As we head into 2027, Cal/OSHA and the Cal/OSH Standards Board have a jam-packed year of rulemaking ahead. A wave of new standards and revisions to existing regulations are on the horizon, including:
- “Enterprise-wide” and “egregious” citation classifications for General Industry (formal rulemaking underway; written comments due November 30, 2026, and public hearing set for December 3, 2026)
- Workplace Violence Prevention Standard for General Industry (most recent Advisory Committee meeting held October 27, 2026)
- Adoption of the Worker Walkaround Rule (formal rulemaking underway)
- Revisions to both Indoor and Outdoor Heat Illness and Wildfire Smoke Prevention
Virtually every employer with California operations should have a great interest in having a seat at the table for these highly consequential rulemakings, as most employers stand to be impacted by at least one of these new or revised standards. Because of the numerous regulatory actions the Cal/OSH Standards Board is planning, Conn Maciel Carey’s Cal/OSHA Practice is organizing a flat fee-based, company-anonymous coalition of employers and trade groups to advocate for the most reasonable possible outcomes across numerous Cal/OSHA rulemakings throughout 2027, with participation renewed annually.
How to Participate in CMC’s Annual Cal/OSHA Rulemaking Coalition
Those of you who have participated in any of CMC’s recent OSHA rulemaking coalitions know that together we have consistently had a significant positive impact on OSHA rulemakings. Through our prior rulemaking coalitions, our input has resulted in direct changes to regulatory text, favorable decisions by OSHA about scope, coverage, and substantive elements of regulations and standards, and even industry exemptions.
We intend to follow a similar approach with this rulemaking, by coordinating with our coalition participants to:
- Identify the priority rulemakings that the coalition will address.
- Keep everyone informed about developments with each priority rulemaking.
- Solicit member input about what is feasible, what is not, what may prove most problematic for operations, and what we need to fight hardest to include in or exclude from final rules.
- Advocate for your interests through written comments, testimony at Standards Board and Advisory Committee meetings, and other formal or informal engagement with decisionmakers at the agency.
- Educate coalition members about the rulemakings and final rules through regular email updates and virtual meetings.
Join today to be part of an especially busy rulemaking calendar to close out 2026 and all of 2027.
If your organization is interested in participating, please contact Rachel L. Conn, Chair of CMC’s California Practice, or Eric J. Conn, Chair of CMC’s OSHA Practice. Also, let us know if you have any questions or if you would like to have a call to talk through our plans and strategy for this annual rulemaking coalition, the fee for participating, and the various value-add benefits of participating with our group.
