further notice.

And inspectors thing to keep in mind.

The reason why I want to talk about this is we’re finding out inspectors they’re actively engaging or actively targeting trenching operations.

So the NEP directs inspectors to initiate inspections whenever they see an open transfer and excavation is observed even during unrelated site visits.

The reason why they’re doing this is penalties that they’re severe and they’re getting more in.

April 20 and April 2026 saw a four point \r\n1,000,000 in proposed penalties across 2 fatal collapses with 2026 maximums reaching 165,000 per will phone repeat violations and covenant persons and protective systems in these things.

They are non negotiable.

Make sure that they’re doing the training before the excavation begins.

Make sure you have it in pre work safety briefings.

These are compliance requirements.

They’re not optional.

And right now we’re actually in a trench.

Safety stand down started on July 15th and ends tomorrow.

But just because it ends today and if you might have missed it, you can have your own.

So, so don’t just do it because you know it’s the official 1.

You can actually mean that you can have your own week later or anytime you want.

Workplace violence.

This is the one that’s on Osha’s regulatory agenda for 2026.

This current proposed rule is specifically aimed at healthcare and social assists or, or social assistance, hospitals, nursing homes, psychiatric facilities, healthcare workers.

But OSHA has been very explicit that the rule does not preclude future expansion to other industries as well.

So even if you aren’t in healthcare, this is something that we all need to be paying attention to now.

So numbers, according to the Bureau of Labor Statistics, there were 5283 fatal workplace injuries in the United States IN2023740 of those were due to violent acts.

Homicides accounted for 458 of those.

That’s 62% of all violent act fatalities and nearly 9% of work related deaths.

And they’re the third leading cause of fatal occupational injuries in the country.

So it’s a mainstream problem.

And so that said, workers who face elevated risks outside of the ones we just mentioned there, anybody that exchanges money for the public, which retail workers, cashiers, bank tellers, drivers, couriers, delivery workers, late night folks earlier early morning hours, working in a high crime area, working alone, those are all the ones.

So if you fit any of those descriptions, make sure you have an elevated risk or are you have an elevated risk profile, you need to make sure you have a plan.

One thing that gets overlooked in workplace violence is the mental health component.

So workplace violence isn’t always just a stranger walking through the door.

It’s also the Co worker who’s struggling.

So on this one, make sure that you have a safe place for the employees to report it and have multiple ways to report these concerns, pathways, you know, that don’t require you going through the direct manager.

And so make sure that there you guys have these different ways of doing this.

So incorporate workplace violence language in your written plan, evaluate your loan workers and remote workers, train supervisors, recognize warning signs and create a culture where it’s safe to speak up and build multiple accessible reporting channels throughout lockout tag out.

Just real quick on this one.

I know I’m approaching my time.

Nothing’s been done on this one, but OSHA is definitely looking to prepare or, or to modernize the lockout hangout lockout tag out standard to reflect new technologies and to clarify acceptable alternatives to traditional energy isolating devices.

Some key focus areas, technology integration, which is going to be recognition and criteria for electronical lockouts or audit capable systems.

They’re going to be looking for it.

It’s still going to be one of their most cited standards.

It’ll be the instance by instance.

And so expect continued scrutiny and potential higher penalties to this.

I look for the SVP’s and the repeat offenders.

They’re focusing on those.

Non compliance with log out, tag out could get you on that SCVP list and then training procedures.

So just make sure that you are focusing on documented training, having written procedures and making sure that you can verify competency.

So where can we go to find some updates?

First one is McGriff resource net.

This is a great website.

If you guys don’t have access to this, please reach out to your McGriff team member.

You’re going to find simple programs, industry specific content, employee facing materials, newsletters, and all sorts of guides.

So if you’re not already on it, please reach out to us.

Next one is the osha.gov was the laws and regulations.

You can find a lot of great information on the osha.gov website, so don’t be too afraid to go there.

You can find all the standards, rulemakings and standard interpretations and even your Neps.

Another website is your Office of Information and Regulatory Affairs.

This is the gatekeeper.

This is where you’re going to find real time information on how a proposed rule or affected rule is, is changing throughout the process.

They only do really update these in spring and fall them and then some additional resources.

You can always go to osha.gov.

You can go to bls.gov to get statistics, and then you can go to regulations.gov for any proposed rules.

And then just a list of resources that we have here.

And again, we can provide you with all these things at a later time.

All right.

Are there any questions?

Thank you so much, Nick, for that wonderful, timely presentation.

I know you covered a lot of information and for those of you who were trying to take notes or whatever, please don’t worry about it.

We will provide a copy of the presentation slide as well as the recording afterwards.

Nick.

Nick, we did have one question.

If you could just clarify the OSHA SST inspection program, is that just for the general industry?

That is for general industry and for construction.

OK.

All right, all right.

Thank you for that clarification.

So again, thank you all for attending on today.

Again, you will receive a copy of the presentation slides as well as the recording afterwards.

Thank you again, Nick, for your wonderful presentation.

And on behalf of McGriff, we would like to thank you all again for your participation.

And we hope you all have a wonderful rest of your day.

Thank you.

Thank you everybody.