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BakerHostetler October 2025 OSHA Safety Update

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Former safety executive at UPS and Amazon David Keeling is confirmed by the U.S. Senate as the new head of OSHA.

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The government shutdown affects OSHA’s work, with the agency announcing that it will pause all but the most sensitive matters.

Employers must nonetheless be mindful of ongoing reporting and recording obligations, and will see no interruption of enforcement in states with their own OSHA agencies.

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As of Oct. 3, after receiving confirmation by the Senate, Assistant Secretary of Labor for Occupational Safety and Health David Keeling is officially leading OSHA. While it may appear odd that OSHA operated without an appointed leader for more than eight months, historically, after a change in presidential administration, OSHA often does not have its assistant secretary confirmed until approximately August. OSHA is structured to operate without a full-time appointed leader.

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Keeling was a health and safety professional and leader at UPS for more than 30 years and spent two years as director of global road and transportation safety at Amazon. Keeling has articulated three goals for his OSHA tenure: 1) improving regulatory oversight and rulemaking, 2) promoting cooperation and collaboration among employers, unions and safety professional groups, and 3) transforming enforcement through technology, such as predictive analytics.

Unfortunately, Keeling stepped into OSHA right after more than 70 percent of its workforce was furloughed. The Department of Labor and OSHA have contingency plans for the shutdown that are generally being followed. <em>See</em>: <a href="https://www.dol.gov/sites/dolgov/files/general/plans/dol-contingency-plan.pdf">https://www.dol.gov/sites/dolgov/files/general/plans/dol-contingency-plan.pdf</a>

OSHA has publicly stated that its reduced crew of compliance officers will continue inspections focused on 1) imminent danger situations, 2) workplace fatalities and catastrophes, 3) complaints involving serious safety and health risks, and 4) abatement of previous high-gravity, serious violations. Our expectations have matched what we are witnessing thus far during the shutdown: OSHA is investigating and spending resources almost exclusively in response to fatalities, significant amputations and complaints of imminent high-hazard dangers.

At least some OSHA area offices are also canceling informal conferences that were scheduled prior to the shutdown. The following are activities that OSHA has publicly acknowledged will temporarily cease during the shutdown:

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Two things that employers must do even if OSHA is not operating (or it is difficult to speak or engage with someone in your local OSHA area office): 1) Timely mail or email your notice of contest to OSHA within the 15-working-day statutory deadline and 2) timely report work-related injuries as required by statute.&nbsp;

Finally, employers need to remain vigilant about worker safety regardless of OSHA’s diminished presence. OSHA has six months after any violation to issue a citation, and nothing prevents the agency from inspecting worksites in connection with past violations after the shutdown ends. Finally, employers should be aware that 21 states operate their own state-funded OSHA agencies, which remain funded and fully operational.

If you have any questions regarding OSHA or safety compliance, or need assistance with federal or state OSHA enforcement, please contact any BakerHostetler OSHA Safety attorney.

Greg Dillard leads BakerHostetler’s OSHA Safety and Catastrophic Accident Response practice teams. He can be reached at <a href="mailto:gdillard@bakerlaw.com">gdillard@bakerlaw.com</a> or 713.646.1333.

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