With President Donald Trump now in his second term, several changes to the Occupational Safety and Health Administration (OSHA) are anticipated based on his previous administration’s approach, current policy signals, and the broader deregulatory agenda he has championed. Here’s what we expect:

1. Full OSHA Enforcement Remains Suspended: The Occupational Safety and Health Commission (OSHRC), the body that adjudicates contested OSHA citations and penalties, has lacked sufficient members to form a quorum since April 28, 2023, and the remaining commissioner’s term expires next month. OSHRC members are appointed by the president, with the advice and consent of the Senate, and are required by law to act only with a quorum of two of the three-member commission. Deputy Solicitor of Labor Jonathan Snare was recently nominated to serve, but unless he is confirmed before the April 27 expiration of Commissioner Atwood’s term, a quorum will still be lacking. Absent a quorum, the significant backlog of cases before the OSHRC will remain unresolved.
2. Reduced Regulatory Activity: President Trump’s first-term administration (2017–2021) saw a significant slowdown in OSHA rulemaking, with fewer new safety standards developed and a focus on rolling back existing ones. This trend is expected to continue, amplified by the “10-to-1” deregulation initiative, which requires agencies to eliminate 10 regulations for every new one introduced. For example, the Biden-era proposed Heat Injury and Illness Prevention Standard, which aimed to protect workers from extreme heat, is unlikely to be finalized. President Trump’s administration paused this rule via a “Regulatory Freeze Pending Review” memorandum issued on January 20, and experts predict it may be scaled back or abandoned entirely, leaving enforcement to OSHA’s general duty clause or state-level rules.
3. Shift in Enforcement Priorities: During President Trump’s first term, OSHA’s enforcement softened, with a 10-percent drop in inspectors (from 878 in 2018 to 790 by 2020) and a focus on voluntary compliance programs over punitive fines. This pattern is expected to repeat, with fewer inspections and a business-friendly approach emphasizing collaboration rather than penalties, especially for small businesses and first-time offenders. The nomination of David Keeling, a former safety director at UPS and Amazon, as OSHA head signals a preference for practical, industry-aligned leadership that may prioritize efficiency over aggressive oversight.
4. Rollback of Biden-Era Rules: Two key Biden-administration OSHA initiatives are likely at risk: the Walkaround Rule (effective May 31, 2024), which allows third-party representatives (like union officials) to join inspections, and the expanded electronic injury reporting requirements (reinstated January 1, 2024). The Walkaround Rule faces legal challenges from business groups, and President Trump’s team could settle these cases by withdrawing it. Similarly, expanded electronic reporting, which requires detailed public-injury data from large employers with 100 or more employees in certain designated high-hazard industries, is expected to be scaled back, as it was in 2019 during President Trump’s first term, thereby reducing administrative burdens and recordkeeping requirements on companies.
5. Legislative Threats to OSHA’s Existence: While not a direct Trump Administration action, Rep. Andy Biggs (R-AZ) reintroduced the Nullify OSHA Act (NOSHA) in February 2025, aiming to abolish OSHA and devolve workplace safety to states and private employers. Though experts consider its passage unlikely due to slim Republican majorities and the need to eliminate the Senate filibuster, it reflects a broader conservative push that aligns with the current administration’s goal of shrinking federal oversight. The Trump administration’s stance on this bill remains unclear, but the current administration’s deregulatory bent suggests sympathy for reducing OSHA’s scope.
6. Impact of Expected Layoffs at NIOSH: The National Institute of Occupational Safety and Health (NIOSH) was created by OSHA as a research arm for high risk workers and for compiling scientific bases for new regulations. Approximately two-thirds of its workforce was laid off as part of the Department of Health and Human Services layoffs. Given that, it will be difficult or impossible for any new regulations to be promulgated and NIOSH investigations conducted in the past, for example into workplace disease outbreaks and certification of respirators, will likely be untenable with the minimal workforce remaining.
7. State-Level Impact: Even if federal OSHA scales back, states with their own OSHA plans (e.g., California, Oregon, Washington) will likely maintain or strengthen rules like heat safety standards, creating a patchwork of regulations. This means employers in these states won’t see relief from safety requirements despite federal rollbacks.
8. Leadership and Budget Pressures: David Keeling’s appointment, alongside deputy Amanda Wood Laihow (a former OSHA adjudicator), points to a pragmatic, less-regulatory focus. Budget cuts or flat funding, as seen in President Trump’s first term, could further limit OSHA’s ability to hire inspectors or pursue new initiatives, reinforcing a leaner agency footprint.

President Trump’s second term is poised to bring a lighter federal OSHA presence — fewer rules, softer enforcement, and potential reversals of recent policies — while state and industry self-regulation may fill the gaps. Employers should prepare for a shift toward voluntary compliance but remain vigilant about state-specific obligations.

Robert W. Clark is a partner in Goldberg Segalla’s Workers’ Compensation and OSHA and Worksite Safety practice groups. He offers experienced, personal, and reliable workers’ compensation and liability-related defense for employers, insurers, self-insured employers, professional employer organizations and third-party administrators. With a focus on helping clients mitigate risk, Bob also provides consultation on OSHA worksite safety compliance and reporting requirements, helping those he represents effectively navigate the Workers’ Compensation claims process in the aftermath of worksite accidents.

Thomas More Buckley serves as vice chair of Goldberg Segalla’s Construction Litigation and Counsel practice and represents businesses in complex commercial litigation. He defends clients against catastrophic personal injury and death claims, construction defect, unfair trade practice claims, and a wide variety of business and contractual disputes, including employment discrimination, wrongful termination, and business dissolution issues. With an intimate understanding of business operations across numerous industries, Tom also defends professional liability and licensing board actions faced by architects, engineers, real estate brokers, and other professionals.