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Seyfarth Synopsis: David Keeling's confirmation as OSHA Chief could give regulatory and enforcement direction to OSHA when federal government funding is restored, likely moving the agency towards enhanced collaboration with industry and refocusing of enforcement priorities.
Senate Confirms Keeling
On October 6, 2025, as part of a larger confirmation of Trump appointees, the Senate voted 51-47 to confirm as Assistant Secretary of Labor for Occupational Safety and Health, officially placing him at the helm of OSHA.
As we previously blogged, Mr. Keeling is a seasoned safety professional with decades of experience at major logistics and transportation employers in the private sector. His familiarity with complex organizational safety programs positions him to lead OSHA with a nuanced understanding of OSHA regulation and enforcement in the context of the modern workplace.
On June 5, 2025, during his nomination hearing before the Senate Health, Education, Labor and Pensions (HELP) Committee, Mr. Keeling outlined his vision for the agency and policy priorities. He would shift OSHA away from reactive enforcement and toward proactive injury and illness prevention. He seeks to "greatly accelerate the pace of modernization in the area of Regulatory Oversight and Rulemaking," emphasizing predictive analytics and informed design to eliminate hazards before they cause harm.
Revitalized Cooperative Programs
Mr. Keeling has also pledged to revamp OSHA's Voluntary Protection Programs (VPP), which he views as underutilized tools for achieving meaningful safety outcomes. "We must move beyond existing silos and self-imposed barriers to achieve real improvement," he testified, signaling a renewed emphasis on collaboration with employers and industry stakeholders.
Mr. Keeling's cooperative tone stands in stark contrast to the enforcement-heavy and confrontational posture of recent Democratic administrations. Under Mr. Keeling, OSHA is expected to prioritize industry alliances, data-driven safety strategies, and employer-led initiatives that align with regulatory goals.
Workplace Violence and Heat Illness Priorities
Mr. Keeling has signaled an interest in pursuing a new workplace violence standard with employer input, as well as maintain OSHA's focus on heat illness. At this point it is unclear whether that this renewed focus on heat illness will take the form of formal rulemaking or revised emphasis programs.
Does Mr. Keeling Have the Resources to Chart a New Path for OSHA?
Mr. Keeling's confirmation ushers in a new chapter for OSHA—one defined by modernization, employer collaboration, and a data-informed approach to safety. As the agency recalibrates under his leadership, employers should prepare for both opportunity and change.
But any goals Mr. Keeling pursues will be limited by the context of an agency and federal administrative state in a period of significant cost reductions. He faces a currently shuttered federal government, with the majority of OSHA staff furloughed and unavailable to handle basic enforcement functions. When the government does reopen, Mr. Keeling will be working with reduced budgets and fewer human resources than the agency had in October 2024. It remains to be seen whether he will have the staff to pursue his new vision for federal OSHA. But in any event, employers can expect to see an OSHA agency less focused on punishing employers and more focused on moving employers into a new era of health and safety.
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