Comments on OSHA’s Worker Walkaround Representative Designation Process Due November 13

On August 30, the Occupational Safety and Health Administration (OSHA) issued a proposal to amend its regulation authorizing which individuals can serve as representatives of employees and employers during the physical inspection of a workplace. OSHA’s proposed amendment will revise the language to authorize participation by third parties who are not employed by the employer. Historically, these individuals have provided subject matter expertise specific to the focus of the inspections, such as industrial hygienists or engineers, on behalf of OSHA or the employer. If the proposal is finalized in its current form, these individuals could potentially include worker advocacy and environmental groups, union organizers, and community activists who may seize on opportunities to advance agendas unrelated to workplace safety.

Members are encouraged to submit comments at, the federal eRulemaking portal by Nov. 13, 2023. Include Docket Number OSHA-2023-0008 on all submissions. Read the Federal Register notice for more information. AGC of America plans to submit comments by the Nov. 13 deadline.

For more information, contact Kevin Cannon at or Nazia Shah at

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