As we begin the second year of President Trump’s second term, priorities and polices are starting to crystalize at the Department of Labor’s Occupational Safety and Health Administration. David Keeling, former head of safety at UPS, has been confirmed as the Assistant Secretary of Labor for OSHA and is beginning to implement his vision for the agency, which includes a greater emphasis on data and analytics, hazard prevention, and proactive risk mitigation. Rather than using every tool in its toolbox to enforce regulations, as we saw during the Biden Administration, OSHA is now looking to meet employers where they are, creating a new pathway to VPP, highlighting the use of letters of interpretation, and expanding the types and amounts of penalty discounts available.
While OSHA’s budget remains in flux pending negotiation of a full spending bill, we know that it will either remain the same as it was last year or be reduced to levels during the first Trump Administration, meaning the agency will likely remain thinly staffed both in the field and in the National Office. What this means for rulemaking and enforcement remains to be seen, but it almost certainly guarantees that OSHA will have to do less with less. For example, rulemakings like for a heat illness prevention standard or a workplace violence rulemaking process that Mr. Keeling committed to during his confirmation hearing, are likely to move slowly or not at all. We will likely see a decline in the number of enforcement inspections OSHA conducts, but over the first year of this Trump Administration, we still saw OSHA issue a slew of significant citation packages with a number of employers in different industries receiving fines of more than 1 million dollars, along with strongly worded press releases.
Given the speed and scope of change expected at OSHA this year, it is more important now than ever before for employers to keep a close watch on developments at OSHA. Conn Maciel Carey LLP’s complimentary 2026 OSHA Webinar Series, which includes monthly programs (sometimes more often) put on by the OSHA-specialist attorneys in the firm’s national OSHA Practice Group, is designed to give employers insight into developments at OSHA during this period of unpredictability and significant change. Continue reading











