2026 May - EHS Regulatory Update

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Colleagues,

 Please see the attached May regulatory update. A few items worth your attention: 

• Heat hazard enforcement has stepped up significantly. OSHA’s revised National Emphasis Program is now active, with expanded inspections, including random inspections on heat advisory days. This is no longer a future issue; it’s an active enforcement focus.
• States are not waiting on federal rulemaking. Several states continue advancing their own heat illness prevention requirements. Expect a more fragmented and demanding compliance landscape.
• Regulatory signals remain mixed, but active. While OSHA is proposing to roll back certain requirements (e.g., ladder retrofits), EPA continues to move forward on chemical data, RMP revisions, and PFAS reporting, albeit with shifting timelines. 

These are not isolated updates; they point to a consistent trend:
enforcement and expectations are advancing, even when rulemaking appears unsettled. 

Leadership takeaway:
If your programs rely on “waiting for the final rule,” you’re already behind. Most exposure today comes from enforcement discretion, not regulatory clarity. 

Uncomfortable question:
Where would your operation struggle if OSHA showed up on a heat advisory day and expanded the inspection?

 Let me know if you’d like to discuss any of these topics further.