OSHA Releases Interim Guidance for Worker Walkaround Representative Designation Process

On May 10th, the Occupational Safety & Health Administration, OSHA, issued a memorandum titled “Interim Guidance for Worker Walkaround Representative Designation Process.” This memorandum outlines interim guidance for implementing the Worker Walkaround Representative Designation Process final rule, the Walkaround rule, published on April 1, 2024, and will take effect May 31, 2024.

The interim guidance clarifies that the authorized employee representative for OSHA inspections can be an employee of the employer or a third party, who may accompany the compliance safety and health officer (CSHO) during the inspection when reasonably necessary. Factors for determining the necessity of a third-party representative include their relevant knowledge, skills, or experience with workplace hazards, conditions, or communication needs. The guidance also outlines procedures for determining employee representation and handling disputes, as well as procedures for addressing denials or interference during inspections.