What the rules actually say right now — and what changes before the end of the year.
Reviewed September 24, 2026
Read this first: this page is a plain-English summary for the crew. It is not the standard, it is not our written safety program, and it is not legal advice. Tennessee is a TOSHA state, so TOSHA is who inspects us. When this page and the actual standard, the manufacturer, or the office disagree — the standard and the office win. Questions, call the office.
OSHA updated the Hazard Communication Standard in May 2024. For substances, the employer deadline is November 20, 2026 — OSHA pushed it back four months from July 20, 2026 in a notice published January 15, 2026. By that date we have to update our workplace labeling, update our written hazard communication program, and retrain anyone who needs it.
Chemical makers had to have substances re-evaluated by May 19, 2026 (also pushed back, from January 19). What that means in the truck: the SDSs and labels coming with new product are changing over, so the binder needs a fresh pass, not a dusting.
For mixtures — which is most of what we carry — makers have until November 19, 2027 and our deadline is May 19, 2028.
29 CFR 1910.1200 · Federal Register, Jan 15 2026The construction PPE rule now says in plain words that protective equipment must be “selected to ensure that it properly fits each affected employee.” OSHA calls this a clarification of what was already required rather than a brand-new rule — but it is now written down, and it is the kind of thing an inspector can see from across the yard.
What that means for us: harnesses, gloves, safety glasses, hard hats and FR that fit the person wearing them. If the only harness on the truck doesn’t fit you, that is not a you problem — text the office and we order your size. Do not make do.
29 CFR 1926.95(c) · Final rule, Dec 12 2024On April 10, 2026 OSHA renewed its National Emphasis Program on indoor and outdoor heat for another five years. That is not a new rule we have to follow — it is a decision about where inspectors spend their time. Attic work, rooftop units, trenches and crawlspaces in a Tennessee July are exactly the picture that program was written around.
The actual heat standard is still only a proposal. It was published August 2024, comments closed January 2025, hearings ran June–July 2025, and post-hearing comments closed September 30, 2025. There is no final rule. Anybody telling you heat rules are now law is ahead of the facts.
Until then the general duty clause still applies: water, shade or A/C, rest breaks, and watching each other. New guys and anybody coming back from vacation are the ones who go down — they aren’t heat-acclimated yet.
OSHA QuickTakes, Apr 10 2026 · Heat rulemaking statusOSHA proposed removing the construction illumination requirements (1926.26 and 1926.56). Comments closed November 1, 2025 and nothing is final. Nothing changes for us today — light the work area. Listed here so nobody is surprised if it moves.
OSHA deregulatory rulemaking docketThis is TOSHA’s own most-cited list for Tennessee construction, January–December 2025. It is the best cheat sheet there is for what an inspector walks up and looks at first.
TOSHA runs the show for private employers in Tennessee. It adopts the federal standards, but a few Tennessee rules add requirements on top:
The TOSHA “It’s the Law” poster has to be up where everybody can see it — that means the shop, not a drawer.
TOSHA vs. federal OSHA differences · Tennessee State PlanThese clocks are federal and they are short. They apply to every employer, no matter how small.
Life-threatening, call 911 first. Then the office. Do not wait until the end of the day, and do not let anybody drive themselves.
615-907-8253We’re past 10 employees, so the small-employer exemption does not apply to us — we keep the OSHA 300 log, the 301 incident report for each recordable, and the 300A year-end summary.
The 300A summary gets posted in the shop February 1 through April 30 every year, signed by a company executive.
Electronic filing to OSHA’s Injury Tracking Application starts at a higher headcount than ours — if we cross 20 employees in a calendar year, the office needs to re-check that before the March filing window.
29 CFR 1904 · OSHA recordkeepingSafety data sheets come from the manufacturer of each product — they can’t be written for us, they have to be collected. Once the office pulls them together we’ll link the binder right here so you can pull an SDS on the phone instead of digging in the truck.
What needs a sheet, by trade:
Pull each one from the manufacturer’s own website — that is the current version, and the November deadline above means a lot of them are being reissued right now. Grab the newest.
TOSHA runs a free, confidential consultation service for small employers — they walk your job, tell you what they find, and it does not generate citations. Worth a call before an inspector picks us instead.
TOSHA consultative servicesWhere this came from. Everything above is pulled from OSHA, the Federal Register and Tennessee’s own TOSHA pages — no third-hand blog summaries. Check the dates before you rely on it; rules move.
HazCom date extension (Jan 15, 2026) · PPE in construction final rule · Heat rulemaking · Heat NEP renewal · TOSHA most-cited · TOSHA differences · Recordkeeping
See something out of date or a hazard we’re missing? Text the office at 615-907-8253.