As workplaces, technology, and safety controls change, OSHA periodically reviews its standards to determine whether existing requirements should be updated, clarified, or removed. OSHA is currently considering a series of deregulatory actions intended to modernize workplace safety standards, eliminate requirements the agency considers outdated or duplicative, and provide employers with greater flexibility in complying with certain requirements. The proposals were initially published in the Federal Register in July 2025, with an additional proposal involving walking-working surfaces and fixed ladders published in April 2026.
PROPOSED RULES:
Respirator Medical Evaluations Could Change
One of the proposals with the greatest potential relevance to healthcare involves OSHA’s Respiratory Protection Standard. Under the current standard, employers generally must provide a medical evaluation before an employee is required to use a respirator. OSHA is proposing to remove some of those medical evaluation requirements for employees who use certain types of respirators—specifically, filtering facepiece respirators and loose-fitting powered air-purifying respirators (PAPRs). Filtering facepiece respirators include respirators commonly used in healthcare, such as N95s.
If finalized, this proposal could change an important component of respiratory protection programs for some healthcare employers. However, it is important to understand what the proposal does not mean. It does not mean employers can stop conducting required respirator medical evaluations today, nor would it eliminate the Respiratory Protection Standard. Requirements involving respiratory hazard evaluation, respirator selection, training, fit testing when applicable, proper use, maintenance, and other elements of a respiratory protection program would continue to depend on the applicable standard and workplace conditions. For now, healthcare employers should continue following existing OSHA requirements while monitoring the rule making process.
OSHA Is Also Reconsidering How the General Duty Clause May Be Applied
Another significant proposal involves OSHA’s interpretation of the General Duty Clause.
Section 5(a)(1) of the Occupational Safety and Health Act requires employers to provide a workplace free from recognized serious hazards when a specific OSHA standard does not address the hazard. OSHA has proposed clarifying its interpretation of the General Duty Clause so that it would not be used to enforce against known hazards considered inherent and inseparable from the core nature of a professional activity or performance.
This proposal deserves attention because the General Duty Clause can play an important role in OSHA’s evaluation of recognized workplace hazards for which there is no specific federal OSHA standard.
Employers should be careful not to interpret the proposal too broadly. A change in how OSHA applies the General Duty Clause would not eliminate an employer’s responsibility to address preventable workplace hazards. Existing OSHA standards would continue to apply, and employers would still need to evaluate hazards and implement required protective measures.
Changes Are Proposed for Several Chemical Standards
OSHA is also proposing revisions to respiratory protection provisions in several substance-specific standards, including those for asbestos, formaldehyde, ethylene oxide, lead, methylene chloride, benzene, cadmium, vinyl chloride, and others. Many of these proposals are intended to better align older substance-specific respiratory protection provisions with OSHA’s broader Respiratory Protection Standard rather than maintaining separate or duplicative requirements.
For healthcare organizations, some of these substances may be more relevant than others. Formaldehyde and ethylene oxide, for example, can be encountered in certain healthcare, laboratory, pathology, or sterilization environments.
These proposals are also a good reminder that employers should know which hazardous substances are present in their workplaces. Safety Data Sheets, chemical inventories, exposure assessments, and the written Hazard Communication Program all help determine which OSHA requirements apply.
Proposed Does Not Mean Final
A proposed OSHA rule is part of the federal rulemaking process. OSHA publishes the proposal, accepts public input, evaluates comments and other information, and may ultimately issue a final rule. The final requirement may differ from the original proposal, or the proposal may not become a final rule at all.
OSHA’s informal public hearings on several of these deregulatory proposals were conducted in late August 2026. Until a rule is finalized, healthcare employers should not revise their OSHA programs based solely on the proposed changes. Continue following the standards currently in effect, including required training, medical evaluations, fit testing, exposure assessments, documentation, and other compliance activities, unless and until OSHA formally changes the applicable requirements.
This is a good opportunity to review your existing safety programs. Make sure your written policies reflect current requirements, that employees are receiving required training, that respiratory protection procedures are being followed, and that your Hazard Communication Program accurately reflects the chemicals present in your workplace.
OSHA’s current deregulatory activity may eventually simplify or modify some employer obligations. Until those changes become final, however, compliance should continue to be based on the OSHA standards that are in effect today.
Not Sure What OSHA’s Proposed Changes Mean for Your Practice?
Keeping up with changing OSHA requirements can be challenging—especially when proposed and final rules, along with existing requirements, are being discussed simultaneously. Total Medical Compliance can help you understand what applies to your medical or dental practice, identify potential gaps in your current safety programs, and ensure your policies, training, and compliance efforts reflect the requirements that are in effect.
Have questions about how an OSHA requirement applies to your practice? Contact TMC today to speak with our compliance team and learn how we can help you stay informed, prepared, and compliant.
Reference: Occupational Safety and Health Administration, Deregulatory Rulemaking. https://www.osha.gov/deregulatory-rulemaking