Earlier today, I had the opportunity to attend a presentation by Assistant Secretary of Labor for Occupational Safety and Health David Keeling during the AGC Summer Health & Safety Conference in Minneapolis.
As someone who has spent more than three decades working alongside contractors, owners, superintendents, and safety professionals, I was interested in hearing not only what OSHA’s newest leader had to say, but where he believes the agency should be headed.
The presentation wasn’t an announcement of sweeping regulatory changes.
It wasn’t a discussion of new standards.
Instead, it was a conversation about philosophy.
Throughout his presentation, Keeling repeatedly returned to several themes: partnership, education, modernization, business leadership, and using enforcement where it has the greatest impact rather than relying on it as OSHA’s only tool.
Below are the five biggest takeaways I took from his presentation, followed by my own observations about what they could mean for construction employers and safety professionals.
Editor’s Note: This article summarizes remarks delivered by Assistant Secretary David Keeling at the AGC Summer Health & Safety Conference. It reflects my notes and observations from the presentation and is not intended to represent an official OSHA policy statement.
1. Enforcement Is Still Necessary—But It Can’t Be OSHA’s Only Tool
The point that resonated with me most came early in the presentation.
Keeling acknowledged something everyone already knows.
OSHA is, by law, an enforcement agency.
That responsibility is not going away.
But he challenged the idea that enforcement alone can accomplish OSHA’s mission.
Using a golf analogy, he described enforcement as “one club in the bag.”
It was a simple illustration, but an effective one.
A golfer doesn’t play eighteen holes with one club.
Likewise, OSHA cannot expect inspections and citations alone to produce the safest possible workplaces.
Instead, Keeling described an approach that also includes education, outreach, consultation, partnerships, communication, mentoring, and collaboration.
That doesn’t diminish enforcement.
It places enforcement in the context of a much larger mission.
For contractors, that’s an important distinction.
Most companies don’t want an inspection because they failed.
They want to understand how to improve before someone gets hurt.
If OSHA succeeds in expanding the use of those additional tools while maintaining consistent enforcement, it could strengthen relationships between the agency and responsible employers.
2. Most Employers Want to Do the Right Thing
One statement that drew considerable attention from the audience was Keeling’s belief that the overwhelming majority of employers genuinely want to protect their workers.
Rather than describing industry as the problem, he suggested OSHA should concentrate enforcement resources on the relatively small percentage of employers who repeatedly refuse to comply with the law.
He referenced companies that repeatedly violate standards, fail to resolve citations, disappear, reopen under different names, or continually place workers at unnecessary risk.
Those are the organizations he believes deserve the greatest enforcement attention.
That message matters because responsible contractors often find themselves competing against companies willing to ignore safety requirements in order to lower costs.
Targeting chronic offenders more effectively benefits workers.
It also benefits ethical employers trying to compete fairly.
3. OSHA Wants to Be Known for More Than Citations
Another recurring theme throughout the presentation was something Keeling referred to as “OSHA Cares.”
His explanation wasn’t about changing OSHA’s legal authority.
It was about changing perceptions.
He explained that OSHA’s mission isn’t simply writing citations.
Its mission is helping workers return home safely at the end of the day.
That may sound obvious.
But it represents a meaningful shift in how many employers have historically viewed the agency.
For decades, many contractors have associated OSHA almost exclusively with inspections, penalties, and enforcement actions.
Keeling appeared to be encouraging the industry to recognize that OSHA also wants to provide resources, education, partnerships, and assistance that prevent incidents before enforcement becomes necessary.
Whether that ultimately changes how contractors experience OSHA remains to be seen.
But it was clearly part of the direction he described.
4. Modernization Has Become a Priority
One of the most practical discussions occurred during the question-and-answer session.
Audience members asked about outdated OSHA standards and the growing disconnect between regulations written decades ago and today’s construction technology.
Keeling acknowledged that challenge directly.
He explained OSHA is actively reviewing regulations for opportunities to modernize existing requirements rather than simply creating new ones.
Lockout/tagout was one example he discussed.
More importantly, he encouraged safety professionals to submit Letters of Interpretation whenever existing regulations create uncertainty or no longer reflect modern work practices.
That recommendation stood out because it gives safety professionals something tangible they can do immediately.
Rather than waiting years for formal rulemaking, employers, manufacturers, consultants, and industry organizations can identify areas requiring clarification and submit those concerns directly to OSHA.
If enough professionals raise similar issues, those requests can help identify where existing regulations no longer match today’s workplace.
5. OSHA Can’t Improve Workplace Safety Alone
Perhaps the biggest message woven throughout the presentation was that OSHA cannot accomplish its mission by itself.
Keeling repeatedly encouraged attendees to become active participants rather than passive observers.
He asked employers to identify outdated regulations.
He encouraged participation in new initiatives.
He discussed helping smaller contractors that lack dedicated safety resources.
He invited safety professionals to communicate directly with OSHA.
He emphasized that the agency needs help from industry.
One comment particularly resonated with me.
Early in the presentation, he reminded the audience that safety professionals rarely know every life they’ve helped protect.
As he explained, “You’ll never know the people that you saved.”
That’s true.
Most successful safety work is invisible.
The incident that never occurred.
The fall that never happened.
The family that never received a devastating phone call.
Those successes rarely make headlines, but they’re the reason this profession exists.
My Perspective
I’ve attended safety conferences for many years.
Some presentations focus heavily on regulations.
Others focus on technology.
Others introduce new products or compliance initiatives.
This presentation felt different.
It focused on direction.
Keeling repeatedly spoke about education, communication, partnership, leadership, modernization, and helping employers improve rather than relying exclusively on enforcement.
That doesn’t mean OSHA is becoming less of an enforcement agency.
He made it very clear that enforcement remains part of OSHA’s responsibility.
Instead, I interpreted his message as recognizing that inspections alone cannot create great safety cultures.
I agree with that.
No inspection has ever created an outstanding supervisor.
No citation has ever developed leadership.
No regulation has ever replaced a company culture where supervisors genuinely care about their people and employees take pride in doing quality work.
Those things are developed long before OSHA ever arrives on a project.
Where This Aligns With My Own Philosophy
Readers of this website know I frequently write about workforce development.
Listening to Keeling today reinforced something I’ve believed for years.
Safety is not created by regulations alone.
Compliance establishes minimum expectations.
But sustainable safety performance is created by capable leaders, engaged employees, effective supervision, quality training, and organizations committed to developing their workforce.
That’s why I continue to believe:
Safety is the byproduct of workforce development.
Nothing Keeling said changed that belief.
If anything, portions of his presentation reinforced it.
When organizations invest in their people, safety improves naturally.
When organizations invest only in compliance, they often achieve compliance—and little else.
Final Thoughts
Conference presentations often generate excitement that fades within a few weeks.
Whether today’s discussion becomes something more will depend on what happens next.
Will OSHA continue modernizing outdated guidance?
Will collaboration with industry increase?
Will programs designed to support smaller contractors expand?
Will Letters of Interpretation become a more effective tool for clarifying standards?
Those questions will only be answered over time.
But one thing became clear during today’s presentation.
Assistant Secretary David Keeling wants OSHA to be viewed as more than an agency that writes citations.
He wants OSHA to be viewed as an organization committed to helping employers prevent injuries, modernize safety practices, and improve worker protection through multiple approaches—not enforcement alone.
Whether every aspect of that vision becomes reality remains to be seen.
But it was an encouraging conversation and one worth following as OSHA continues to define its direction in the years ahead.
