Every year, we see a number of environmental, health, and safety (EHS) trends rise to the surface that have the potential to impact many industries. As we enter 2025, some challenges and opportunities in EHS remain ongoing; some are just gaining traction with impacts yet to be known, particularly with a change in Administration just taking hold. Here are some of the top EHS trends KTL is keeping watch on in 2025…

Regulatory Landscape

In 2022, the Environmental Protection Agency (EPA) published its FY 2022-2026 EPA Strategic Plan to communicate the Agency’s vision, priorities, and strategies. Specifically, the Plan includes targeted objectives and outcomes in the areas of climate change; environmental justice; compliance enforcement; clean land, air, and water; and chemical safety. The Occupational Safety and Health Administration’s (OSHA’s) focus centers on National Emphasis Programs (NEPs) for 2025 related to combustible dust, fall protection/prevention, heat, silica crystalline, and warehousing and distribution center operations, as well as many regional directives.

With a new Administration taking office in January, a big unknown of the coming four years is how the EHS regulatory landscape will change. There is speculation regarding plans to reorganize the EPA and establish “pause and review” teams to assess major rules, guidance materials, grants, legal settlements, budgets, etc. How this will translate into regulatory action remains to be seen.

Mental Health

Companies are increasingly recognizing that traditional safety programs must evolve to prioritize mental health as much as physical health—from mental health days to employee assistance programs, to stress management training, to flexible work hours. Correspondingly, psychological safety is becoming a critical concept for building effective teams and encouraging workplace innovation and success. A psychologically safe culture allows employees to take reasonable risks in a safe environment without negative interpersonal consequences.

A related concept is safety culture, which is concerned with many cognitive aspects of safety, like norms, perceptions, beliefs, and values. Emphasizing mental health as part of the organization’s safety culture may become a priority for mature organizations. As the concept of total worker health continues to expand, the focus on mental health is also likely to be reinforced by new regulations and standards regarding psychological safety in the workplace.

Sustainability and Climate Change

Environmental, Social, and Governance (ESG) initiatives have dominated many corporate agendas for the past several years, particularly with Europe and Canada advancing standards related to sustainability and climate change data reporting and ISO’s recent Climate Change Amendments. Many organizations have worked to significantly improve their data collection efforts and have integrated climate change management and circular economy principles into their sustainability strategies.

The change in Administration may increase scrutiny regarding the value of these ESG initiatives. We have already seen the Securities and Exchange Commission’s (SEC) March 2024 Climate-Related Disclosures Rule stayed due to multiple petitions and lawsuits. This may be a sign of things to come. Many companies have invested in their ESG efforts and will continue to do so, but 2025 may present an opportunity to reassess and streamline initiatives to ensure they are practical and upholding sustainability goals, while also contributing value to the company.

PFAS

Per- and polyfluoroalkyl substances (PFAS) became a focal point for EPA in 2021 with the publication of its PFAS Strategic Roadmap, which committed to addressing concerns related to PFAS exposure. Actions have included improving reporting on PFAS, as well as adding seven additional PFAS to the Toxics Release Inventory (TRI) in January 2024 and an additional nine in January 2025. In April 2024, EPA announced three more notable actions, including introducing the first-ever national drinking water standards and designating perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) as “hazardous substances” under Superfund. In addition, the updated Interim Guidance on the Destruction and Disposal of PFAS and Materials Containing PFAS will require entities to report releases of these “forever pollutants” that exceed threshold quantities. 

Beyond federal regulations, many states are introducing policies related to PFAS, including monitoring and testing for PFAS in water and sewage sludge and banning PFAS in food packaging, clothing, and other consumer products. Organizations need to address PFAS in their operations, products, supply chains, and waste streams; stay informed about ongoing PFAS regulatory developments; and adjust compliance programs and operational practices, as needed.

Personal Protective Equipment (PPE)

Properly fitting PPE is essential for workers to complete their tasks safely. If PPE is not correctly fitted to the body, it can cause discomfort and increase the risk of workplace accidents and injuries. On December 11, 2024, the Occupational Safety and Health Administration (OSHA) announced its finalized revision to the PPE Standard for Construction, which requires PPE to properly fit any construction worker who needs it, including women and physically smaller or larger workers.

Employers must ensure that every employee not only has the right PPE, but that it also fits. Fit testing may identify the need for PPE alternatives to meet the anthropometric needs of all workers. Importantly, employees must be trained and empowered to speak up if PPE does not fit appropriately to ensure their safety.

Technology/AI

Artificial intelligence (AI) and machine learning technologies have the capacity to significantly alter how companies manage their EHS programs. While still not fully mature, these technologies are becoming more sophisticated. As AI evolves and becomes more generally accepted, more companies are likely to start adopting it to automate routine compliance tasks, conduct EHS assessments, perform training simulations, predict potential safety incidents, monitor workplace conditions in real-time, and more.

While the efficiencies and other benefits of technology solutions are many, the increased reliance on AI and machine learning will require increased oversight and management. In particular, companies will need to determine where automation is appropriate and where the human factor is still required. Not all processes lend themselves to AI. It will also be imperative to consider stronger data privacy protocols to ensure the security of the company.

Others to Watch

• OSHA Reporting: On January 1, 2024, the Department of Labor’s (DOL’s) final rule requiring employers in designated high-hazard industries to electronically submit injury and illness information to OSHA took effect. KTL inspections routinely find errors and omissions in OSHA recordkeeping. Effective solutions, particularly areas where hard copies can be replaced by digital forms, are needed.
• Hazard Communication Standard: The final Hazard Communication Standard took effect on July 19, 2024, implementing the first major updates since 2012. The first compliance date requires chemical manufacturers, importers, and distributors to update labels and Safety Data Sheets (SDSs) for chemical substances by July 19, 2026.
• Lead Levels: In January 2024, the EPA reduced the acceptable amount of lead in soil for residential exposure, stating that no level of lead is acceptable. These reduced levels may soon be translated into commercial exposures. 
• One Health: Both the Society of Environmental Toxicology and Chemistry (SETAC) and Society of Toxicology (SOT) have adopted One Health initiatives as an integrated, unifying approach that aims to sustainably balance and optimize the health of people, animals, and ecosystems (SOT). The idea is to look at the health of our environment and all aspects of our environment as a whole and not one component at a time. This idea is being translated into health impact assessments. 
• Pesticide/Herbicide Re-evaluation: The EPA has initiated re-evaluations of registered pesticides, herbicides, rodenticides, and fungicides, including the highly publicized Roundup. These reviews are expected to result in a recommendation to focus the use of these chemicals rather than using a general broadcast application. 
• Microplastics: Microplastics have been found in every ecosystem on the planet—in food, beverages, and human and animal tissue. Scientists do not fully understand the impacts of microplastics on human health and aquatic life, and industry is struggling with how to manage them due to their pervasive nature and wide variety of shapes and sizes. Ongoing research in pollution prevention will be forthcoming.

Getting Ahead in 2025

In 2025, organizations will continue to encounter evolving workplace challenges, regulatory adjustments, societal demands, economic pressures, and rapid advancements in technology—some of which can be anticipated, some which remain to be seen. KTL suggests completing the following early in 2025 to prepare for whatever is on the horizon:

• Get senior leadership commitment. Even with the best EHS personnel, the organization and its EHS system will only be as strong as the top leadership and what they prioritize.
• Stay abreast of regulatory developments. Monitor what is going on at the federal (i.e., EPA and OSHA) and state levels, assess your regulatory applicability, and evaluate how any potential regulatory changes over the next year(s) may impact your operations.
• Conduct a comprehensive gap assessment to ensure you are efficiently meeting your EHS requirements (i.e., regulatory, management systems, internal, supply chain). Think critically about how overlapping requirements may apply (e.g., your chemical inventory may uncover requirements for air permitting, waste management, Tier II report, etc.) and how you can integrate systems to improve efficiency and compliance.
• Determine where you can integrate technology solutions into your operations. This could mean stepping into the world of AI and machine learning; it could also mean implementing compliance information management systems to help manage compliance and reporting requirements. Technology advancements can help create significant business efficiencies when used appropriately.
• Seek third-party oversight. Many EHS departments are severely understaffed. Having external experts periodically look inside your company provides an objective view of operations, helps you to prepare for audits, and allows you to implement corrective/preventive actions that ensure compliance. An outside expert can often provide the “big picture” view of what you have vs. what you need; how your plans, programs, and requirements intersect; and how you can best comply with changing requirements.