Two years ago, January 1, 2024 — back when the world made sense — I drafted some New Year’s Resolutions to advance worker safety, health, and wellbeing. Recognizing that some things take time, especially in the realm of public policy, I decided to give it two years before assessing progress.
Hearkening back to my academic days, I’ve assigned a Grade: reflecting progress on each resolution as of the end of December 2025 – based on data and information available through personal communication and on-line searches.
- A = mission accomplished
- B = some positive progress
- C = very limited progress
- D = no progress
- F = doesn’t even deserve a grade:
- I = Incomplete – because I was unable to assess
This has not been an easy process. The past two years under review present a stark contrast: major progress in many areas during the first year, with rollbacks during the second year.
Nevertheless, we march on: The resolutions follow.
Spoiler Alert: There are very few passing Grades.
Congress resolves to:
- Stop attacking OSHA, MSHA, and the EPA and recognize that the government has a critical role protecting workers, the environment, and consumers.
GRADE: F. For the majority of Republican members
GRADE: A. For majority of Democratic members
GRADE: C: Overall
- Significantly increase funding for Department of Labor workplace health and safety entities (OSHA, MSHA, DOL Wage and Hour Division), EPA, CDC/NIOSH. And the National Labor Relations Board. GRADE: F
- Pass the Protecting the Right to Organize Act(PRO Act) Grade: F
- Pass the Protecting America’s Workers Act Grade: F
- Increase employer penalties for fatalities and serious violations of health and safety, child labor, environmental and wage & hour laws. Grade: D
- Update the nation’s antiquated child labor laws. Grade: F
OSHA resolves to:
- Issue final standards for heat, violence, and infectious diseases. Grade: D-
OSHA went forward with the hearings on the Biden heat proposal. We don’t know yet what will come out of the process – most likely nothing, or possibly a very weak heat standard. Workplace violence has been relegated to the “Long-term Agenda,” and infectious diseases has been removed completely.
- Issue a final rule related to employee walkaround representation during inspections. Grade: A.
Effective May 31, 2024, the rule clarifies that employees can designate any representative (another employee or a non-employee third party, like a union rep or expert) to join an OSHA inspector during a workplace inspection, provided the non-employee is reasonably necessary for an effective inspection. Trump has threatened to repeal it, but it’s still there for now.
- Use and enforce the General Duty clause more vigorously. Grade: D
Biden did use the General Duty clause aggressively, but Trump has proposed a rule to weaken use of the General Duty Clause for entertainment and sports, and possibly other areas as well.
- Increase the number of inspectors and inspections. Grade: D
While staffing rose during the Biden administration, Trump’s proposed budget would result in significant cuts to enforcement staff.
- Strengthen oversight of OSHA state plans. Grade: I.
Hard to imagine that a resource-constrained OSHA was able to enhance oversight
MSHA resolves to:
- Issue final standard on miners’ exposure to respirable crystalline silica. Grade: A
- Fully enforce the coal dust rule. Grade:. Grade: F
MSHA published its final rule titled “Lowering Miners’ Exposure to Respirable Crystalline Silica and Improving Respiratory Protection on April 18, 2024. Unfortunately, Trump’s MSHA has “delayed” enforcement of the rule and recently announced that it was planning to “reconsider” the standard.
- Issue final rule on Safety Programs for Surface Mobile Equipment. Grade: A
The final rule was published on December 20, 2023, and became effective on January 19, 2024.
EPA resolves to:
- Conduct more and more timely chemical risk assessments. Grade: B
New Chemical Risk Assessments. These are pre-market reviews of chemicals before they enter commerce. From January to May 2024 alone, EPA completed 218 risk assessments for new chemicals. In FY 2023, EPA completed 70% more risk assessments compared to FY 2022 and maintained this pace in FY 2024. In FY 2022, EPA completed 480 risk assessments for new chemicals.
Existing Chemical Risk Evaluations under TSCA. These are comprehensive evaluations of chemicals already in commerce – a much more resource-intensive process. In 2024, EPA completed final risk evaluations on 4 existing chemicals: formaldehyde, DIDP, DINP, TCEP.
- Issue the final Risk Management Program rule. Grade: A
The final rule was signed on February 27, 2024, and is titled “Safer Communities by Chemical Accident Prevention.” However, on March 12, 2025, EPA announced the agency is reconsidering the 2024 Risk Management Program Safer Communities by Chemical Accident Prevention final rule. Not a good sign.
- Fully implement the Toxic Substances Control Act. Grade: F
Budget cuts, resource constraints, and administrative policy changes in the Trump Administration have significantly challenged TSCA implementation.
- Stand up to pressure from agrochemical companies and prioritize worker and public health. Grade: C
In August 2024, EPA issued an emergency suspension of DCPA (Dacthal), marking the first time in almost 40 years the agency used this emergency authority. However, this action came only after decades of delay. EPA classified DCPA as a “possible carcinogen” in 1995.
In December 2024, EPA issued final cancellation orders for chlorpyrifos products. The final action allows chlorpyrifos to continue on 11 crops despite links to neurodevelopmental harm in children, and EPA does not plan to determine whether these remaining uses are safe until 2026.
- Increase and ensure robust enforcement of environmental laws & regulations. Grade: F
The Trump Administration is not a fan of the environment or of robust regulatory enforcement.
- Strengthen oversight of state environmental programs. Grade: I
Hard to imagine that a resource-constrained EPA was able to enhance oversight.
- Continue efforts to develop and implement regulations to mitigate Greenhouse Gas emissions. Grade: F
More depressing details here.
Centers for Disease Control and Prevention (CDC) resolves to:
- Issue comprehensive guidelines that protect workers against COVID-19 & other airborne infectious agents. Guidelines that recommend improved ventilation, air filtration, and (belatedly) the use of N95 respirators for staff exposed to airborne infections. Grade: A-.
NIOSH issued guidelines for COVID-19 and other airborne infectious agents in the workplace. Guidelines address respiratory protection (N95s, fit testing), infection control measures (ventilation, cleaning), protecting vulnerable workers, and preventing transmission in healthcare settings, with guidance evolving over time.
- Appoint occupational health and safety and worker experts to its Healthcare Infection Control Practices Advisory Committee (HICPAC) Grade: F
HICPAC was terminated on March 31, 2025, though members weren’t notified until early May. The decision to disband HICPAC was based on President Trump’s executive order to reduce the federal workforce, with HHS stating the committee was “unnecessary.”
- Defer to the expertise of NIOSH on worker health and safety issues. Grade: C-
- Increase the number and reach of NIOSH Health Hazard Evaluations (HHEs) Grade: B
Number of HHEs relatively stable over past 2 years. Given NIOSH resource constraints, this is progress. You can search specific HHE reports here. You can see annual reports for 2024 and 2023 here and here.
National Labor Relations Board resolves to:
- Prosecute more unfair labor practices. Grade: C
Over the past 2 fiscal years, the NLRB received 41,154 charges of unfair labor practice. This represents a significant upward trend, with charges increasing for the fourth consecutive year. More than half of all charges are withdrawn or dismissed, and in cases where an investigation finds probable merit, the majority settle by agreements between the parties
In FY 2023, the Board issued 246 decisions in contested cases, including more than a dozen significant precedent-setting cases, compared to 243 decisions in FY 2022.
Unfortunately, Trump has fired Board members appointed by Democrats and replaced General Counsel Jennifer Abruzzo with an anti-union replacement
Federal and State Courts resolve to:
- Ensure that workers and/or their representatives are included and heard in all OSH and labor cases and proceedings. Grade: I (unable to assess)
- Firmly support the federal government’s role and responsibilities to protect workers, consumers, and the environment. Grade: D
- Retain and/or strengthen application of the Chevron Doctrinethat allows agencies the discretion to issue regulations and enforce the law. Grade: F
- Reverse decisions on the so-called Major Questions Doctrinethat take legislated authority away from regulatory agencies. Grade: F
- Reverse SCOTUS decision on Roe v Wade. Grade: F
States resolve to:
- Vigorously enforce occupational safety and health laws/regulations and strengthen child labor laws instead of weakening them Grade: C
- Become places where workers and their families want to reside and work. Grade: D
Florida and Texas led the nation in attracting new residents between 2023 and 2024, each gaining over half a million newcomers from other states. From a worker rights perspective, the top five states according to Oxfam’s 2024 report were: District of Columbia, California, Oregon, Washington, and New York NRDC. These states scored highest for wages, worker protections (like paid family leave), and rights to organize.
- Set a living wage rate that exceeds the required minimum wage. Grade: C
30 states plus the District of Columbia, Guam, Puerto Rico, and the Virgin Islands have minimum wage rates set higher than the federal minimum wage U.S. Department of Labor of $7.25 per hour. 13 states match the federal minimum wage of $7.25; 7 states either have no minimum wage law or have rates below the federal minimum.
- Issue heat protections for workers in the absence of a federal OSHA standard. Grade: F
Currently, 5 states have heat protection standards: Minnesota, Oregon, California, Colorado, and Washington. Maryland is working to finalize its standard. California is also developing an indoor heat standard to complement its existing outdoor regulations.
- Pass laws providing OSHA coverage to public employeesin the 23 states where government workers still have no right to a safe workplace. Grade: F
Workers at state and local government agencies are not covered by Federal OSHA. This means that in the 23 states without any OSHA-approved State Plan, state and local government employees have no OSHA protections at all. Only states with approved State Plans are required to provide OSHA-equivalent protections to their public employees.
Employers resolve to:
- Put worker safety first by providing a safe workplace and complying with all workplace safety and health regulations and guidelines.
- Provide safety training and give workers a voice in developing safe work practices, processes, and procedures.
- Allow workers to organize unions.
Clearly a mixed bag, depending on the employer. Employers, you must be your own judge of how well you did. Let your conscience be your guide (seeing as it’s unlikely you’ll ever see an OSHA inspector.) Grade: I
Unions resolve to:
- Build on the momentum and recent organizing/contract negotiation successes.
- Launch more creative and ambitious organizing and strike/walkout strategies to build power and make gains for workers.
- Increase union health and safety staff and make safety and health an integral part of organizing campaigns.
Again, a mixed bag – with some successes and some setbacks. For example, according to the Economic Policy Institute, union election petitions increased 27% in fiscal 2024, and workers won 73% of union elections, the highest rate in 15 years. At the end of 2023, the UAW ratified contracts with the Big Three automakers (Ford, GM, and Stellantis), which included significant pay raises, cost-of-living adjustments, and improved terms for temporary workers.
And the Starbucks Workers United campaign became one of the most significant labor organizing victories in recent decades, despite ongoing contract challenges. Over 11,000 workers at more than 500 Starbucks stores across at least 40 states have voted to unionize as of October 2024. The Starbucks organizing campaign stands out for its rapid growth and young worker leadership, though the path to a finalized contract remains contentious.
Despite these successes, unions lost 184,000 members in 2024, dropping private‑sector unionization from 6.0% to 5.9%. According to the Department of Labor (DOL) Bureau of Labor Statistics’ Union Members – 2024 report, the percentage of unionized wage and salary employees decreased for the fourth year in a row to 9.9 percent— the lowest on record. The union membership rate of public-sector workers (32.2 percent) continued to be more than five times higher than the rate of private-sector workers (5.9 percent).
While two-thirds of Americans approve of labor unions, including nearly 90 percent of Americans under age 30, and while nearly half of nonunion workers say they’d vote to join a union if they could, only one in ten American workers are in unions
All this suggests that while organizing wins are up and public approval of labor unions is strong, overall membership density remains a long‑term struggle. Grade: I
Workers resolve to:
- Exercise their right to refuse hazardous and unsafe work.
- Participate in or otherwise support an existing worker safety committee in their place of employment.
Action on these issues varies, depending on where they work, the presence or absence of union protection, and their own personal circumstances. Grade: I
You, Me, and Other Members of the Public: GIVE YOURSELF A GRADE
- Become or continue to be vocal advocates for worker health and safety.
- Participate in public hearings; provide comments or information for relevant proposed rulemaking processes.
- Support and vote for pro-labor, pro-worker candidates for public office.
- Make our displeasure known when elected officials are silent or oppose policies that advance worker safety, health, and well-being.
- Smile and say thank you to the workers you encounter in the course of your day. You know: the ones who ring up your purchases; stock the shelves; serve you a meal; fill you tank; provide your transport; deliver your mail; pick up your trash; provide your health care, your child care, & care for your aging parent/partner/friend; and those who keep the power on and maintain the roads
- Come November, support democracy and turn back authoritarianism once and for all. Grade: I (But hoping for an A+++++)
HAPPY NEW YEAR!