OSHA Compliance Changes in 2026: What’s Actually in Effect and What You Still Need to Do

OSHA compliance changes 2026 present a genuinely complex picture — not because there is one big rule that landed, but because five simultaneous workstreams are running at different stages, and the status of each one is different. Some deadlines have passed and you either met them or you didn’t. One is active enforcement right now. Two are final rules that are not yet final. And one is a penalty story where the number didn’t change, but the context around it did.

This is a current-state roundup — what each workstream is, where it stands in June 2026, and what an EHS manager at a manufacturing facility needs to do about it.

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The March Deadline: ITA Electronic Recordkeeping

The first hard deadline of the year was March 2, 2026. If your establishment qualifies under OSHA’s electronic injury and illness recordkeeping requirements, that was your submission date for 2025 data.

Two thresholds apply under 29 CFR Part 1904:

Form 300A (Summary): Establishments with 250 or more employees that are not in an exempt industry, and establishments with 20–249 employees in a high-hazard NAICS code listed in Appendix A to Subpart E, were required to submit the 2025 Form 300A electronically through OSHA’s Injury Tracking Application (ITA) by March 2, 2026.¹

Forms 300 and 301 (Full Log and Incident Reports): The 2023 final rule added a requirement for establishments with 100 or more employees in the high-hazard industries listed in Appendix B to Subpart E to submit the complete 300 Log and 301 individual incident reports electronically. This is a real data-submission requirement — OSHA receives your individual injury and illness records, not just the summary.¹

If you missed March 2, the ITA portal accepts late submissions through December 31 of the calendar year. That does not eliminate the violation for missing the deadline, but submitting late is better than not submitting at all. If you are not sure whether your NAICS code is in scope, check the NAICS code lookup on the ITA coverage application at osha.gov before the year closes.

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HazCom 2026: The GHS Rev 7 Transition Is Real and the Training Deadline Is Coming

OSHA published its final rule updating the Hazard Communication Standard (HCS) to align with the seventh revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS Rev 7) on January 15, 2026.² This is not a small update — GHS Rev 7 changes classification criteria for certain physical and health hazards, modifies SDS and label requirements, and has a cascading effect on workplace hazard communication programs.

The compliance schedule, extended four months from OSHA’s original dates:

• May 19, 2026 (just passed): Chemical manufacturers, importers, and distributors were required to evaluate substances and comply with the revised HCS provisions. OSHA extended the initial January 19, 2026 deadline by four months to allow guidance materials to be published first.²

• November 20, 2026 (upcoming): Employers must update alternative workplace labeling, update the written hazard communication program, and provide additional employee training for any newly identified physical or health hazards under the GHS Rev 7 criteria.²

• November 19, 2027: Chemical manufacturers, importers, and distributors evaluating mixtures (as opposed to individual substances) must be in compliance with all modified provisions.²

Here is where most facilities will have a problem: SDSs get updated when vendors send new versions. Training programs get updated when someone in EHS has time to update them. Those two timelines are not the same, and November 20 is the date OSHA cares about for employee training. If your SDS library reflects GHS Rev 7 classifications but your training still references the old criteria, that is the gap — and it is the kind of gap that shows up during an OSHA inspection as a failure to maintain an adequate hazard communication program.

Work backward from November 20. If you handle substances that changed classification under GHS Rev 7, you need to know which ones, update the program, and deliver the training. That is three steps that take time to do correctly.

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Heat NEP: The Enforcement Program That Does Not Wait for a Final Rule

Here is the most important enforcement development of 2026 that requires no rulemaking to be in effect: OSHA updated its National Emphasis Program on outdoor and indoor heat-related hazards on April 10, 2026 (CPL 03-00-024).³ The updated NEP targets 55 high-risk industries identified using Bureau of Labor Statistics injury and illness data from 2022 through 2025.

The mechanics are direct: on any day when the National Weather Service issues a heat advisory or warning, OSHA compliance officers conduct random inspections of establishments in the 55 high-risk industries. If any inspection — heat-triggered or otherwise — turns up evidence of heat-related hazards, the inspection expands to cover heat. The NEP is a five-year program, effective through approximately 2031.

Manufacturing, agriculture, and construction are in the highest-density zone of the 55 targeted industries. If you operate outdoor work or indoor operations with significant heat load (foundries, bakeries, industrial laundries, warehouses without adequate cooling), assume your facility is on the inspection target list during summer months.

The enforceable standard right now is OSHA’s General Duty Clause (Section 5(a)(1) of the OSH Act) — OSHA cites employers for heat hazards under the clause’s requirement to provide a workplace free from recognized hazards. A formal Heat Injury and Illness Prevention standard has been in development since OSHA published the NPRM on August 30, 2024.⁴ Public hearings ran June 16 through July 2, 2025. Post-hearing comments closed October 30, 2025. OSHA is reviewing the record as of June 2026, with no final rule issued.

What that means for compliance right now: the absence of a codified heat standard does not reduce your exposure. The General Duty Clause is enforceable today. OSHA has publicly identified heat hazards as a recognized hazard across numerous industries. An active NEP with weather-triggered random inspections is running. A written heat illness prevention program — with heat index action levels, acclimatization procedures, hydration requirements, shade access, and emergency response protocols — is the practical minimum for facilities in the 55 targeted industries.

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The Deregulatory Package: What It Is, What It Is Not, and When It Matters

On July 1, 2025, OSHA published a package of more than 20 proposed rulemakings as part of the Trump administration’s Executive Order 14192 deregulatory initiative.⁵ The package has a specific, narrower scope than the word “deregulatory” implies.

What the package actually does: it modifies respirator requirements in substance-specific health standards to align them with OSHA’s general Respiratory Protection standard (29 CFR 1910.134), which is already the primary framework for respiratory protection. The affected standards include asbestos, benzene, lead, cadmium, formaldehyde, methylene chloride, ethylene oxide, inorganic arsenic, vinyl chloride, and roughly ten others.

What the package does not do: it does not remove permissible exposure limits (PELs), eliminate medical surveillance requirements, rescind action levels, or change the underlying health standard structure for any of these substances. The deregulatory purpose is to give employers flexibility in selecting respirator types rather than being locked into substance-specific respirator language that predates modern respiratory protection technology.

Where it stands in June 2026: still in proposed rulemaking. The Federal Register published a consolidated notice on June 3, 2026 scheduling public hearings beginning August 19, 2026.⁶ Notices of intent to testify are due July 6, 2026. After hearings close and post-hearing comments are submitted, OSHA will review the record and issue final rules. None of the substance-specific changes are in effect yet.

Separately, OSHA withdrew its proposed rulemaking to add a musculoskeletal disorder (MSD) column to the OSHA 300 Log. That withdrawal is final and the MSD column requirement will not be issued under this administration.⁵

The practical posture: if you operate under any of the affected substance standards (asbestos, benzene, lead, cadmium, etc.), your current compliance requirements are unchanged. Watch for final rules in late 2026 or 2027 — they will expand your respirator selection options, which could reduce program costs if you are currently using higher-protection respirators than the standard requires.

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Respiratory Medical Evaluations: Still a Proposed Rule, Still Fully Required

A related item that belongs on every EHS manager’s watch list: OSHA proposed to remove some pre-placement medical evaluation requirements for filtering facepiece respirators (FFRs — dust masks, N95s) and loose-fitting powered air-purifying respirators (PAPRs) in a separate NPRM published July 1, 2025 (Docket OSHA-2025-0006).⁷

Current requirement: before an employee is required to use a respirator, 29 CFR 1910.134 requires medical evaluation using OSHA’s Respirator Medical Evaluation Questionnaire (Appendix C). The proposed change would remove that requirement specifically for FFRs and loose-fitting PAPRs, on the basis that these lower-protection devices do not create the same physiological demand as supplied-air or tight-fitting air-purifying respirators.

Status as of June 2026: not final. A public comment period ran through November 1, 2025, and a public hearing was requested. Current medical evaluation requirements for all respirators remain fully in effect. If your program relies on Appendix C medical evaluations or licensed healthcare professional medical clearance before respirator use, nothing has changed.

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National Emphasis Programs: The Enforcement Running in Parallel

While rulemaking moves at its pace, OSHA’s enforcement programs run on a separate track. Three NEPs are active and relevant to manufacturing operations in 2026:

Heat NEP (CPL 03-00-024, April 10, 2026): Described above. Weather-triggered random inspections in 55 industries through 2031.³

Silica NEP: OSHA’s National Emphasis Program on Respirable Crystalline Silica remains active. 29 CFR 1910.1053 (general industry) and 29 CFR 1926.1153 (construction) require a written Exposure Control Plan, designated competent person, exposure assessment, medical surveillance, and engineering controls for operations that generate silica dust. Facilities with cutting, grinding, crushing, drilling, or polishing operations on silica-containing materials are in scope.

Amputations NEP (CPL-03-00-027, renewed June 2025): OSHA renewed the National Emphasis Program on Amputations in Manufacturing Industries.⁸ The program targets machine guarding deficiencies and lockout/tagout program failures. Facilities with punch presses, shears, conveyors, molding machines, or any machinery with amputation exposure points should audit machine guarding and LOTO programs before an inspector arrives.

NEPs are not rulemaking. They are inspection directives that OSHA issues based on injury data and enforcement priorities. They require no new standard. The citations they generate are issued under existing standards — OSHA 300-series recordkeeping, 1910.217 for mechanical power presses, 1910.147 for lockout/tagout, 1910.1053 for silica — and the penalty framework is the same $16,550 per serious violation and $165,514 per willful or repeated violation that has been in place since January 15, 2025.⁹

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Penalty Math in a Deregulatory Year

It is worth being precise about the penalty situation in 2026. The DOL published the annual inflation adjustment notice in the Federal Register on May 27, 2026 (91 FR 31358).⁹ However, OMB Memorandum M-26-11, issued April 17, 2026, cancelled the 2026 inflation adjustment because a government shutdown in fall 2025 prevented BLS from producing the October 2025 CPI-U data required to calculate the adjustment. The 2025 penalty levels remain in effect.

Current maximums:

• Serious or other-than-serious violation: $16,550 per violation
• Failure to abate: $16,550 per day beyond the abatement date
• Willful or repeated violation: $165,514 per violation⁹

These numbers are not going up in 2026 due to the adjustment cancellation. They are also not going down. A facility receiving a willful citation for an unguarded press or an inadequate lockout/tagout program is still looking at $165,514 per violation. The deregulatory environment does not affect penalty levels — it only affects the pace at which new standards are created. Existing standards are enforced at existing penalty levels.

The July 2025 DOL penalty guidelines update did introduce greater flexibility for small employers demonstrating good-faith compliance efforts and quick abatement — but that flexibility applies at the inspector’s discretion and does not eliminate penalties for willful or repeated violations.

An IH assessment that catches a machine guarding gap before an inspector does costs a fraction of one willful citation. That math has not changed.

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State Plans: Not All of This Lands the Same Way

Twenty-nine state plans cover private sector employers. State plans must adopt standards that are “at least as effective as” federal OSHA, but they are not required to mirror every federal enforcement priority.

A few specific points for 2026:

California: Cal/OSHA operates its own heat standard under Title 8 CCR 3395, which has been in effect since 2005 and does not wait for the federal heat final rule. California employers face state-specific requirements that are more prescriptive than the federal General Duty Clause.

HazCom GHS Rev 7: State plans must adopt the revised standard within 6 months of the federal effective date. The compliance dates above apply to federal OSHA states directly. State plan employers should confirm their state’s adoption timeline.

ITA submission: The ITA portal is federal and universal. Both federal OSHA and state plan employers submit to osha.gov/injuryreporting. There is no parallel state submission for the federal ITA requirement.

NEPs: State plans run their own emphasis programs and may or may not mirror the federal Heat NEP, Silica NEP, or Amputations NEP. Cal/OSHA, Michigan MIOSHA, and Washington L&I often run parallel or more aggressive programs.

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The Counter-Signal: What Is Not in Effect That Many Managers Think Is

The volume of OSHA rulemaking activity in 2025–2026 is high enough to create a false impression of how much has actually changed. The reality, checked against primary sources in June 2026:

The 20+ deregulatory proposed rules published July 1, 2025 are still in proposed status. None are final rules. No new respiratory flexibility for substance-specific standards is in effect yet.

The Heat Injury and Illness Prevention standard has been in development since August 2024. Post-hearing comments closed October 30, 2025. No final rule has issued.

The respiratory medical evaluation NPRM for FFRs and loose-fitting PAPRs is in rulemaking. Current 1910.134 medical evaluation requirements remain in full effect.

The gap between announced rules and enforceable rules is the most important thing to track in 2026. The enforcement programs — the heat NEP, silica NEP, and amputation NEP — require no rulemaking and are running today. The standards that would give employers additional flexibility are still months or years from being final.

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What a COOP Retainer Does With All of This

Five simultaneous compliance workstreams running at different stages of the regulatory calendar is precisely the situation a COOP retainer is built for. The ITA deadline in March, HazCom training update in November, heat NEP inspections triggered by weather — those are not one-time events. They are recurring compliance calendar items that require someone to be watching the Federal Register, tracking your facility’s NAICS code against changing requirements, updating training programs when classification criteria change, and building heat illness prevention programs before summer.

Our COOP clients with manufacturing facilities already had the HazCom GHS Rev 7 analysis and the November 20 training update on their compliance calendar the day the January 15 final rule published. We were waiting at the door before the rulemaking was final, because that is what the retainer is for — you do not have to hope someone on your team caught a Federal Register notice before the deadline arrived.

If your facility is working through this list and discovering gaps, that is the right time to have the conversation about what your current compliance support structure is actually tracking. Call us at (316) 264-7050 or request a COOP retainer assessment.

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Sources

Footnotes

1. OSHA Injury Tracking Application — recordkeeping requirements and deadlines: https://www.osha.gov/injuryreporting ↩ ↩²

2. Federal Register — Hazard Communication Standard final rule, GHS Rev 7 compliance dates (January 15, 2026): https://www.federalregister.gov/documents/2026/01/15/2026-00653/hazard-communication-standard ↩ ↩² ↩³ ↩⁴

3. OSHA news release — Updated National Emphasis Program for heat-related hazards, April 10, 2026: https://www.osha.gov/news/newsreleases/osha-national-news-release/20260410 ↩ ↩²

4. Federal Register — Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings NPRM (August 30, 2024): https://www.federalregister.gov/documents/2024/08/30/2024-14824/heat-injury-and-illness-prevention-in-outdoor-and-indoor-work-settings ↩

5. OSHA Deregulatory Rulemaking — full list of proposed rulemakings published July 1, 2025: https://www.osha.gov/deregulatory-rulemaking ↩ ↩²

6. Federal Register — consolidated health standards hearing notice, June 3, 2026: https://www.federalregister.gov/documents/2026/06/03/2026-11126/12-dibromo-3-chloropropane-1-3-butadiene-13-carcinogens-4-nitrobiphenyl-etc-acrylonitrile-asbestos ↩

7. Federal Register — Amending the Medical Evaluation Requirements in the Respiratory Protection Standard (August 20, 2025): https://www.federalregister.gov/documents/2025/08/20/2025-15912/amending-the-medical-evaluation-requirements-in-the-respiratory-protection-standard-for-certain ↩

8. OSHA Amputation NEP, renewed June 2025 — CPL-03-00-027: https://www.osha.gov/enforcement/directives/cpl-03-00-027 ↩

9. OSHA Penalties page — current maximum penalty amounts (2025 levels, in effect as of June 2026): https://www.osha.gov/penalties; Federal Register 91 FR 31358, DOL 2026 penalty inflation adjustment (May 27, 2026): https://www.federalregister.gov/documents/2026/05/27/2026-10456/department-of-labor-federal-civil-penalties-inflation-adjustment-act-annual-adjustments-for-2026 ↩ ↩² ↩³