At the Crossroads: OSHA’s New Rules and Deregulation
As 2025 closes, workplace safety stands at an intersection: New rules on PPE fit and heat stress signal stronger worker protections while deregulatory proposals will reshape how employers will manage compliance in 2026.
- By David Kopf
- Nov 20, 2025
It’s not a stretch to label OSHA regulatory compliance as a moving target but rarely has that felt more literal than it does at the close of 2025.
This year, employers find themselves standing at a regulatory crossroads. On one side, OSHA is expanding its reach with new standards that emphasize inclusion, prevention, and worker well-being. On the other hand, the agency has launched a sweeping deregulatory initiative aimed at streamlining decades of accumulated rules. The resulting map is a bit confusing: protection vs. simplification, expansion vs. reduction.
For safety and health managers, navigating this intersection means staying alert to both directions at once. Here’s where things stand as 2025 winds down and where the road appears to be heading in 2026.
PPE Fit Rule Closes a Lasting Gap
After nearly 15 years of discussion and drafting, OSHA finalized its long-awaited clarification to the construction personal protective equipment (PPE) standard, 29 CFR 1926.95(c), officially requiring that PPE “properly fit each affected employee.”
Effective January 13, 2025, the rule brought construction in line with existing PPE fit requirements already present in general industry and shipyard standards. The change might seem simple, but it addresses one of the most persistent and overlooked contributors to workplace risk: ill-fitting protective equipment.
Too often, workers, and especially women and those with body types outside the “average” range, have had to choose between wearing oversized gear or going without adequate protection. The new rule clarifies that such compromises are no longer acceptable. PPE that doesn’t fit can be considered noncompliant, and therefore unsafe. Moreover, OSHA’s economic analysis found that compliance costs are minimal compared to the potential benefits of injury prevention. The agency’s stance is straightforward: PPE that fits is PPE that protects.
For employers, the compliance path is practical and proactive—review PPE inventories for size inclusivity, engage workers in testing gear for usability, and document fit assessments as part of safety audits. It’s a modest administrative step with a potentially major cultural payoff: signaling that every worker deserves equipment that protects them equally.
Heat Stress Rule Comes into Focus
If the PPE fit rule closes a final, remaining gap, OSHA’s proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings standard aims to build a new bridge entirely. First introduced as a Notice of Proposed Rulemaking (NPRM) in August 2024, the measure has been among the most closely watched in OSHA’s history.
The proposal would require employers to create written Heat Injury and Illness Prevention Plans, triggered when ambient temperatures reach 80°F, with additional controls at 90°F. It includes familiar but crucial elements: access to cool water and shaded rest areas, procedures for acclimatizing new or returning workers, ongoing monitoring for heat stress symptoms, and supervisor and employee training.
OSHA held public hearings through mid-2025, and post-hearing comments are still under review at press time as the post-hearing comments were accepted up to Oct. 30. A final rule is widely expected in mid to late 2026. When issued, it will be the first federal standard explicitly addressing heat-related hazards, marking a milestone in the agency’s response to climate-related risks.
Many states haven’t waited for Washington. California, Oregon, Nevada and Maryland already enforce comprehensive heat rules that cover both outdoor and indoor environments. Notably, California is already preparing to adopt a long-awaited revision to its indoor heat illness rule by early 2026 (the original rule took effect July 2024). Other states, including Washington, Minnesota and Colorado, have narrower rules.
For national employers, this patchwork presents both a challenge and a preview. The prudent move is to act early: adopt written heat programs, designate responsible supervisors, and provide hydration and rest procedures now. These steps not only prepare companies for the eventual rule—they also demonstrate good faith in protecting workers from a hazard that is already among the fastest-growing causes of occupational illness and fatality.
The Deregulatory Wave
Just as OSHA was reinforcing some protections, it announced in July 2025 that it was launching a broad deregulatory initiative that included one final rule and 25 proposed rules designed to modernize, simplify, or rescind older requirements.
The single final rule in OSHA’s deregulatory package eliminated a long-standing procedural requirement that the agency consult with the Advisory Committee on Construction Safety and Health (ACCSH) before issuing, modifying, or revoking any construction safety standard. Published in the Federal Register on July 1, 2025 (90 FR 27996), the rule took immediate effect. OSHA cited the change as a measure to “streamline administrative processes” and reduce delays in construction rulemaking. Because it was deemed a procedural adjustment rather than a substantive one, the agency invoked the Administrative Procedure Act’s “good cause” exemption (functionally if not explicitly) and issued the revision directly as a final rule, without prior notice and comment.
Among the most discussed deregulatory proposals has been OSHA’s plan to narrow the application of the General Duty Clause, which broadly obliges employers to provide workplaces “free from recognized hazards.” Under the proposed change, the clause would no longer apply to “inherently risky professional activities,” where hazards can’t be fully eliminated even with reasonable precautions.
Supporters argue the change would bring more clarity and reduce arbitrary enforcement. Critics warn it could weaken the agency’s ability to address new or complex hazards, such as extreme heat or emerging technologies, before specific standards are developed.
Other deregulatory moves include proposals to rescind outdated illumination standards (29 CFR 1926.26 and 1926.56) and revise medical evaluation requirements for certain respirators, such as N95s and loose-fitting powered air-purifying respirators (PAPRs).
In announcing the initiative, OSHA framed these steps as part of a modernization effort that aims to remove redundancies, improve efficiency, and focus resources on high-impact hazards. That said, the timing is notable; it arrives just as the agency’s regulatory expansion gains momentum.
For safety managers, this juxtaposition of new rules amidst OSHA’s deregulatory efforts underscores the need to keep on top of the agency both, since compliance expectations might tighten in one area even as they ease in another.
Navigating the Intersection
The coming year promises both momentum and uncertainty. The PPE fit rule has already altered expectations in construction. The heat illness prevention standard is poised to reshape workplace health protections nationwide. Meanwhile, OSHA’s deregulatory campaign will continue to test the boundaries of what “modernization” really means.
So, what should safety and health managers do in terms of regulatory compliance as they steer into 2026? It begins with these five priorities:
- Reassess PPE programs. Verify that equipment is available in appropriate sizes and that fit is checked and documented.
- Develop or update heat illness prevention plans. Even before the federal rule is finalized, early implementation can save lives and reduce liability.
- Stay informed on deregulatory proposals. Streamlined standards could shift how inspections are conducted or citations are issued.
- Monitor state plan updates. State-level approaches, especially from states with very proactive or innovative state OSHA programs, might become models for federal adoption down the road.
- Train supervisors to recognize evolving risks. From climate stress to automation, emerging hazards will demand continually refreshed awareness.
For safety managers, these developments aren’t conflicting directions; they’re intersecting paths that must be navigated together. Whether the road ahead bends toward expansion or deregulation, workplace safety and regulatory compliance are clearly not standing still. As the regulatory landscape shifts, proactive, informed leadership will be the surest way to move safely through the crossroads.
This article originally appeared in the November/December 2025 issue of Occupational Health & Safety.