On January 20, 2026, the Occupational Safety and Health Administration (OSHA) launched the Safety Champions Program (the “Program”), a new voluntary cooperative program designed to help employers develop and implement safety and health programs. The Program reflects OSHA’s stated effort to take a more collaborative approach to workplace safety, moving beyond purely enforcement-driven engagement with employers. The Program is distinct from OSHA’s existing Voluntary Protection Program (VPP) and, with careful consideration, may present an opportunity for employers to strengthen their safety and health practices with assistance from OSHA.
Key takeaway
The Program provides a progressive, step-based framework for employers to build or improve their workplace safety and health programs around seven core elements identified in OSHA’s Recommended Practices for Safety and Health Programs. Employers may participate independently or request support from OSHA-assigned Special Government Employees (SGEs) who can review program documentation, provide feedback, and answer questions. Even employers who believe they already have strong safety programs may benefit from using the program framework as an internal audit tool to evaluate existing safety and health procedures against OSHA’s recommended practices. Participation has no impact on any OSHA enforcement activity or determination.
The Safety Champions Program Structure
The Program features three progressive steps: Introductory, Intermediate, and Advanced, each building on the prior step. At each step, employers are expected to achieve specific goals and complete defined actions across seven elements OSHA believes are critical to a successful safety and health culture: (1) management leadership; (2) worker participation; (3) hazard identification and assessment; (4) hazard prevention and control; (5) education and training; (6) program evaluation and improvement; and (7) communication and coordination for host employers, contractors, and staffing agencies. Participants use a Safety Champions Tracker to monitor their progress through each Step. Notably, participants must continue meeting criteria from previously completed Steps as they progress through the program.
Below is a summary of what OSHA expects employers to accomplish during each step in the program.
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Introductory step – Employers focus on foundational actions like developing written safety and health policies, establishing safety committees, creating initial hazard inventories, and building training plans.
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Intermediate step – Employers implement the programs developed in the Introductory step, increase worker involvement, conduct regular hazard inspections at least semi-annually, and provide refresher training.
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Advanced step – Employers are expected to demonstrate mature, fully integrated safety and health programs with continuous improvement processes, routine self-inspections at least monthly, and annual trend analyses of safety and health data.
Role of Special Government Employees
Participants can work through the program independently or with the assistance of an SGE assigned by OSHA. SGEs may review safety and health program documentation, provide feedback on progress, and answer questions on an as-needed basis. When a participant believes it has completed all actions within a step, OSHA will assign an SGE to conduct a formal review. The SGE may then recommend the participant for step completion or identify areas where further progress is needed.
Implications for Employers
Though employers may view the Program with a healthy dose of skepticism, the Program represents a shift in OSHA’s posture toward employer engagement. Employers should consider whether participation, or even informal use of the Program framework as a self-assessment benchmark, could help improve their safety and health program performance and compliance posture. The structured, step-based approach may be particularly useful for organizations looking to formalize safety practices, engage workers in safety initiatives, and build a documented track record of continuous improvement. Also, because of the Program’s step-by-step approach, employers should participate in the Program only if they are focused on continuous improvement of their safety and health programs.
The Program operates separately from OSHA’s enforcement activities, and OSHA has made clear that participation has no impact on any enforcement activity or determination. Though a strong safety program may reduce the risk of workplace incidents that may trigger an inspection, employers should not participate in the Program with the expectation that it will shield the employer from an OSHA inspection or citations.
Additional resources on the Safety Champions Program are available on OSHA’s dedicated webpage.
This article was co-authored by Reed Smith partner, Adam Roseman.
