palletcentral

Pallet C e nt ral • July -Aug u st 2 0 25 41 Adele Abrams, Esq., ASP, CMSP, is Senior Counsel in the Washington, DC, office of Li ler Mendelson PC, where she is part of the firm's Occupa onal Safety and Health group and leads the na onal MSHA prac ce. Adele provides OSHA/MSHA case representa on, training, and consulta ve services on safety and employment law. She can be reached at safetylawyer@gmail.com or 301-613-7498. (ILO) also issued a report in April 2025 exploring how AI, digitalization, robotics, and automation are reshaping occupational safety and health in workplaces worldwide. e report, Revolutionizing Health and Safety: The Role of AI and Digitalization at Work, underscores the need for proactive policies to address AI risks. While robots may take over the most hazardous tasks, workers who maintain and repair robotics may face new dangers, including unpredictable robot behavior, system failures, and even cyber threats that can impact workplace safety. While ergonomic risks may be mitigated by smart machines, improperly fitting wearable devices or exoskeletons may fatigue or injure workers. ILO's OSH Conventions No. 155 and No. 187 provide a foundation for ensuring the right to a safe and healthful work environment in the digital age, and these should be reviewed by multinational employers. In October 2024, the Biden US Department of Labor (DOL) published Artificial Intelligence and Worker Well- being: Principles and Best Practices for Developers and Employers, a guidance document which highlighted DOL's recommended eight AI principles. e guidance, intended to be a roadmap for employers and workers, has now been removed from DOL's website as part of the DEI document purge by the Trump administration. Despite this, it is worthwhile reviewing these eight principles as industry sectors consider and increasingly integrate AI into work practices and safety and health protocols. DOL's 2024 AI Principles and Best Practices included the following: 1. Centering Worker Empowerment: DOL advocated that AI should have the dual aim of benefitting employers while also advancing worker well- being. DOL urged employers to seek regular input from workers as they adopt AI technologies, and to bargain in good faith on the use of AI in union workplaces. 2. Ethically Developing A I: DOL urged AI developers to establish standards so AI systems would protect workers' civil rights, mitigate risks to occupational health and safety, and meet performance requirements. AI systems should allow for ongoing human oversight and review of the data informing decisions. 3. Establishing A I Governance A nd Human Oversight: DOL urged employers to establish governance structures, be accountable to leadership, and coordinate across organizational components when implementing AI systems that impact workers. Including worker input into decision-making is critical. 4. Ensuring Transparency In A I Use: DOL's report said employers should provide workers with advance notice and appropriate disclosure if the company intends to use worker-impacting AI. is includes providing conspicuous notice to workers who will be electronically monitored by AI systems. 5. Protecting Labor A nd Employ ment R ights: DOL discouraged use of AI systems that could interfere with or undermine labor organizing and other protected activities. Employers should also monitor AI systems to ensure they do not undermine worker health or safety, are compliant with applicable OSHA or state laws, and do not interfere with the rights of workers to leave, accommodations, wages, or breaks. 6. Using A I To Enable Workers: DOL stressed that AI should be used to improve job quality and assist workers, rather than replace them. AI can reduce the time workers spent on repetitive tasks and free them to develop and use more valuable skills. 7. Suppor ting Workers Impacted By A I: DOL noted that employers should train workers to use AI systems that complement their work to prevent displacement. If workers are displaced due to adoption of AI, they should be retrained where possible to fill other roles within the organization. 8. Ensure Responsible Use of Worker Data: AI raises concerns about the collection, retention, and use of private workers' data that does not serve a legitimate business purpose. Employers must comply with federal, state, and local laws concerning worker privacy and security, and not share collected data outside of the company without informed consent. Although the Trump Administration has withdrawn this guidance document, and it no longer has materials on AI on the US DOL website, the AI Principles and Best Practices remain just that: a nonbinding set of recommendations for proactive, positive, and ethical implementation of AI in American workplaces.

• Cover