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36 Pallet C e nt ral • Janu a r y -Fe b r u a r y 2 0 25 OSHA BY ADELE L. ABRAMS, ESQ., ASP, CMSP 2025 FORECAST FOR OSHA T he contentious 2024 national elections are over, and a major shift will occur on January 20, 2025, as the "Trump 2.0" administration takes over. e next four years will differ from President Trump's first term in that much of his cabinet has already been selected, and instead of trying to appease the "mainstream" GOP as he did early in his first term, he now is able to nominate individuals who are loyal supporters, for the most part. Instead of working to manage the myriad regulatory agencies that they have been tasked to lead, this time there will be more of a deregulatory mission . . . including dissolution of some agencies entirely (e.g., the Department of Education, Bureau of Labor Statistics, and even OSHA), or otherwise laying off career staff and appointing individuals who will more efficiently implement President Trump's mission. e soon- to-be-formed new office DOGE (Department of Government Efficiency) will be headed by Elon Musk and former GOP candidate Vivek Ramaswamy, and all signs point to DOGE pushing for rapid cuts across many agencies. On the regulatory front, a 10–1 deregulatory agenda has been floated: for each new rule that an agency promulgates, 10 existing rules would need to be rescinded. Using OSHA as an example, in order to finalize the heat illness prevention standard now under development, the agency would have to select 10 other worker protection laws for revocation. If OSHA proceeds with its workplace violence prevention rule, another 10 safety standards would bite the dust. e real question, of course, is who would make those selections and what impact would such rescission have on injury and fatality rates going forward. Key factors in determining OSHA's fate will be the head of the US Department of Labor and the selection to run OSHA. During Trump 1.0, there were two Secretaries of Labor over four years, but they left OSHA largely intact. Trump's intended nominee for DOL this time is Rep. Lori Chavez-DeRemer (R-OR), a favorite of Teamsters President Sean O'Brien, and one of few GOP members of Congress to co-sponsor the Protecting the Right to Organize (PRO) Act (she lost her reelection bid). Right wing GOP members are expected to oppose the nomination, while she has been endorsed by Democratic senators and also several unions. If her nomination is DOA, then the replacement may be more aligned with the Project 2025 goals for the Labor Department: reducing minimum wage and overtime pay, allowing youths under 18 to work in hazardous jobs such as construction and mining, and rolling back OSHA protections. In 2021, Trump's nominee to head OSHA, Scott Mugno from Federal

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