As we closed the book on 2013 — a truly remarkable year of OSHA enforcement and regulatory activity — we look to the future, and think about what to expect from OSHA in 2014.  Over the next few weeks, we will roll out what we believe are the 5 most significant OSHA developments to monitor in 2014.

If you are interested in how accurate our past predictions have been, take a look at these articles from December 2011 forecasting five OSHA developments for 2012 and from December 2012 predicting three developments from OSHA in 2013.

Without further ado, here are the 5 OSHA-related developments you should anticipate in 2014, so says the collective wisdom of the national OSHA Practice Group at Epstein Becker & Green:

  1. ...(to be revealed later this week)
  2. Enforcement Focus on Temporary Workers
  3. Hazard Communication Comes Into Focus

December 1, 2013 marked the first key implementation deadline of OSHA’s Hazard Communication standard, which was recently amended to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals.  The HazCom Standard now requires employers to use a standardized system of labeling chemical containers and a standardized format for Safety Data Sheets (formerly MSDSs).  The December 1st deadline was the point by which employers were required to have trained all employees on the new labeling formats and safety data sheet format.  We expect OSHA to scrutinize employers’ compliance with that training requirement in the coming year, to make sure the roll out of the rest of the new Standard’s requirements proceeds as planned.

The next major deadline under the HazCom Standard is not until June 1, 2015, by when employers must implement the new labels and SDSs.  That work should start in earnest in 2014 or employers will find themselves behind the eight ball when these requirements kick-in.  During the transition period, chemical importers, distributers, manufacturers and employers may comply with the old HazCom standard, the new HazCom standard, or a combination of both.  Here is a link to an article with additional information about the upcoming deadlines and requirements of OSHA’s updated HazCom/GHS Rule.

  1. New Judges May Change the Outcomes of OSHA Disputes
  2. Heat Illness Will Get More Attention by Cal/OSHA and Private Litigants