OSHA Updates 14 Standards

As part of the President’s Executive Order for agencies to improve regulations and conduct regulatory reviews, OSHA has been working on reviewing their standards to remove outdated, duplicate, and inconsistent parts of their standards. The latest round of reviews and updates, called Standards Improvement Project – Phase IV, will go into effect on July 15, 2019 and it updates 14 different OSHA standards at a projected $6.1 million/year savings.

⚡ TL;DR: Phase IV eliminated Social Security number collection requirements, updated 911 emergency procedures for areas without auto-location, removed outdated medical surveillance requirements (periodic chest X-rays for lung cancer no longer required), updated hearing loss recordkeeping guidance, simplified lifeline breaking strength from 5,400 lbs to 5,000 lbs, aligned traffic control with DOT standards, and made technical updates to PSM, equipment, and construction standards. Most changes reduce administrative burden while maintaining safety.

Updates range from clarifications and deletions, to updates for current technology, to good news for cats.

⚠️ Why this matters: These aren’t minor tweaks—some eliminate requirements entirely (periodic X-rays, SSN collection), while others align OSHA with newer standards. If your facility has procedures built around the old rules, you need to review and update. For instance, if you’ve been collecting SSNs on OSHA forms, you can stop. If your emergency procedures are built around the old PSM construction standard, that’s now consolidated into the general industry rule.

Social Security Numbers 29 CFR Parts 1910, 1915, 1926

OSHA is eliminating the requirement to collect worker social security numbers in 19 of its standards. Any social security numbers already collected on previous forms can remain on those forms, and if employers want to continue to collect numbers, they may do so.

Medical Services and First Aid 29 CFR 1926.50

Current standards require posting of physician, hospital and ambulance phone numbers where 911 service is not available. At the time, 911 was a relatively new concept, but many of today’s 911 services for landlines can pinpoint the caller’s location. If your area has landline auto-location for 911, you no longer have to post the additional information.

However, the auto-location feature isn’t always available for cell phones in remote locations. The new rule requires employers, in areas where 911 auto-location for wireless phones is not available, to post the latitude and longitude of the current location in a conspicuous place so that emergency services may locate the worksite. Employers are also to ensure that the communication system they are relying on to use to report an emergency is working and is effective.

Medical Surveillance Requirements 29 CFR part 1910, subpart Z

Employers will no longer be required to conduct periodic chest x-rays of their employees for lung cancer purposes. This is a requirement in asbestos, cadmium, coke emissions, inorganic arsenic, and acrylonitrile standards. Medical data has been found that periodic x-rays don’t make much of a difference in reducing lung cancer. However, periodic x-rays are still required for asbestosis determinations, and initial baseline x-rays are still required as well. Digital radiographs will be allowed as well as different sizes of x-ray films.

Occupational Hearing Loss 29 CFR 1904.10

The recordkeeping rule now clarifies physicians must use the standards of 29 CFR 1904.05 to make the determination if a hearing loss is work-related. Previously, employers have been able to not record hearing loss as an injury when a physician determines the loss was NOT work related. However, no guidance was given for physicians in that determination. A cross-reference from 1904.05 will be added to 1904.10 to help make that determination. Get more info on iSi’s work area noise surveys & sampling.

Cotton Dust 29 CFR 1910.1043

The technology of pulmonary function testing has come a long way since 1978. OSHA will be updating the pulmonary function testing guidelines. More info on iSi’s worker sampling protocol development.

Lifelines 29 CFR 1926.104

OSHA is changing the minimum breaking strength of lifelines from 5,400 lbs. to 5,000 lbs. to align with the most recent ANSI/ASSE standards.

Process Safety Management (PSM) 29 CFR 1926.64

Rather than having a separate PSM standard for construction, this standard will now reference the general industry standard 1910.119.

Coke Oven Emissions 29 CFR 1926.1129

OSHA has determined coke oven emissions does pertain to construction work, and will be deleting the standard. Any construction worker exposures to coke oven emissions will fall under the General Duty Clause.

Signs, Signals and Barriers 29 CFR 1926, Subpart G

Employers will now be required to comply with the 2009 version of the Manual on Uniform Traffic Control Devices to better align with DOT’s requirements. OSHA feels the newest version adds better safety controls. These included high visibility safety apparel, stop/slow signage (not just hand signals), the use of automated flagger assistance devices, and crashworthy temporary traffic barriers and lane channelization. Confusing language will be removed from the traffic signs section, and the barricades and definitions sections will be deleted because they’re duplicates.

Materials Handling and Storage 29 CFR 1926.250

Currently, posting of maximum safe load limits of floors in storage areas is required. However, in residential buildings, heavy materials are not placed in areas above floor or slab on grade. Thus, this requirement no longer applies to construction of “single-family residential structures and wood-framed multi-family residential structures.” iSi’s safety assistance services

Underground Construction 29 CFR 1926.800

Mobile diesel-powered equipment used in “other than gassy operations” must now meet the most current MSHA requirements of 30 CFR Part 7, Subpart E.

Occupational Health and Environmental Controls, Gases, Vapors, Fumes, Dusts and Mists 29 CFR 1926.55

“Threshold limit values” will change to “permissible exposure limits” and references to ACGIH standards will be removed. OSHA is also cleaning up phrases such as “shall be avoided”, deleting the terms “inhalation, ingestion, skin absorption, or contact”, will change Appendix A to Tables 1 and 2, and will correct inconsistent and errant table headings, footnotes, cross references and asterisks. iSi’s workplace sampling program development services

Shipyards 29 CFR 1915.80

Feral cats will no longer be considered vermin and thus, no longer a health and safety hazard.

Rollover Protective Structures, Overhead Protection 29 CFR 1926, Subpart W

OSHA is removing test procedures and performance requirements and replacing them with the current standards of ISO 3471: 2008. They will also be making some other technical error revisions.

For more details about each change, read the Federal Register notice here.

Most facilities don’t track standard updates. When OSHA arrives and cites you under an old version of a rule that was revised, you’re still liable. Staying current with Phase IV and subsequent updates requires regular monitoring. A facility that hasn’t reviewed their rescue procedures since the lifeline strength change, or whose medical surveillance is still requiring periodic X-rays when they’re no longer required, creates unnecessary administrative burden and potential audit gaps.

💰 Staying compliant: One regulatory update audit costs $1,500–$3,000. Missing an update that invalidates part of your program can cost $16,000+ in citations when OSHA finds a mismatch between what you’re doing and what the current standard requires.

Frequently Asked Questions

Q: What is OSHA’s Standards Improvement Project and what does Phase IV accomplish?

A: OSHA’s Standards Improvement Project reviews and updates standards to remove outdated, duplicate, and inconsistent requirements. Phase IV, effective July 15, 2019, updated 14 standards with an estimated $6.1 million annual savings by clarifying requirements, removing redundancies, and incorporating current technology and consensus standards.

Q: Can employers still collect Social Security numbers on OSHA forms after the Phase IV update?

A: No, OSHA eliminated the requirement to collect Social Security numbers in 19 standards across 29 CFR Parts 1910, 1915, and 1926. Any previously collected numbers can remain on existing forms, but employers are no longer required to collect them going forward.

Q: What changed regarding medical surveillance requirements for workers exposed to hazardous substances?

A: OSHA eliminated periodic chest X-ray requirements for asbestos, cadmium, coke emissions, inorganic arsenic, and acrylonitrile standards because data showed they don’t reduce lung cancer rates. However, initial baseline X-rays and periodic X-rays for asbestosis determinations remain required under 29 CFR Part 1910, Subpart Z.

Q: How did the lifeline strength requirement change in the Phase IV update?

A: OSHA reduced the minimum breaking strength requirement for lifelines from 5,400 lbs to 5,000 lbs in 29 CFR 1926.104 to align with current ANSI/ASSE consensus standards, while maintaining worker safety levels.

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