CSHEMA - Campus Safety, Health, and Environmental Management Association

CSHEMA Seeks Clarity from OSHA on General Duty Clause Proposal

November 6, 2025—The Campus Safety, Health, and Environmental Management Association (CSHEMA), representing more than 400 higher education institutions, has submitted comments in response to OSHA's proposed rule, "Occupational Safety and Health Standards: Interpretation of the General Duty Clause: Limitation for Inherently Risky Professional Activities" (Docket No. OSHA-2025-0041).

OSHA's proposal would limit enforcement of workplace hazards that are considered inherent and inseparable from professional or performance-based activities. CSHEMA is concerned that unclear terms such as "inherently risky employment activities" and "integral to the essential function" could lead to broader future interpretations of the rule and create regulatory uncertainty for colleges and universities.

CSHEMA urges OSHA to provide clear definitions and detailed guidance in the final rule so academic institutions can accurately assess their safety obligations while protecting students, faculty, and staff.