What’s Going On
DAVE JOHNSON:

10 EHS Issues with Significant Impact For 2025-2028
T
he next three years leading up to the 2028 presidential election will be marked by unpredictable national and local politics, precedent-setting legal cases, domestic and international economic uncertainties, global unrest and continued social divisions. It presents a window to look at how the world turns in environmental health and safety. Here are ten developments to track.
1. OSHA’s “4 Es”
First up is OSHA’s role in this de-regulatory climate. We’re going to see OSHA’s leadership lean into what I’ll call OSHA’s “4 Es” or roles — engager, educator, enabler — and enforcer.
Here’s the engagement potential: In 2024, Google's AI says 22 million users visited OSHA's website. This is far, far greater engagement that OSHA achieves through inspections or comments on standard proposals. Plus, these 22 million visitors include millions from small companies that OSHA rarely "touches."
Technology, specifically artificial intelligence, will expand and enhance OSHA's educational offerings. Scores of safety and health topics, issues and concerns will be searched by professionals using generative AI for almost instant identification of very specific queries. And imagine if AI becomes accurate enough and OSHA has the money enough to develop OSHA chatbots for Q&As. Bottom line: OSHA’s website will move from being passive to being interactive.
The value of putting money into making OSHA an enabler, an educator and engager, is that it makes OSHA more relevant. The agency will become more positive (a theme of Safety Differently). It will provide more context for topics and more capacity in terms of resources (another Safety Differently theme) and it allows OSHA to avoid the pendulum swing of politics that causes the agency to be slow-moving, controversial, biased, unpredictable and increasingly irrelevant. Who can argue against OSHA promoting engagement, education, enabling proactive activities — as long as it retains its enforcement responsibility?
2. VPP expands.
The second development is also OSHA-related.
OSHA’s mindset in 2025 is that it’s time to modernize, expand, and enhance the pathways to VPP status. OSHA has been thinking this way for years, has asked for ideas, and the new Labor Secretary and OSHA’s new front office will make VPP expansion more of a priority.
The number of VPP sites has stalled at about 2200 sites since 2008. Last year there were 1854 federal and state sites. The all-time high was 2,436 sites in 2010.
Here are ways VPP could grow:
• Outsourcing: Increase the use of Special Government Employees (SGEs) and third parties, such as CSPs, to supplement OSHA’s application review efforts
• Use independent workplace safety and health auditors (consultants) to supplement the agency’s resources in a third-party audit program to perform VPP reviews
• Partnerships: Increased collaboration with professional organizations
• Marketing: Increased public recognition for VPP companies and sites
• Targeted recruiting: Use AI analytics to comb data to recruit companies identified to be in compliance with consensus standards, such as ANSI/ASSP Z10 or ISO 45001
• Self-audits: OSHA recently announced that it was promoting the value of and allowing workplaces interested in VPP to conduct self-audits to prove their aspirations. These companies would enter VPP at a lower, less mature level of program development if they demonstrate a documented and audited commitment to continuous improvement of safety and health.
Photo: Ecleposs / iStock / Getty Images Plus
3. Voluntary Consensus Standards gain traction.
In the spirit of de-regulation and due to the lack of OSHA standards action — which has been the norm for years — more professional attention will be paid to voluntary standards that benefit from regular updates. These standards include:
• ASTM International E2920-19, Standard Guide for Recording Occupational Injuries and Illnesses
• NFPA 660 combustible dust standard
• NFPA 70E standard for electrical safety in the workplace
• ANSI/ASSP A10.1 revisions to the pre-project and pre-task planning standard -- requires contractors to submit detailed information on safety personnel, training, substance abuse programs, and personal protective equipment (PPE)
• ANSI/ASSP Z244.1 is a new standard focusing on the control of hazardous energy
• ANSI/ASSP Z490 incorporates both in-person and virtual training methods and outlines methods for evaluating training effectiveness.
Also, don’t be surprised if in the next three years there is a move to set voluntary standards for using artificial intelligence in EHS and serious injury and fatality (SIF) prevention.
4. Artificial intelligence applications will be standard in most EHS programs.
AI will not be feared but accepted. AI will have the least impact, in terms of job losses, in professions that require the human touch – that are empathy-driven, face-to-face hands-on jobs like nursing, therapy, coaching, social work — and EHS.
EHS jobs are safe — of course, there will always be exceptions — for one reason. Many programs have been understaffed for years and there is little fat to cut. And think about it. Safety and health pros use empathy, emotional intelligence, and are often either official or de facto therapists, coaches, trainers, emergency responders, security managers and on the floor or construction site “social” workers focused on individual well-being and physical and psychological safety.
These are responsibilities hard for AI to replicate. But EHS work will change, no doubt. Here are three examples:
1. Shift from enforcer to strategist: This move away from policing has been ongoing and will gain momentum. Safety managers will spend less time on paperwork and rulebooks and more time on strategic risk management and culture development using AI-generated data and analytics.
2. New skills of course will be required: Understanding data analytics, AI systems (analytical, generative and agentic), and digital helpers and assistants will become a core part of the job. The importance of companies establishing tightly controlled data sets for AI queries and practice applications can’t be understated as necessary guardrails
3. Collaboration with AI: AI will be a powerful assistant—not a replacement—helping EHS professionals make better, faster decisions using data points pulled from audit findings, hazard ID, incident analysis, worker health status, exposure analysis, and performance of leading and lagging indicators. Data collection and analysis could reach the point of overload if pros get over-zealous.
5. Safety Differently principles turn into practical tools.
Safety Differently has been a topic of discussion for more than a decade, since Sidney Dekker published his book by the same title in 2014. But it hasn’t developed into a staple of most EHS work because of its roots as a philosophy with definitions and principles more than a practical day to day tool.
These are some core principles:
• People are the Solution, not the Problem. Get away from the blame game.
• Safety is the Presence of Positives, not the Absence of Negatives. Focus on success more than failure.
• Human error is inevitable. Plan for it.
• Context — circumstance and conditions — drives behavior
• Build positive capacity in individuals and systems to control hazards
Safety Differently will evolve as an EHS modern toolkit as awareness and promotion grows and best practices and day to day tactics will become better known and more widely used.
6. Leading indicators will become embedded in more EHS programs.
The push is on. OSHA, professional societies, articles, webinars, podcasts, books, conference presentations are all urging greater use of leading indicators. Again, technology will be a significant enabler in giving visibility to and tracking leading indicators.
There is no going back to solely relying on lagging indicators, except in small companies. But the total recordable incident rate will remain the one consensus EHS metric because it is the only EHS metric acknowledged by most senior business executives. On a positive note, AI analytics will give pros a new holistic picture of EHS processes and status. Leading indicators include:
• The frequency of safety meetings
• Percentage of workers completing safety training
• Number of safety inspections conducted
• Number of hazards reported
• Percentage of hazards corrected
• Worker participation in safety programs
• Number of near misses reported
• “Good observations” program data
• Improved understanding of employee safety perceptions using surveys, one-to-one safety conversations, Total Worker Health “huddles”
• Hazard elimination and reduction of risk
AI will not be feared but accepted. AI will have the least impact, in terms of job losses, in professions that require the human touch.
7. SIF prevention becomes widespread
SIF — serious injuries and fatalities – joins the long list of EHS jargon acronyms: OSHA, NIOSH, ASSP, AIHA, VPP, LOTO, TLVs, PELs, PPE, PAPRs, MSDs, MSDSs, SDSs, IDLH, KPI, HOP, BBS, TRIR, etc. that you don’t need to spell out.
SIF prevention will grow because:
• Large companies have had recordable injuries and illnesses under control for years.
• Reducing fatalities and life-changing workplace incidents has not been achieved. This stagnation is depicted in probably the most widely-used safety and health chart in the EHS world – the flatlining of the number of occupational fatalities in the past ten years.
• Significant improvement in safety and health human losses — the over-arching EHS goal — cannot be claimed until the most consequential incidents — fatalities, life-altering injuries & illnesses, process safety events, broad environmental exposures are markedly reduced.
The sense of urgency in preventing SIFs will not let up. The credibility of the EHS profession depends on progress — and a new chart showing fatalities decreasing.
8. Health, in particular mental health, becomes more equal to the emphasis on safety.
Safety used to dominate the term safety and health. It was literally safety first. But health in recent years has achieved a degree of balance with safety. Partly because more work is white collar compared to blue collar today, and office work is a prime environment for psychosocial hazards such as bullying, harassment, violence, fatigue, long hours, work overload and interpersonal conflicts.
More serious action will be taken on mental health in the workplace due to growing recognition and acceptance of psychosocial hazards and stress points like these uncovered in a recent survey:
• 24% of employees are stressed because they say they have more work to complete than time to do it.
• 24% say they don’t have enough resources or the right tools to do their job properly.
36% think management does not take employee input and feedback on safety issues, such as hazards, seriously.
• Employees believe their employer prioritizes company reputation (75%), bottom line finances (68%) and employee productivity (68%) over safety.
• 26% employees admit their workplace safety fears have skyrocketed in the past few years.
• 56% admit they don’t feel completely safe at work.
One note: white collar office work may be more mentally taxing, but construction in recent years has had the second highest rate of suicides of any industry. Dr. David Daniels, a psychological safety expert, believes suicides, which are very often difficult to link to workplace traumas and stresses, are in fact the leading cause of fatalities at work.
9. Leadership becomes more essential than ever.
The old adage, Safety starts at the top, must be more than rhetoric in the next three years. Why? To remove the mental health stigma; to value safety in the age of voluntary, discretionary compliance; to fairly negotiate EHS staff and budget cuts; and to steer AI EHS adoption.
Here are 8 leadership traits — not states which can change — needed to meet these challenges:
1. Be Proactive — too much of the EHS world is reactionary
2. Be Curious — too many employers only want to know total recordable incident numbers
3. Be Open-minded and accepting — this comes with more data being collected, and it is especially important w/hard findings from audits, incidents & hazard ID
4. Be Action-oriented with findings — if you find it you fix it/no delays, denials or deferrals
5. Be Value-based — EHS cultures are built on core corporate values, not priorities that will change
6. Communicate — This is especially important with so much data being collected. Findings must be transparent and disseminated at all levels of an organization to build trust and engagement.
7. Actively care — a term coined by E. Scott Geller more than 20 years ago is more relevant than ever given the stress points listed earlier. Leaders must listen, coach, mentor, converse, reward and correct with empathy and patience.
8. Be positive — A positive, encouraging, rewarding mindset is needed for the first seven leadership traits.
Positivity — not safety’s longstanding focus on negative events — is emphasized by Safety Differently.
10. The gap between EHS haves and have nots widens.
The EHS world has always been divided into two realms, the haves and the have nots.
There is the beyond compliance, management systems processes of multi-national and high-risk enterprises with deeper resources and larger staffs.
And almost on another planet is the compliance-focused reactive cultures of many small and mid-size companies that very often do not have an EHS professional on staff and leadership with little or no interest in safety and health.
The have nots are still very much with us.
Here is copy for a recent ad: “Struggling to understand OSHA regulations? Who has time to read ALL those regulations? The manuals are dense, and regulations are difficult to understand. Here’s your ultimate OSHA regulations cheat sheet.”
This “struggle to understand” and need for OSHA cheat sheets has not dissipated after 50+ years of OSHA. A sad commentary indeed.
With deregulation, economic uncertainty and cost-cutting, the “have nots” in EHS will likely increase. It’s very hard to see them decreasing in numbers. EHS budgets and staffs in these smaller companies will not be increasing.
Meanwhile, the haves will continue to invest and improve their safety and health management systems (SHMS):
• Focusing on Serious Incident and Fatality Prevention.
• Integrating Human and Organizational Performance (HOP) Principles.
• Using Stronger Controls for Hazards and Unsafe Conditions.
• Emphasizing Occupational Health.
• Supporting Well-Being and Mental Health
• Using Technology to Advance the SHMS.
• Recognizing the value of Institutional Knowledge and Capacity.
• Using Data-Driven Decision Making.
• Technology-driven Implementation of ISO 45001 and ANSI/ASSP Z10 SHMS will increase beyond compliance companies and will remain out of reach for under-resourced EHS programs.
So there you have it: 10 thoughts on what will be in store for EHS professionals in the next three years. I’ll now glide down from my view from 30K feet and join the rest of you.
Dave Johnson was chief editor of ISHN from 1980 until early 2020. He uses his decades of expertise to write on hot topics and current events in the world of safety. He also writes and edits at Dave Johnson’s Writing Shop LLC and is editor-at-large for ISHN.