OSHA's regulatory agenda has been moving fast. If your last compliance review was 18 months ago, you have gaps. Here's a practical summary of what's changed and what your EHS team needs to do before your next audit.
Expanded Electronic Recordkeeping Requirements
The most operationally significant change for most employers is the expansion of electronic submission requirements for injury and illness records. Under the updated rule, establishments with 100 or more employees in high-hazard industries must now submit OSHA Form 300 (the Log of Work-Related Injuries and Illnesses) and Form 301 (the Injury and Illness Incident Report) electronically to OSHA each year — not just the 300A summary.
This is a significant data exposure increase. OSHA publishes submission data publicly, so competitors, unions, and journalists can access your injury log data. This has driven many EHS teams to tighten their recordkeeping practices — not to hide incidents, but to ensure that every recorded incident is accurately classified and that near-misses or first-aid cases that don't meet the recording threshold are clearly documented as such.
Heat Illness Prevention: Now a Federal Standard
After years of operating under a general duty clause, OSHA's heat illness prevention rule is now in effect for indoor and outdoor work environments. Key requirements include:
- Heat index monitoring — Employers must monitor heat conditions when outdoor or indoor heat index reaches 80°F or above.
- Water and rest requirements — At least one quart of drinking water per worker per hour, shaded rest areas (or cooled rest areas for indoor work), and mandatory rest breaks at high heat index levels.
- Acclimatization protocols — New workers and returning workers after prolonged absence must follow structured acclimatization schedules for the first 14 days in heat-exposed work.
- Emergency response plans — Specific procedures for responding to suspected heat illness, including training supervisors to recognize symptoms and immediate response protocols.
- Training requirements — Annual training for all heat-exposed workers and supervisors on heat illness recognition, prevention, and response.
OSHA has signaled that heat illness will be a major enforcement priority. Inspectors visiting facilities for any reason are now authorized to ask about heat illness prevention programs even if heat wasn't the basis for the inspection.
Penalty Increases
Maximum penalties for OSHA violations have increased again with the annual inflation adjustment. Current maximums are:
- Serious violations — up to $16,550 per violation
- Other-than-serious violations — up to $16,550 per violation
- Willful or repeated violations — up to $165,514 per violation
- Failure to abate — up to $16,550 per day beyond the abatement date
These figures are per violation, not per incident. A single OSHA inspection that identifies five serious violations is a potential $82,750 penalty event — before any egregious-case multipliers.
Walkaround Rights Update
OSHA's walkaround rule now allows third-party representatives — including union representatives even at non-union workplaces, community organizations, and safety advocates — to accompany OSHA inspectors during workplace inspections. This has significant implications for how inspections play out and requires EHS teams to prepare not just for the technical audit but for the presence of outside observers.
What EHS Teams Should Do Now
- 1Audit your recordkeeping — Ensure your 300 log is complete, accurate, and that every recorded incident has a completed 301. Fix any gaps before your annual submission deadline.
- 2Build your heat illness prevention program — If you don't have a written program with the required elements, build one now. Don't wait for summer.
- 3Train supervisors on walkaround protocols — Every supervisor should know what to do when OSHA shows up: cooperate fully, document everything, involve legal counsel early.
- 4Review your abatement tracking — Any open corrective actions from previous inspections need visible completion documentation. Failure-to-abate penalties compound quickly.
- 5Conduct a gap assessment — Compare your current programs against the updated OSHA standards matrix for your industry.
OSHA compliance isn't a once-a-year exercise anymore. The regulatory environment is moving too fast. EHS teams need live visibility into their compliance posture, not an annual audit.