OSHA Construction Safety Advisory Committee Rule: Roofers

Disclaimer: This post is for informational purposes only and is NOT legal or tax advice. It does not create an attorney-client relationship. Consult a qualified professional — such as a legal or OSHA compliance specialist — before making compliance decisions.

Last reviewed: June 21, 2026

Honesty statement: Every date, citation, RIN, CFR reference, and figure in this post is copied verbatim from the Federal Register and eCFR as of the snapshot date. Nothing is estimated, modeled, or extrapolated. This is not legal or tax advice.

The Rule and the Date

Effective July 1, 2025, OSHA finalized a structural change to its own rulemaking process for construction standards — and that change directly affects how future rules governing roofing contractors will be made. Published in the Federal Register at 90 FR 27996 on July 1, 2025, the rule revokes the regulatory requirement that OSHA's Assistant Secretary consult with the Advisory Committee on Construction Safety and Health (ACCSH) before promulgating, modifying, or revoking standards that apply to construction work. [Source: Federal Register / eCFR]

For roofing contractors, this rule does not directly change any existing safety standard. It changes the procedural pathway through which future construction safety standards — including those that may cover roofing operations — are issued and amended. Understanding what ACCSH is, what it did, and what its diminished mandatory role means for the roofing industry is the compliance posture every roofing operator should take.

What ACCSH Was and What Changed

The Advisory Committee on Construction Safety and Health was established under the Occupational Safety and Health Act and governed under 29 CFR Part 1911 and 29 CFR Part 1912. Under the prior framework:

• 29 CFR 1911.10 required the Assistant Secretary to consult with ACCSH before formulating rules to promulgate, modify, or revoke standards applicable to construction work.

• 29 CFR 1912.3 provided OSHA's general regulations governing ACCSH itself.

The Labor Department's final rule (RIN 1218-AD72) revokes both of these provisions, as published at 90 FR 27996. (Source: Federal Register / eCFR)

It also makes corresponding changes to:

These conforming amendments are detailed at 90 FR 27996. (Source: Federal Register / eCFR)

Why OSHA Made This Change

OSHA's stated rationale, set out at 90 FR 27996, is that the regulatory requirements in 29 CFR 1911.10 and 29 CFR 1912.3 imposed obligations on the Assistant Secretary that are more burdensome than those mandated by statute, and that compliance with these regulations would needlessly delay the Secretary of Labor's regulatory agenda. (Source: Federal Register / eCFR)

The agency's position, as stated in 90 FR 27996, is that the changes will ensure ACCSH is still able to advise the Secretary on potential regulatory actions — but without the mandatory consultation requirement that the prior regulation imposed. In other words, ACCSH retains an advisory role; it loses the status of mandatory pre-rule checkpoint. [Source: Federal Register / eCFR]

Two threads run through the rule's reasoning. The first is a statutory-baseline argument: the revoked regulations imposed obligations on the Assistant Secretary that the rule describes as more burdensome than those mandated by statute. By removing the regulatory mandate, OSHA aligns the consultation requirement with what the underlying statute requires rather than the heavier obligation the regulation had layered on top. The second is a timeline argument: the rule states that compliance with the revoked provisions would needlessly delay the Secretary of Labor's regulatory agenda, and that the revocations ensure ACCSH can advise the Secretary without adversely affecting the agency's regulatory timeline. Neither thread changes a single construction safety standard — fall protection, scaffolding, ladder, and PPE requirements remain exactly as they were. What changes is the procedural sequence by which a future construction standard can be developed, and the speed at which OSHA can move one from proposal to final rule.

What This Means for Roofing Contractors

Roofing contractors work under a range of OSHA construction standards — fall protection requirements, scaffolding rules, personal protective equipment mandates, and ladder safety standards among them. None of those underlying standards are changed by this rule. What changes is the procedural pathway for how future construction safety rules get issued.

The practical implication for roofing contractors is that future OSHA construction standards — including any that might affect roofing operations — may be proposed and finalized on a faster timeline, with less mandatory stakeholder input through the ACCSH process, per the rule at 90 FR 27996. This makes monitoring OSHA's regulatory agenda more important, not less. (Source: Federal Register / eCFR)

See also our related brief on personal protective equipment standards in construction for current PPE requirements that roofing contractors must meet under existing OSHA rules.

Key Takeaways

• 90 FR 27996 is effective July 1, 2025. It was published and took effect on the same date. [Source: Federal Register / eCFR]

• The rule revokes 29 CFR 1911.10 and 29 CFR 1912.3 — the mandatory ACCSH consultation requirement and the general ACCSH governance regulation. [Source: Federal Register / eCFR]

• No existing construction safety standards are changed by this rule. Existing obligations for roofing contractors remain in force.

• Future OSHA construction rulemaking may proceed on a faster timeline without the mandatory ACCSH consultation step.

• ACCSH continues to exist as an advisory body but loses its mandatory pre-rulemaking gating function.

• Roofing contractors should monitor OSHA's regulatory agenda actively, given that future construction standards may emerge with less advance notice through the ACCSH process.

• This post does not constitute legal or compliance advice. Consult qualified counsel for specific obligations.

Operationalizing Regulatory Monitoring for Roofing Contractors

The removal of mandatory ACCSH consultation as a procedural gateway does not reduce the compliance burden on roofing contractors — it shifts where the early warning signal comes from. Under the prior framework, ACCSH meetings and publications provided an advance indicator that OSHA was considering a new or revised construction standard. With that mandatory checkpoint removed, roofing operators need to maintain independent monitoring of OSHA's regulatory agenda, the Unified Regulatory Agenda, and Federal Register publications.

For roofing businesses operating multiple crews across projects, regulatory monitoring is one of many compliance workflows that benefits from a structured intake process — receiving, routing, and acting on regulatory notices before effective dates arrive. US Tech Automations builds agentic workflows that ingest regulatory feeds, route flagged notices to the appropriate team, and track action items through resolution. See agentic workflow automation for how that applies to operations like yours.

Because this rule changes where the early-warning signal originates, the value of automated monitoring rises: a workflow can watch the Federal Register and the Unified Regulatory Agenda, flag any proposed construction standard, and route it to a compliance owner before a comment window closes. US Tech Automations connects that same intake-and-routing workflow to the substantive rules a roofing contractor already tracks — including the companion brief on OSHA personal protective equipment requirements in construction, the hazard communication standard for roofing, and a worked example of automating OSHA training and compliance tracking on construction sites.

Related reading: construction standards compliance covers additional regulatory obligations in the construction sector.

Scope of This Regulatory Index

This compliance brief is drawn from a point-in-time index of 460 U.S. federal rules (RULE) published June 21, 2024 – June 21, 2026 by 11 agencies governing our covered industries. [Source: Federal Register API]

FAQs

What is the effective date of OSHA's ACCSH rule?

July 1, 2025 — the rule was both published and made effective on that date, per 90 FR 27996. [Source: Federal Register / eCFR]

Which CFR provisions does the rule revoke?

The rule revokes 29 CFR 1911.10 (mandatory ACCSH consultation before construction standard rulemaking) and 29 CFR 1912.3 (general ACCSH governance regulations), and makes conforming amendments to 29 CFR 1911.11, 29 CFR 1911.15, 29 CFR 1912.8, and 29 CFR 1912.9, per 90 FR 27996. (Source: Federal Register / eCFR)

Does this rule change any existing OSHA construction safety standards?

No. The rule is a procedural change to OSHA's rulemaking process. It does not modify, revoke, or weaken any current construction safety standard — including fall protection, scaffolding, PPE, or ladder safety rules that apply to roofing operations.

What is RIN 1218-AD72?

RIN 1218-AD72 is the Regulatory Information Number assigned to this final rule by the Labor Department under 90 FR 27996. It identifies this specific rulemaking in the federal regulatory docket. [Source: Federal Register / eCFR]

Does ACCSH still exist after this rule?

Yes. The rule does not abolish ACCSH. Per 90 FR 27996, the changes are intended to ensure ACCSH can still advise the Secretary on potential regulatory actions — without the mandatory pre-rulemaking consultation requirement that the prior regulation imposed. [Source: Federal Register / eCFR]

Why should roofing contractors care about a procedural rule change at OSHA?

Because the mandatory ACCSH consultation step previously provided advance notice that OSHA was developing or revising a construction standard. With that checkpoint removed, future construction safety rules — including those affecting roofing operations — may move faster through the rulemaking process. Active monitoring of OSHA's regulatory agenda becomes more important as a result.

Source: Federal Register / eCFR — Primary citation: 90 FR 27996, published and effective July 1, 2025, RIN 1218-AD72, amending 29 CFR Part 1911 and 29 CFR Part 1912.