2026 Occupational Health Compliance Timeline and Checklist

As employers prepare for 2026, the occupational health compliance landscape is entering a period of significant transition. OSHA is advancing updates to long-standing standards, including phased changes to the Hazard Communication Standard, potential adjustments to respiratory protection requirements, and new rules addressing emerging risks such as heat-related illness and workplace violence in healthcare settings.

At the same time, the agency faces budgetary and staffing reductions that are expected to shift enforcement priorities toward high-hazard industries while leaving greater responsibility for compliance on employers themselves. State-plan OSHA programs may further accelerate regulatory activity, creating a patchwork of requirements across jurisdictions.

This timeline highlights the most important milestones expected in 2026, with links to authoritative sources to help organizations anticipate, plan, and adapt their occupational health programs.

Q1-Q2, 2026

January 19th, 2026

OSHA Hazard Communication Standard (HazCom) Update - Phase 1

• Alignment with GHS Rev. 7 (and some Rev. 8).

• Employers must begin updating SDSs, labeling, and hazard classifications.

• Full compliance required by January 19th**, 2028**.

• Source:

  • ERA Environmental – HazCom Update Timeline (Sept. 2024)

Proposed, Subject to Finalizations

Respiratory Protection Update

• Possible removal of medical evaluations for filtering facepiece respirators and loose-fitting PAPRs.

• Source:

  • OSHA Proposed Deregulatory Rulemaking

General Duty Clause Interpretation

• Proposal to limit § 5(a)(1) use for “inherent hazards.”

• Source:

  • Haynes Boone OSHA Regulatory Update

Workplace Violence Prevention (Healthcare & Social Services)

• Part of OSHA’s current regulatory agenda.

• Source:

  • Safety+Health Magazine - OSHA Agenda Coverage (June, 2025)

Heat Illness/Injury Prevention Standard

• Federal rule under development

• Source:

  • Safety+Health Magazine - OSHA Agenda Coverage (June, 2025)

Powered Industrial Truck Standard Update

• Modernization proposal.

• Source:

  • Safety+Health Magazine - OSHA Agenda Coverage (June, 2025)

Q3-Q4, 2026

OSHA Fiscal Year 2026 Budget Reduction

• $50 million budget cuts, approximately 233 fewer staff.

• Possibly anticipate fewer inspections, with more focus on high-risk sectors.

• Sources:

  • Ogletree Deakins - OSHA FY 2026 Budget Review (July, 2025)
  • J.J. Keller - OSHA Budget Analysis (July, 2025)

Your 2026 Health Compliance Checklist

Conclusion

Looking ahead, 2026 will be a pivotal year for occupational health compliance. While some regulatory changes will reduce administrative burdens, others will expand employer responsibilities in areas such as hazard communication, workplace violence prevention, and heat illness protection. Coupled with reduced federal enforcement resources and growing divergence among state-level programs, employers cannot afford a reactive approach.

Organizations that invest early in updating policies, training, and recordkeeping systems will be better positioned to navigate uncertainty, demonstrate compliance during inspections, and safeguard their workforce. By treating 2026 as both a compliance challenge and an opportunity to strengthen safety culture, employers can mitigate risk while reinforcing their commitment to employee health and operational resilience.

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Sources

• ERA Environmental. (2024, September). OSHA Hazard Communication Standard update: What you need to know. ERA Environmental Management Solutions. https://www.era-environmental.com/blog/hazcom-update
• Haynes and Boone, LLP. (2025, July 2). OSHA issues wave of rules: One final and 25 proposed. Haynes and Boone News Alerts. https://www.haynesboone.com/news/alerts/osha-issues-wave-of-rules-one-final-and-25-proposed
• Insurance Journal. (2025, May 5). Federal OSHA vs. state plans: Diverging compliance landscapes. Insurance Journal Magazine. https://www.insurancejournal.com/magazines/mag-features/2025/05/05/821564.htm
• J. J. Keller & Associates, Inc. (2025, July 18). Reading the tea leaves in OSHA’s FY 2026 budget request. J. J. Keller Compliance Network. https://jjkellercompliancenetwork.com/news/reading-the-tea-leaves-in-oshas-fy-2026-budget-request
• Occupational Safety and Health Administration (OSHA). (2025). Deregulatory rulemaking. U.S. Department of Labor. https://www.osha.gov/deregulatory-rulemaking
• Ogletree Deakins. (2025, July 15). OSHA’s FY 2026 budget justification offers insight into a much smaller agency. Ogletree, Deakins, Nash, Smoak & Stewart, P.C. https://ogletree.com/insights-resources/blog-posts/oshas-fy-2026-budget-justification-offers-insight-into-a-much-smaller-agency/
• Safety+Health Magazine. (2025, June 27). Multiple changes for OSHA in latest regulatory agenda. National Safety Council. https://www.safetyandhealthmagazine.com/articles/25645-multiple-changes-for-osha-in-latest-regulatory-agenda