The Hearings Are Over. The Standards Aren’t.

OSHA’s deregulatory rulemaking reached the end of its most visible phase last month. The agency held five days of informal public hearings beginning August 19, 2026 and concluding August 26, all held virtually before an administrative law judge. The record is now built. What happens next occurs out of public view.

What the Five Days Covered

The schedule tells you where OSHA expected the most contention:

• August 19 and 20 — the proposal to remove medical evaluation requirements in the Respiratory Protection Standard for filtering facepiece respirators and loose-fitting powered air-purifying respirators. Two full days for a single proposal.
• August 24 — Walking-Working Surfaces, fixed ladders.
• August 25 — respiratory protection provisions across 16 chemical-specific standards, including asbestos, benzene, cadmium, formaldehyde, lead, and coke oven emissions.
• August 26 — the Safety Color Code for Marking Physical Hazards, covering 29 CFR 1910.144, the textiles and sawmills provisions at 1910.262(c)(8) and 1910.265(c)(11), and the shipyard standard at 1915.90.

The One With the Longest Reach

Most of these proposals adjust which respirators may be used for which substance. One does something different.

The fixed ladder proposal would remove the provision setting a November 18, 2036 deadline for installing personal fall arrest systems or ladder safety systems on all fixed ladders extending more than 24 feet above a lower level. OSHA’s stated reasoning is that employers could then replace ladders at the end of their service lives rather than to a fixed calendar date, which the agency expects to significantly reduce costs given how long fixed ladders last.

Read that against your own capital plan. If your facility has been phasing out cages and installing ladder safety systems on a schedule built backward from 2036, the schedule is the thing under review, not the requirement. Fall protection on fixed ladders remains required. The deadline for retrofitting existing ladders is what may move.

Beyond the fixed ladder proposal, another change is worth noting because it is a rescission rather than an adjustment: the construction illumination proposal would remove 29 CFR 1926.26 and 1926.56 from the Code of Federal Regulations entirely.

Where This Leaves You

The same thing that was true in August is true now, and will stay true until final rules publish: every one of these standards is currently in force and currently enforceable. A closed hearing record is not a final rule. It is the point at which OSHA begins writing one.

Two things are worth doing while the agency works. First, if your organization testified or submitted documentary evidence, watch for whether OSHA opens a post-hearing comment period — participation is generally limited to parties who testified on that particular proposal, so this is not a second chance for everyone. The underlying proposals and the full public comment record remain available on regulations.gov under their individual dockets. Second, resist the temptation to pre-comply with a proposal you expect to win. An employer who stops fit-testing today because a proposal might eventually excuse it has simply created a citation with no offsetting benefit.