When federal administrations change, the tone of enforcement agencies like the Occupational Safety and Health Administration also shift—which is evident in a new voluntary safety training program.

Earlier this month, OSHA unveiled its Safety Champions Program, a “cooperative initiative” that the U.S. Department of Labor says encourages employers to proactively reduce the risk of injuries, illness and fatalities. According to the department, the program enables organizations to progress through three stages—Introductory, Intermediate and Advanced—building seven core elements into their safety and health programs.

Since the start of President Trump’s second term in office, the administration has shifted the narrative about OSHA’s role in driving workplace safety outcomes.

“Now, it’s more about cooperation and less about more hardline enforcement,” says Jason Mills, partner at Morgan Lewis & Bockius, calling it a “softer” approach than was taken in the Biden administration. “What [the Safety Champions Program] looks like to me is an opportunity to put a stamp on that.”

The new initiative differs from current efforts like the Voluntary Protection Program in a number of key ways. For instance, the Safety Champions Program doesn’t require OSHA inspection, creating an “easier” pathway to recognition, Miss says. However, employers won’t necessarily get the same “gold star treatment” as they do when they complete VPP.

“But they’ll still get to brag and say they’re a ‘Safety Champion’ approved by OSHA, so it can be a nice benefit,” he says. “VPP is still there, but this is more ‘come one, come all.’ ”

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A new focus on ‘cooperation’

While Mills views the program as “well-intended”—“It’s not meant to be a ‘gotcha,’ ” he says—he does anticipate many employers will be a bit skeptical.

“It’s still an enforcement agency,” he says. “Nothing against them, but many employers probably don’t want to invite them into their business.”

In particular, large organizations with sophisticated safety departments likely have standout programs and could be eager to leverage the benefits of the new OSHA program to showcase their work. However, if they have open OSHA citations, questions will likely emerge about the impact on those of their involvement in the new program.

“If OSHA has cited you in 15 states and they’re all open and on appeal, I don’t know how this would work in practice,” Mills says. “I’m sure OSHA would love large, nationwide employers to be involved, but there is a bit of a rub there.”

Mills suggests that employers considering participating should first understand the organization’s citation history and seek clarity on how OSHA will view program participation and enforcement actions.

Another factor to weigh is the program’s stipulation that participants can work independently or with a safety and health expert designed as a Special Government Employee. SGEs are qualified volunteers from VPP sites, who are trained and approved by OSHA.

Mills characterizes the process as OSHA “deputizing” a private sector employee to take a more active role in driving workplace safety. While he says that aspect can be viewed as a “nice concept” to bridge the gap between the private and public sectors, some employers may have a “kneejerk response” to inviting an outside, non-OSHA volunteer into their internal safety work.

Given the likely hesitation surrounding participation, Mills says HR leaders will need to partner with safety leaders to thoroughly consider how the program could fit into the organization’s safety strategy.

“I do believe they want this to be successful and want to work with employers,” he says about OSHA. “They want to cooperate; that’s the basis of the program.”

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