How a New Directive May Reshape OSHA Regulatory Framework

On October 21, 2025, the Office of Management and Budget’s Office of Information and Regulatory Affairs (OIRA) established an ambitious framework to expedite deregulatory actions across federal agencies. According to an article by John D. Surma of Ogletree Deakins, the directive carries immediate implications for the Occupational Safety and Health Administration (OSHA), which manages one of the government’s most detailed regulatory regimes. 

The OIRA memo shortens review timelines for deregulatory actions, endorses the “good cause” exception under the Administrative Procedure Act to bypass traditional notice-and-comment procedures, and encourages agencies to reassess existing rules through the lens of recent Supreme Court decisions that have limited administrative authority.

For OSHA, this marks a potential turning point. Deregulatory actions deemed “facially unlawful” could move through interagency review in as little as two weeks, far faster than the traditional ninety-day period. The memo also empowers agencies to rescind rules directly if they conflict with statutory text or exceed explicit congressional authorization. In practical terms, this means that OSHA may revisit standards that rely on broad or ambiguous provisions of the Occupational Safety and Health Act, particularly those with significant economic impact or contested feasibility data.

For employers and compliance officers, Surma notes that this evolving framework signals a sharper focus on legal defensibility and quantifiable cost-benefit analysis. While it does not alter OSHA’s core mission under the Occupational Safety and Health Act, the memo establishes a procedural environment that favors rapid deregulatory action. The takeaway for regulated entities: expect shorter timelines, more targeted rulemaking, and a premium on clear statutory authority and data-driven justification when OSHA acts under this new OIRA directive.