
Regulatory Compliance News & Updates
Keep up to date on the latest
developments affecting OSHA, DOT,
EPA, and DOL regulatory compliance.

Keep up to date on the latest
developments affecting OSHA, DOT,
EPA, and DOL regulatory compliance.
Employees who handle food, clean food processing areas, or work around food-contact surfaces must be trained to understand the practices and procedures used to ensure food is safe to consume. Equally important, however, is the OSHA-related side of training aimed at keeping workers safe.
Busy production lines, heavy equipment, and frequent cleaning tasks can expose employees to numerous hazards. OSHA recently cited a commercial bakery in Illinois for repeatedly exposing employees to safety hazards and failing to train them in electrical work, implement safety-related practices, and enforce the use of personal protective equipment (PPE) when performing electrical work. Proposed penalties totaled over $300,000!
The following table highlights the Top 10 most frequently cited violations for food manufacturing in fiscal year 2025.
| Rank | 29 CFR | Title |
| 1 | 1910.147 | The control of hazardous energy (lockout/tagout) |
| 2 | 1910.212 | Machine guarding |
| 3 | 1910.1200 | Hazard communication |
| 4 | 1910.178 | Powered industrial trucks |
| 5 | 1910.305 | Wiring methods, components, and equipment for general use |
| 6 | 1910.303 | Wiring – general |
| 7 | 1910.219 | Mechanical power-transmission apparatus |
| 8 | 1910.132 | Personal protective equipment – general requirements |
| 9 | 1910.134 | Respiratory protection |
| 10 | 1910.28 | Duty to have fall protection and falling object protection |
| *Data reflect October 2024 through September 2025. | ||
Lockout/tagout. Employees who operate or perform service or maintenance on machines or equipment that must be locked out or tagged must be trained on the energy control procedures to be used. Training must be given prior to employees performing maintenance or service, as needed for employee proficiency, and when there are new or revised procedures. Energy control procedures must be reviewed annually to ensure they’re being followed and to correct any deficiencies.
Machine guarding. Exposed moving parts, frequent cleaning/changeovers, and close employee interaction with equipment make machine guarding critical. Although OSHA’s machine guarding regulations don’t specify training, the General Duty Clause requires that you provide a safe work environment. Employees should understand the purpose of machine guards, the types of guards used at your facility and the importance of not bypassing them, and who to contact if guards are missing or damaged.
Hazard communication (HazCom). Cleaning and sanitation of food production equipment is an integral component of food manufacturing. HazCom gives employees the right to know the hazards of the chemicals they’re exposed to. Paragraph (h) of 1910.1200 outlines the standard’s information and training requirements related to chemical hazards.
Powered industrial trucks (PITs). Congested production areas and warehouses, tight aisles, and limited visibility can pose hazards for both forklift drivers and nearby employees. PIT operators must be trained and evaluated according to the criteria at 1910.178(l)(1) and you must maintain certification that this was completed.
Electrical. In food manufacturing environments, electrical systems are often exposed to moisture, washdowns, chemicals, vibration, and temperature extremes, which increases the potential for hazards. Under 1910.332, training must be provided to employees who are exposed to electrical shock and those who work on or near exposed energized parts.
Personal protective equipment (PPE). In food manufacturing, PPE often serves the dual purpose of protecting workers from injury and protecting food from contamination. Employees must be trained to understand when PPE is necessary; what PPE is necessary; how to properly don, doff, remove, adjust, and wear PPE; its limitations; and its proper care, maintenance, useful life, and disposal.
Respiratory protection. Respirators may be needed during ingredient handling, sanitation, or maintenance processes. OSHA’s regulation at 1910.134 requires training for employees who wear respirators. Training must be conducted before employees use a respirator, repeated annually, and as often as necessary to ensure safe use.
Duty to have fall protection and falling object protection. Food manufacturing facilities often have fall-risk areas such as mezzanines or catwalks above production lines, elevated platforms for mixers and other equipment, and conveyor crossings. Employees who use fall protection or are otherwise exposed to fall hazards must be trained under the requirements at 1910.30. Training must be conducted by a qualified person, as defined at 1910.21(b).
Key to remember: Food manufacturing can expose employees to numerous hazards. Workplace safety training plays a key role in helping employees recognize hazards, work safely, and protect both themselves and the product.
The U.S. Environmental Protection Agency (EPA) is taking another major step toward modernizing hazardous waste tracking. The Agency’s proposed “manifest sunset rule” would officially phase out paper hazardous waste manifests and require the exclusive use of the e-Manifest system. For employers, especially those generating or managing hazardous waste, it’s a fundamental shift in how waste shipments are documented, tracked, and audited.
Since 2018, EPA’s e-Manifest system has been available as a digital alternative to paper manifests. Over the years, the agency has added requirements pushing the industry toward adoption, including mandatory registration and electronic data submission. But despite those efforts, many companies have continued to rely on paper manifests, either out of habit, convenience, or because parts of their waste chain weren’t ready to go digital. EPA even states in the proposed rule that less than one percent of all e-manifest users have completely switched to digital manifest. The proposed sunset rule is designed to close that gap. Once finalized, it would set a firm deadline (24 months) after which paper manifests would no longer be allowed.
EPA’s reasoning is pretty straightforward. Paper manifests are slower, easier to lose, and more prone to errors. They rely on manual handling and delayed processing, which can create gaps in tracking and compliance. A fully electronic system, on the other hand, allows for real-time visibility, standardized data entry, and faster correction of mistakes. It also gives regulators a clearer, more immediate picture of what’s happening across the entire waste life cycle.
One overlooked part of the proposed rule is how EPA is trying to solve one of the biggest barriers to going fully digital, which is signatures in the field. Anyone who has dealt with manifests knows that the weak point is often the hand-off between the generator and the transporter, especially when drivers don’t have system access or reliable connectivity. To address that, EPA is proposing new functionality that would allow users to sign manifests using quick response (QR) codes or even short message service (SMS). In practice, this could mean a driver scans a QR code or receives a text prompt, then completes the signature process directly from their phone. So, no login or full system access needed. EPA is also exploring the ability to use SMS and QR-based tools to make updates to manifest data without needing full system permissions. That’s a big deal operationally, because it removes one of the most common bottlenecks in needing a registered user at a specific site to make even minor corrections.
With that said, moving to a fully digital system still comes with potential issues. It requires coordination across your entire operation. Generators, transporters, and disposal facilities all have to be aligned and capable of using the system effectively. If one party in that chain struggles, it can create delays or compliance issues for everyone involved. There’s also an upfront investment to consider. Companies may need to upgrade internal systems, ensure reliable connectivity, and train employees in new work processes. For organizations with multiple sites or field operations, which can take some planning. But over time, many of those burdens are expected to decrease. Electronic signatures, reusable templates, and centralized record-keeping can significantly reduce administrative work.
One of the biggest shifts employers will notice is the level of visibility. With paper manifests, there’s often a lag between shipment and final documentation. In a digital system, that lag disappears. Information becomes available almost immediately, and regulators have access to the same data. That means errors or discrepancies are easier to find and harder to ignore.
The good news is that companies don’t have to wait for the final rule to start preparing. Taking a close look at your current manifest process is a good first step. If paper is still a major part of your workflow, that’s a clear signal that changes are coming. Making sure your e-Manifest account is fully set up and that employees understand how to use it, will go a long way in avoiding future disruptions.
Keys to remember: The EPA’s proposed Paper Manifest Sunset Rule would set a firm date to phase out paper hazardous waste manifests and require that all covered shipments be tracked through the agency’s electronic e‑Manifest system, in which the Agency says will improve hazardous‑waste tracking and transparency while reducing administrative burden and saving regulated entities roughly $28.5 million per year.
OSHA revised its National Emphasis Program (NEP) on outdoor and indoor heat-related hazards on April 10. Using OSHA and Bureau of Labor Statistics data from 2022-2025, the agency will prioritize inspections in 55 “high-risk industries” in indoor and outdoor work settings.
The revised NEP introduces two reorganized appendices: one that includes information on how OSHA investigators will evaluate heat illnesses and prevention programs and another that provides citation guidance. The updated NEP also includes better guidance designed to strengthen tracking procedures and more effectively implement the program’s enforcement and outreach efforts.
Compliance officers will provide outreach and compliance assistance and broaden inspections if heat hazards are found on heat priority days. Additionally, random inspections will occur on days when the National Weather Service issues a heat advisory or warning.
The revised NEP remains in place for 5 years after the effective date.
Keeping track of employee leave under the federal Family and Medical Leave Act (FMLA) can be challenging, particularly when employees take tiny amounts of intermittent leave. Covered employers must, however, track the leave and keep records on how much FMLA leave employees take, as required by the law and its regulations. Failure to keep track of FMLA leave can result in a violation and claim.
Employers with FMLA-eligible employees must keep records with the following information:
Employers with no FMLA-eligible employees must maintain records under the first bullet only.
While employers aren’t required to ask for certifications, if they do, they must keep those with medical information confidential and separate from the general personnel file(s).
Employers with exempt employees don’t have to keep records of actual hours worked, as long as they presume that employees are eligible for FMLA leave if they’ve worked for the company for at least 12 months.
For exempt employees who take intermittent or reduced-schedule leave, employers and employees should agree on the employees’ normal schedule or average hours worked each week and put this in writing.
The FMLA doesn’t mandate any particular order or form of records.
Employers must keep these records for at least 3 years and make them available for inspection, copying, and transcription by U.S. Department of Labor representatives upon request.
Employers must account for FMLA leave using an increment no greater than the shortest period of time that they use to account for other forms of leave, as long as it’s not greater than 1 hour. This should be clear in the records.
Key to remember: Employers must accurately track how much FMLA leave employees take and keep related records of it for at least 3 years.
Spring has sprung, and with the change in seasons come warmer weather, more flowers and wildlife, and of course, increased construction. If you are a construction company, or haul construction equipment, it is important to go into the busy season prepared.
Each state has regulations on handling oversize or overweight (OS/OW) vehicle movements. These regulations indicate:
Before any trip involving an OS/OW load, it is important to check in on the expectations of each state and obtain the proper permits.
Last year, oversize/overweight permitting saw significant updates with movement windows, escort thresholds, and weekend/night travel allowances shifted in several states. At the same time, agencies are pushing for automation and harmonization, meaning more permits can be issued instantly, but thresholds still vary widely.
Electronic cab cards and permits gained traction in 2025, and many jurisdictions now accept digital copies. However, some states still require paper for OS/OW and specialty permits.
For instance, in many states digital cab cards are accepted for IRP and IFTA, but paper OS/OW permits are still mandatory in most places. Before departure, check your route and prepare both formats as needed. At this point, best practice is to carry both PDFs stored offline, and printed copies.
Many carriers, especially those managing permits in-house, fall into the same traps when applying for or managing permits. Watch out for these frequent errors:
Operating without proper permits can lead to violations which include fines of up to several thousand dollars, impoundment, being escorted off-route, and noncompliance points against your safety score.
Set yourself up for a successful construction season by doing your research well in advance to avoid running into obstacles that may impede your ability to operate on the requested dates. Verify which states require paper permits and which allow digital, and continue to monitor OS/OW rule changes and automation capabilities to avoid delays.
Late last year, we conducted a hazmat survey to better understand the state of safety when transporting hazmat. What we found was encouraging on the surface, but more revealing once we looked closer at how training actually shows up in daily operations. While most organizations are clearly investing time and resources into training, mistakes are still happening.
Most companies are training regularly, and nearly everyone surveyed uses a mix of classroom, online, and hands-on formats. Despite that, compliance issues still show up in everyday work, including paperwork errors, labeling mistakes, rejected shipments, and near misses that shouldn’t happen. These issues don’t suggest training is missing, but they do suggest something is being lost between the training room and the work environment.
Only about one-third of respondents say hazmat safety is truly “second nature” for employees. Most say training is applied well overall, but with occasional lapses that still create risk. Those lapses are exactly where mistakes tend to occur, even in organizations that take safety seriously.
Training usually happens in a controlled setting, with time to explain rules and walk through scenarios. The actual job environment looks very different. Employees are often working under time pressure, switching between transport modes, dealing with changing regulations, and relying on systems that don’t always align as well as they should.
That gap shows up clearly in the survey results. Respondents consistently pointed to documentation errors, marking and labeling issues, and packaging problems as the most common compliance failures. These aren’t careless mistakes; they’re usually judgment calls made in complex situations where employees believe they’re following the rules.
The survey comments made one thing clear: human error remains one of the biggest risks in hazmat operations. Respondents frequently mentioned distraction, fatigue, high turnover, and employees who don’t handle hazmat often enough to build confidence. Others pointed to drivers or third-party carriers arriving without proper paperwork, or undeclared hazmat showing up in inbound shipments.
Even organizations that consider themselves well prepared acknowledged that complacency can creep in over time. When someone has completed the same task dozens or hundreds of times, it’s easy to assume nothing will go wrong on the next one. That assumption is often where small but serious mistakes begin.
This doesn’t mean employees don’t care about safety. It means expecting perfect recall for detailed, high-risk tasks isn’t realistic without consistent reinforcement and support.
The good news is that improving execution doesn’t automatically require more training hours or larger budgets. Many of the strongest survey responses pointed to simple, practical reinforcement methods that keep training top of mind, such as daily checklists, short safety conversations, and reminders about common errors.
Technology is helping bridge this gap as well. Shipping software, digital documentation, and compliance tools are increasingly used to catch errors before shipments move. When systems support decisions at the moment they’re made, they reduce reliance on memory and lower the likelihood of mistakes.
The survey makes one thing clear: companies care deeply about hazmat safety. Safety emerged as the top concern across nearly every question, outweighing cost pressures, paperwork, and efficiency challenges.
But safety isn’t built on training alone. It’s built on reinforcement and practical support that aligns with the real conditions employees face every day. When that support is in place, hazmat safety becomes less about remembering what was taught and more about consistently doing the right thing.
Key to remember: Training is clearly happening, but the survey shows that mistakes persist when training isn’t reinforced in day-to-day work. Real improvement comes from bridging the gap between knowing the rules and consistently applying them under real-world conditions.


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