If you think OSHA is stepping back, think again.
On July 1, 2025, OSHA proposed more than two dozen rule changes; including a major change to the OSHA General Duty Clause (GDC), the agency’s “catch-all” rule for citing employers when no specific regulation covers a workplace hazard. A final decision is expected in late 2025 or early 2026.
OSHA General Duty Clause Changes: Inherent Risk
The proposal would limit OSHA’s use of the General Duty Clause for hazards that are “inherent risk” and inseparable from the nature of certain jobs. These are situations where the core activity cannot be done without some level of unavoidable risk.
Some possible examples:
- Stunt and performance work: A professional performing planned action sequences that involve physical impact or falls, even when safety measures are in place.
- Animal handling: Working in close proximity to unpredictable animals, where some level of danger remains despite training and barriers.
- Live event crowd management: Overseeing large groups of people at events where movement, noise, and crowd surges are part of the environment.
- High-risk field inspections: Visiting active work sites with operating equipment or environmental hazards that cannot be completely paused or removed.
- Tactical training: Participating in realistic practice scenarios for law enforcement or security roles that involve physical maneuvers or simulated hazards.
In all cases, employers would still need to take reasonable steps to reduce risk, such as training, protective equipment, and safety protocols, but OSHA possibly would not cite under the General Duty Clause solely for the unavoidable hazard itself.
Does This Mean I Don’t Need to Worry About the General Duty Clause Anymore?
No. Here’s why:
- The GDC still exists: It can be enforced for any hazard that can be reasonably mitigated.
- “Inherent risk” is a high bar: Many legal disputes will center on whether a hazard truly qualifies.
- Other enforcers remain: State level agencies, insurance carriers, and civil lawsuits can still hold you accountable.
When Will the OSHA Rule Changes Take Effect?
OSHA is collecting public comments now. The final decision on the General Duty Clause change, and the rest of the July 2025 proposals, is expected by late 2025 or early 2026.
How Will OSHA General Duty Clause Changes Affect My Business?
Even if your work involves “inherent risks,” this change shifts more responsibility to you:
- You must prove you acted reasonably to reduce hazards.
- Documentation, training, and hazard assessments become even more critical for OSHA workplace safety rules.
- A gap in federal enforcement doesn’t protect you from state, insurer, or court action.
What Should I Do Now to Prepare?
- Assess: Identify and document workplace hazards, including workplace violence and lax security that potentially facilitates criminal attacks.
- Mitigate: Implement reasonable, defensible steps to reduce risks.
- Train: Make sure staff know security and safety procedures and response protocols.
- Document: Keep clear records to prove you are in OSHA compliance and acted in good faith.
What About Workplace Violence and Active Shooter Risks?
While OSHA’s proposed changes cover certain hazards considered “inherent” to specific jobs, many threats that matter to our clients, including OSHA workplace violence requirements and OSHA active shooter preparedness, will still fall under the General Duty Clause or other similar requirements.
That’s because these risks are generally viewed as preventable or reducible through reasonable measures:
- Conducting a workplace violence risk assessment
- Conducting case-specific threat assessments when the need arises
- Establishing and practicing response plans
- Training staff on workplace violence prevention, de-escalation techniques, early warning signs, and emergency procedures
- Coordinating with security professionals for expert support and law enforcement as needed
For security personnel, law enforcement, and others whose roles involve responding directly to potential or actual violent incidents, some element of risk is indeed built into the job. But even in those roles, these OSHA general duty clause changes, and other regulators, expect employers to demonstrate active prevention and preparedness efforts.
This is where TAL Global’s expertise comes in, helping organizations design and document security and safety programs that both protect people and help stand up to regulatory or legal scrutiny.
How TAL Global Helps
We work with organizations to stay ahead of OSHA enforcement, and protect against broader security and safety liabilities:
- Assess: We conduct a tailored security assessment and OSHA compliance review.
- Advise: We identify gaps and provide practical, defensible solutions .
- Support: We help you implement, document, and train for lasting compliance.
Stay Ahead of the Changes
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About TAL Global
TAL Global is an international security consulting and risk management firm with over 25 years of proven experience. We protect people, places, assets, and logistics in an increasingly complex and connected world.
Our team includes former federal agents, military veterans, executive level leaders, and crisis response experts recognized for delivering results under pressure. We are trusted by Fortune 500 companies, government agencies, and mission driven organizations worldwide.
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