OSHA is signaling one thing clearly heading into 2026: contractors should prepare for higher expectations around planning, documentation and proactive hazard control.
Even if the regulations themselves haven’t fully changed, OSHA’s enforcement priorities and rulemaking progress absolutely have. Owners and insurance carriers are aligning with these expectations too, meaning contractors who modernize their programs now will avoid citations, reduce risks and strengthen their competitive position when bidding in 2026.
From high-energy hazard controls to updated heat illness programs and digital documentation, here’s what contractors need to know and how to get ahead before enforcement tightens.
1. HIGH-ENERGY HAZARDS WILL DRIVE 2026 OSHA ENFORCEMENT
OSHA has made it clear that inspections will continue focusing on hazards most associated with serious injuries and fatalities: struck-by, caught-in/between, falls, electrical and trenching.
These activities remain the leading causes of worker deaths and will shape the majority of OSHA inspections in 2026
-
Struck-by hazards: heavy equipment blind spots, haul roads, work zones
-
Caught-in/between hazards: rigging, pinch points, rotating parts
-
Falls: leading-edge exposures and residential construction
-
Trenching & excavation: still one of OSHA’s highest-fatality hazards
OSHA’s National Emphasis Programs reinforce this trend, including those for falls, heat, and work zones.
What contractors should do now: Instead of relying on compliance checklists alone, OSHA wants to see systems that identify high-energy hazards before work begins. Contractors can get ahead by:
-
Incorporating the Energy Wheel concept into pre-task.
-
Adding hazard maps or diagrams showing high-risk areas.
-
Asking crews during daily huddles questions like, What could cause a serious injury today?
-
Refreshing training around struck-by prevention and equipment interaction.
Documentation is becoming one of the clearest indicators of safety performance. Training must be both current and verifiable.
2. UPDATE WRITTEN SAFETY PROGRAMS FOR NEW AND EXPECTED OSHA RULES
Several OSHA rulemakings are advancing in 2026, and contractors will feel the effects even before final rules are published.
> Heat Illness Prevention Standard (Proposed Rule Progressing)
OSHA continues moving toward a federal heat illness standard. Until finalized, OSHA uses the General Duty Clause and Heat National Emphasis Program for enforcement.
What OSHA expects now:
-
A written heat plan
-
Shade, rest, and hydration provisions
-
Acclimatization for new or returning workers
-
Heat monitoring during high-risk periods
Be prepared by adding worker protections now to ensure all workers are safe during the hot summer months and reviewing OSHA’s heat exposure tips here.
> OSHA Walkaround Rule Expansion (Final Rule)
Under the updated rule, OSHA may allow third-party representatives such as safety professionals or worker advocates to join inspections. This increases the importance of having documents, training records and site controls inspection-ready at all times.
> Injury & Illness Electronic Reporting (Expanded Requirements)
More contractors must now electronically submit injury and illness data, and OSHA plans to post some information publicly.
This means accuracy, documentation and timeliness now influence not just compliance but which companies OSHA chooses for targeted inspections.
3. OSHA WILL EXPECT PROOF OF TRAINING AND COMPETENCY
Documentation is becoming one of the clearest indicators of safety performance. Training must be both current and verifiable.
What OSHA inspectors will look for in 2026:
-
Proof that equipment operators are competent, not only trained.
-
Digital or easily accessible training logs with dates and signatures.
-
Documented pre-task hazard analyses tied to specific activities.
-
Evidence that subcontractors received the same orientation and expectations.
-
Follow-up actions documented after hazards or near misses.
OSHA’s stance is reflected in its guidance on competent persons guidelines here.
How contractors can prepare:
-
Create a simple digital log for training: shared drives, apps or spreadsheets all work.
-
Standardize pre-task plans that include high-energy hazard identification.
-
Develop a subcontractor onboarding checklist to ensure alignment.
-
Schedule annual retraining and keep documentation up to date.
Owners and insurance carriers increasingly request this same data, amplifying its importance.
4. EXPECT MORE SCRUTINY OF WORK ZONES AND MOBILE EQUIPMENT
Work zone deaths and struck-by incidents continue to rise nationally, prompting OSHA to intensify inspections involving mobile equipment and mixed-traffic work.
OSHA’s 2026 focus will likely include:
-
Worker visibility in and around equipment traffic
-
Blind spot management and signal person communication
-
Work zone layout (signage, taper lengths, buffers)
-
Equipment inspections and seat belt enforcement
-
Proximity controls and alarms when feasible
Steps contractors should take:
-
Update worker safety guidelines for high-traffic jobsites.
-
Ensure equipment inspections are documented daily.
-
Provide enhanced high-visibility apparel for mixed-traffic conditions.
-
Implement proximity alarms or cameras where practical.
Even small improvements in visibility and communication can dramatically reduce struck-by risks.
5. HOW CONTRACTORS CAN BUILD A 2026 OSHA ACTION PLAN
This simple framework will help contractors stay ahead of changing expectations in the new year.
January–February
-
Update heat illness, fall protection, trenching and equipment programs.
-
Audit injury logs before electronic submission deadlines.
-
Create a plan for handling hazardous materials on construction sites.
March–June
-
Conduct annual orientation and competency refreshers.
-
Standardize pre-task plans.
-
Roll out digital documentation processes.
-
Train all workers on electrical safety hazards and solutions.
July–September
-
Add hazard maps to active projects.
-
Reinforce high-energy hazard identification in daily huddles.
-
Reassess subcontractor safety alignment.
October–December
-
Conduct a mock OSHA inspection.
-
Review all training logs and retraining needs.
Join the Safety & Health track at CONEXPO-CON/AGG 2026 to learn cutting-edge strategies and tech that keep your crews safe and your projects compliant. Register now to secure your spot.
Photo credit: SHUTTERSTOCK/M2020
