OSHA and MSHA Propose 30+ Rules Including Rescission of Coordinated Enforcement Regulations on July 1, 2025

Executive Summary

On July 1, 2025, OSHA and MSHA published over 30 proposed rules; among OSHA's proposals is a rescission of coordinated enforcement regulations (OSHA Law Blog). A legal analysis describes the rescission as targeting coordinated enforcement procedures for migrant farmworker programs involving OSHA, the Wage and Hour Division, and the Employment and Training Administration (Jackson Lewis). Comment periods for most proposals run through early September 2025, so scope and impacts may evolve (Well Workforce).

Background

OSHA and MSHA issued a broad set of mid-year regulatory actions on July 1, 2025, including 30+ proposed rules and other deregulatory steps (OSHA Law Blog). One OSHA proposal would rescind coordinated enforcement regulations, with the Department of Labor explaining that such regulations restrict flexibility and create redundant procedures (Jackson Lewis). The same analysis notes the targeted coordinated enforcement procedures relate to migrant farmworkers and involve OSHA, WHD, and ETA (Jackson Lewis). Most proposals are open for public comment through early September 2025 (Well Workforce).

Key Provisions

• Scope of action: OSHA and MSHA published over 30 proposed rules in the Federal Register on July 1, 2025, marking a significant mid-year regulatory slate (OSHA Law Blog).
• Rescission proposal: One OSHA proposal is the rescission of coordinated enforcement regulations; the Department of Labor characterizes such regulations as limiting agency flexibility and creating redundant internal procedures (OSHA Law Blog, Jackson Lewis).
• Program targeted in analysis: A legal summary explains that DOL proposes removing regulatory procedures for coordinated enforcement activities related to migrant farmworkers, involving OSHA, the Wage and Hour Division, and the Employment and Training Administration (Jackson Lewis).
• Timeline: The public comment period for most proposed rules remains open through early September 2025, indicating that specifics and scope may be further clarified before any final action (Well Workforce).
• Related July 1 actions: OSHA also issued a final rule eliminating the requirement to consult its construction advisory committee before changing construction standards, and terminated its rulemaking to add an MSD column to the 300 Log, both effective July 1, 2025 (Jackson Lewis, Well Workforce).

Decision Framework

Two threshold questions drive whether to reallocate compliance resources now: (1) Does the rescission proposal affect OSHA–MSHA coordination at mine sites, or is it limited to other DOL coordinated enforcement programs? (2) How much OSHA/MSHA overlap exists at your specific locations and functions, creating realistic risk of duplicative inspections absent coordination?

• If the rescission is limited to the migrant farmworker coordinated enforcement procedures described in legal analysis, then the proposal does not, on its face, demonstrate a change to mine-site OSHA–MSHA coordination or immediate duplication risk (Jackson Lewis).
• If subsequent rule text or guidance indicates that OSHA–MSHA coordination at mines will be curtailed, then the likelihood of uncoordinated or duplicate inspections could increase and would warrant contingency planning; the proposal exists within a broader July 1 package and may evolve during the comment period (OSHA Law Blog, Well Workforce).
• Before deciding, confirm: review the Federal Register notice and preamble for the rescission to determine whether MSHA or mine-site coordination is implicated (proposal noted here), and track the comment-period developments through early September 2025 (OSHA Law Blog, Well Workforce).
• Before deciding, assess site-specific overlap: map which operations are typically under OSHA versus MSHA at your facilities and review the last 24 months of inspection history to identify any patterns of dual-agency activity. These internal diagnostics will calibrate whether targeted, not enterprise-wide, resourcing is warranted.

What We're Monitoring

• Final scope of the rescission in the Federal Register text to confirm whether mine-site OSHA–MSHA coordination is implicated; watch the proposal docket and agency materials (proposal referenced here) (OSHA Law Blog).
• Public comment period developments through early September 2025 that may clarify intent and operational impacts (Well Workforce).
• Further legal analyses indicating whether the rescission remains focused on migrant farmworker coordinated enforcement procedures (OSHA, WHD, ETA) (Jackson Lewis).