WHAT’S AHEAD IN 2026
KEY ENVIRONMENTAL, HEALTH & SAFETY TRENDS TO WATCH

The start of a new year is always a good opportunity for reflection, both on the past and on what to look forward to in the year ahead.  Here at STP, our team of regulatory experts is always keeping close tabs on the pulse of environmental, health, safety and sustainability regulations. We cast a wide view to sift through the day-to-day noise and pick out the trends we believe will have lasting impacts for our clients.  In this article, our team identifies five topics that we believe will be front of mind for EHS leaders in 2026 and beyond. 

Continued Deregulation from U.S. Federal Agencies, Countered by More State-Led Actions

In 2025, we reported on several proposals to cut back or repeal regulatory programs by the U.S. Environmental Protection Agency (EPA) and Occupational Health Administration (OSHA). In particular,   OSHA proposed to revise or repeal 25 standards in August and the EPA  proposed significant cut backs to the Mandatory Greenhouse Gas Reporting Rule  in September.  On the environmental side, perhaps the most significant deregulation proposal is to repeal the “Endangerment Finding” which is the legal basis for EPA’s authority to regulate greenhouse gas emissions and climate change adaptation.  Other priorities include rolling back vehicle emissions standards starting with 2027 model years.  On  the safety side, OSHA’s

proposal to restrict the applicability of the General Duty Clause from  inherently risky professional activities” got a lot of attention because of its broad wording.  Assuming the administration continues to follow through with its deregulatory agenda, EHS leaders should expect EPA and OSHA to finalize these proposals in 2026. 

As anticipated, many states have been more proactive in adopting state-specific regulations to counter the federal trend, resulting in more state-to-state variation.  Recent examples from last year include  California extending its cap-and-trade program and  New York finalizing its mandatory greenhouse gas reporting regulations.  EHS leaders should closely follow regulatory developments in the states where they have operations and be prepared for more state-level actions. 

Limited Global Response to U.S. GHG Deregulation

Modifications to the stringency of global greenhouse gas (GHG) and sustainability regulations in response to U.S. deregulation throughout 2025 appear to be limited, with most major economies continuing to advance stricter GHG targets.  

Commitments and Shifting Foci

The  New Climate Institute reported in November 2025 that, as of October, 14 of the 25 countries analyzed have submitted or announced a 2035 Nationally Determined Contribution (NDC) target to reduce GHG emissions as part of the UN Paris Agreement; projections remain on a downward trend, despite the withdrawal of the U.S from the Agreement. 

Although off track with its NDC target,  Canada has reaffirmed its commitment to reducing GHG emissions, notably by announcing the finalization of the new Enhanced Methane Regulations for the oil and gas sector and Landfill Methane Regulations in December 2025. Earlier Canadian actions refocused pollution pricing on industrial carbon pricing by effectively eliminating the fuel charge for consumers and businesses  on April 1, 2025, following the issuance of the federal  Regulations Amending Schedule 2 to the Greenhouse Gas Pollution Pricing Act and the

OSHA’s Hazard Communication Standard (HCS) update became effective July 19, 2024, bringing many substantive changes yet leaving HCS’ structure unchanged. OSHA expects it to reduce incidents with a minimal learning curve for downstream users because the look and feel of safety data sheets (SDS) and most labels remain unchanged, but they will have better hazard classifications (the changes to Appendices A and B convey potential health and physical hazard risks more clearly to users). Other factors, such as a long compliance lead time, should keep training and other costs associated with the HCS update minimal for most employers. Hazardous communications and training programs, for which OSHA states in the final rule’s preamble it will publish related guidance documents, must be updated by July 19, 2026, with an additional eighteen-month allowance for mixtures.

Chemical manufacturers, distributors, and importers have until January 19, 2026, and July 19, 2027 (for substances and mixtures, respectively) to issue labels and SDS that reflect the new HCS requirements. Such companies are most impacted by the HCS update, but some of its changes should lower costs. For example, a clarifying revision to  1910.1200(d) now explains that manufacturers shall consider their customers’ “reasonably anticipated uses or applications” in assigning hazard classifications. However, another change refers to that same provision to grant relief from the label update requirement. Now, shipped containers with long supply chains are not required to retain their original labeling if paragraph (d) uses or applications change. Also, trade secrets provisions for chemical mixtures now conform to the Canadian standard, requiring less detail, and allowing the same SDS to be used by Canadian and U.S. workers alike.

Another area of cost savings comes from aligning with seventh revision (Rev. 7) of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Now HCS is aligned with other U.S. agencies and international trading partners such as Canada and the EU, which have all adopted Rev. 7. All told, this harmonization, conservation of basic HCS framework, and making HCS documentation more efficient have led OSHA to project that the implementation of the new HCS will result in national annual cost savings of $30M.

Fuel  Charge Regulations: SOR/2025-107 and their companion   Regulations Amending the Output-Based Pricing System Regulations: SOR/2025-108, which amended the  system to ensure the on-site transportation emissions of facilities covered under the Regulations remain subject to carbon pollution pricing. 

In the European Union (EU), while the  Council of the EU agreed in November 2025 and remains largely on track with its NDC target, recently approved amendments in the  Omnibus I Directive on December 22, 2025, relax climate reporting and other requirements for many businesses. This Directive amends the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CS3D). Once in effect, the revised CSRD and CS3D will apply only to EU companies that meet specific criteria, including those with more than 1,000 employees and a net turnover exceeding €450 million for the CSRD and more than 5,000 employees, and a net turnover exceeding €1.5 billion for the CS3D. 

In conclusion, despite the U.S.’s 2025 withdrawal from its commitments, stakeholders must remain vigilant, as climate-related regulatory actions continue worldwide. STP reported national legislation in 2025 by Australia, Belgium, Canada, Switzerland, the Czech Republic, the EU , IndiaJapan, South Korea, the Netherlands, Norway, New Zealand, the UK, and Vietnam, among other state and provincial jurisdictions.   

OSHA Proposal Expands Regulatory Focus on Heat Injury and Illness

Heat injury and illness prevention has been a major regulatory trend in the United States throughout 2024. Longer periods of hotter, drier weather are fueling the focus on mitigating the effects of workplace exposure to heat in both indoor and outdoor workplaces.  Most recently, on August 30, 2024, the United States  Occupational Safety and Health Administration (OSHA) issued a proposed rule establishing a nation-wide health and safety standard to address safety risks from heat.  OSHA’s proposed rule follows a state-level trend dating back to 2006, when California adopted the first dedicated heat safety standard.  The California standard is applied to outdoor workplaces exclusively, with a focus on agricultural, construction and seasonal workers exposed to high outdoor temperatures.  Since then, five other states have adopted heat safety standards (Minnesota, Colorado, Washington, Oregon, and Maryland), and California has expanded the scope of its regulation to cover indoor workplaces.  The most recent state-level developments are from Maryland (September 2024 at COMAR 09.12.32) and California (June 2024 at 8 CCR 3396).   The state regulations and federal proposal share several common themes, particularly threshold heat conditions that trigger employers to take additional remedial actions and establish a heat illness prevention and management plan. The proposed federal standard is notable because it is relatively rare for OSHA to develop a completely new safety standard that will apply to employers across industry sectors nationwide.  OSHA is collecting public comments on the proposal through December 30, 2024.

Canada’s Approach to Reducing ‘Red Tape’

Canada is pursuing red tape reduction commitments to modernize its regulatory systems by eliminating unnecessary, duplicative, or outdated administrative requirements. The objective is to strengthen economic competitiveness, encourage innovation and investment, and enable governments to focus regulatory effort on measures that most effectively protect health, safety, and the environment. 

In July 2025, the Government of Canada launched a comprehensive Red Tape Review of regulations across federal departments and agencies with regulatory responsibilities. As part of this initiative, and in collaboration with provinces and territories, Employment and Social Development Canada’s Labour Program has proposed three regulatory initiatives under the Canadian Free Trade Agreement to support occupational health and safety (OHS) harmonization and modernize workplace safety practices. These initiatives include aligning federal first aid kit requirements with the CSA Z1220 standard used by provinces and territories, updating personal protective equipment requirements to address inconsistencies across federal OHS regulations and ensure proper fit for diverse workers, and modernizing requirements related to  levels of sound by reflecting current best practices in noise control and hearing loss prevention while eliminating unnecessary reporting obligations. The Labour Program is

Effective July 1, 2024, California’s Department of Toxic Substances Control (DTSC)  adopted the federal EPA’s Generator Improvements Rule (GIR), in the first of two rulemaking packages. The changes significantly amend, recodify, and restructure rules applicable to small quantity generators, very small quantity generators, and large quantity generators in relation to acute hazardous waste, extremely acute hazardous waste, and non–acute hazardous waste.

The provisions DTSC included in this first rulemaking package are all more stringent than the provisions they replace, which made their adoption by the Department mandatory. These include 1) a new generator re-notification requirement, 2) new marking and labeling requirements for containers and tanks, 3) new requirements for closures and satellite accumulation areas, and 4) new spill procedure-related requirements for small and large quantity generators. The new structure now mirrors the federal rule for better comprehension.

targeting final regulatory changes by fall 2026, with proposed amendments expected to be released before spring 2026. 

Environment and Climate Change Canada (ECCC) is also advancing a range of red tape reduction initiatives, as outlined in its  Red Tape Reduction Plan and Progress Report 2025. Recent examples include amendments to the PCB Regulations , the repeal and replacement of the Prohibition of Certain Toxic Substances Regulations, and amendments to the  Multi-Sector Air Pollutants Regulations. Looking ahead, ECCC is exploring further initiatives, such as reducing administrative burdens under the  Environmental Emergency Regulations, 2019, and reviewing the New Substances Notification Regulations , both (Organisms) and (Chemicals and Polymers), in coordination with Health Canada to improve efficiency, flexibility, and clarity for industry. 

At the provincial level, similar efforts are expected to continue in 2026 and beyond. Ontario has recently enacted the Protect Ontario by Unleashing Our Economy Act, 2025  and the Building a More Competitive Economy Act, 2025, which amend multiple environmental statutes, signalling further regulatory change. Ontario and Canada have also committed to streamlining environmental assessment processes for major projects through a  new cooperation agreement, reinforcing the broader trend toward coordinated red tape reduction across jurisdictions. 

Consolidation of ESG Reporting Frameworks

Several leading ESG reporting framework organizations have indicated plans to further consolidate and align their frameworks to address concerns from the business community about complexity and overlapping reporting requirements.  Throughout 2025, framework organizations have issued several mapping tables and announcements about “interoperability” between the various reporting standards.  The pull back of ESG reporting requirements under the EU’s Omnibus package highlights some push back from the business community, asserting that the pace and complexity of ESG reporting requirements are overwhelming and businesses are looking for some relief.  There appears to be a strong desire for simplification and consistency, especially as a  growing number of jurisdictions adopt ESG reporting standards as law.  The concept of “passporting” has taken hold, where jurisdictions will accept reports prepared in accordance with International Sustainability Standards Board (ISSB)standards that account for jurisdiction- specific differences.   

Two examples highlight this trend.  Recent announcements from the Taskforce on Nature-Related Financial Disclosures (TNFD) and the ISSB mention that the ISSB will proceed with the development of nature-related disclosure standards consistent with the TNFD  recommendations.  As a result, TNFD plans to complete all technical work in progress and pause the commencement of any further work to focus additional technical efforts on supporting the ISSB’s work. If and when ISSB finalizes the nature disclosure standards, TNFD may disband its technical work program. The International Standards Organization (ISO) and the Greenhouse Gas (GHG) Protocol announced a collaboration to issue a unified global GHG emissions accountingstandard. Under the agreement, ISO and GHG Protocol will combine their leading GHG standards into harmonized co-branded international standards. For those who have been following the emergence of ESG reporting standards for some time, the pace of change to the “alphabet soup” of reporting frameworks has slowed down compared to earlier years, but ESG leaders can expect a push for more consolidation in the coming year.   

New ISO 14001:2026 – Environmental Management Systems Standard Coming in April

Climate change, biodiversity loss, and evolving ESG expectations have significantly reshaped the environmental management and business landscape. As a result, ISO 14001 is being updated to ensure it remains relevant and continues to provide effective guidance to organizations navigating these emerging challenges. 

On January 5, the Final Draft International Standard for ISO 14001 was released for an eight-week review and comment period, with final publication currently expected in April 2026. While the transition period is still under discussion, if a three-year transition is confirmed, all certifications issued to ISO 14001:2015 will need to be transitioned to the new edition by May 2029 to remain valid. 

The anticipated ISO 14001:2026 revisions include editorial updates and improved terminology to enhance clarity, readability, and alignment with other management system standards, along with an expansion of several existing concepts. Key expected changes include: 

  • Enhanced requirements to help organizations consider how environmental conditions—such as pollution levels, natural resource availability, climate change, and biodiversity—affect their operations and how their activities impact the environment; 
  • A strengthened expectation to consider a life cycle perspective when determining the scope of the environmental management system (EMS); 
  • A requirement to manage changes that affect, or could affect, the EMS in a planned and systematic manner, whether arising from internal or external sources; 
  • Revisions for controlling or influencing externally provided processes, products, or services relevant to the EMS; and 
  • A requirement to define audit objectives for each internal audit. 

An effective EMS fosters a culture of environmental stewardship and serves as a critical pillar for organizations addressing climate-related risks and advancing sustainable development. ISO 14001, together with complementary climate-related standards such as ISO 14064-1:2018 (Greenhouse Gases), ISO 14090:2019 (Adaptation to Climate Change), IWA


42:2022 (Net Zero Guidelines), and ISO 50001 (Energy Management), provides essential implementation tools for achieving aligned, credible, and measurable climate action. 

In a related update, a review of ISO 45001:2018 – Occupational Health and Safety Management System has been initiated, but a published version is not expected until 2027. 

Spotlight on Workplace Violence and Worker Well-being Continues to Shine

  • STP has been tracking a regulatory trend addressing workplace violence and overall worker well-being throughout the past year, and we expect this momentum to continue through 2026 and beyond.  The principle that workers who have better mental health and well-being in and outside the workplace leads to fewer accidents and better performance has taken hold, and regulators continue to adopt policies and programs aimed at protecting workers’ well-being.  In the past quarter, STP has  tracked 23 regulatory updates across the countries we monitor.  15 of the


updates were finalized in the last quarter of 2025, which means new requirements to be implemented in the new year.  The remaining eight updates are in a proposed status, with final adoption planned in 2026.  Globally, countries such as Canada, Chile, India, Italy, Saudi Arabia, and the United States have been active.  Notably, Saudi Arabia passed a comprehensive framework for evaluating employees’ physical and mental fitness to ensure safe and efficient job performance with aim to reduce workplace injuries and illnesses and promote employee well-being.  In Canada, the Ontario Legislature proposed updates to its Occupational Health and Safety Act to require employers to address workplace sexual violence and to require workplace sexual harassment training for all workers.