Compliance Stuff

On January 14, 2025, just six days before the transition from the Biden Administration to the second Trump Administration, OSHA closed the books on collecting public comments about the agency’s  Notice of Proposed Rulemaking (“NPRM”) for a Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings standard , taking the proposed rule one step (perhaps a very long step now) away from issuing a final Heat Standard. On behalf of the Employers Heat Illness Prevention Coalition, we submitted a robust set of  written comments  detailing our concerns about some of the more onerous and rigid aspects of the proposed rule. Although OSHA has now moved the Heat Rulemaking so close to the finish line, it is likely that the finish line will be pushed back, potentially for at least four years.  We do not expect Trump’s OSHA to engage in much, if any, rulemaking activity, other than de-regulatory actions. From a process standpoint though, the next time there is a Democra...

  Maryland Occupational Safety and Health (MOSH) issued the final version of its Heat Stress Standards, which became effective on September 30, 2024 , becoming the f i rst state on the East Coast to adopt a heat standard and joining others such as California, Colorado, Minnesota, Oregon, and Washington in doing so. The standards take a sweeping approach to regulating heat injury and illness issues, requiring employers to develop heat-related illness prevention and management plans, monitor temperatures at worksites, train employees, and implement other measures such as breaks and acclimatization programs. MOSH’s  new heat standards   apply to all “employer[s] with employees whose employment activities, indoor or outdoor, e xpose employees to a heat index in the area where the employee is working that equals or exceeds  80 degrees Fahrenheit. ” This effectively covers anybody working outside in the summer as well as many indoor places of employment without air cond...