It’s time to ask Chat GPT a hypothetical question concerning the fate of OSHA and the NRTLS they accredit in the United States.

OSHA (The Occupational Safety and Health Administration) is now potentially going to be dissolved this year should H.R.86, otherwise known as the NOSHA Act (introduced to Congress on 1/3/25) get sufficient support to pass.

To find out what potentially may happen to NRTLs should OSHA be dissolved as the agency tasked with accrediting them, the staff of Lewis Bass asked Chat GPT the following question verbatim concerning this potential outcome of having no more federal OSHA to steward worker safety in the United States:

Let’s say that OSHA is dissolved this year and no longer exists as a US government agency. What happens to all the NRTLs that were accredited by OSHA? Do NRTLs still exist if the agency that is tasked with periodically evaluating them for continued accreditation disappears?

What follows below is Chat GPT’s multi-tiered response to this hypothetical future without OSHA regulating and accrediting NRTLs.

Great question! If OSHA were to be dissolved, it would create a major regulatory vacuum, especially regarding the Nationally Recognized Testing Laboratories (NRTLs). Here’s what would likely happen:

1. Existing NRTLs Would Be in Limbo (At Least Temporarily)

OSHA is the only entity responsible for accrediting and overseeing NRTLs under 29 CFR 1910.7. If OSHA ceased to exist, its accreditation framework would technically vanish along with it. That means:

• NRTLs would no longer have an officially recognized status under federal law.
• Employers might struggle to determine if previously OSHA-approved NRTLs still hold any authority.
• A legal gray area would emerge regarding whether products previously certified by NRTLs would remain compliant with existing workplace safety laws.

2. Other Regulatory Bodies Might Step In

While OSHA is the primary authority in the U.S. for NRTL accreditation, other agencies and organizations rely on similar testing and certification frameworks. If OSHA were gone, a few possible outcomes could unfold:

• Another Federal Agency Takes Over: The Department of Labor (DOL) could create a new office to oversee NRTLs, or another agency like NIST (National Institute of Standards and Technology) or CPSC (Consumer Product Safety Commission) might absorb the function.

• State-Level Oversight Develops: Some states might set up their own accreditation programs or defer to international certification bodies.

• Private Accreditation Rises: Organizations like ANSI (American National Standards Institute) or IAS (International Accreditation Service) could take over aspects of the NRTL framework.

3. The Impact on Safety Standards

Even if OSHA disappeared, the NFPA, NEC, and ANSI standards wouldn’t disappear—they are independent organizations that develop safety standards. However, enforcement of those standards could become chaotic, as OSHA is a major enforcement mechanism. If no replacement is created, manufacturers and businesses might still rely on NRTLs voluntarily, but without legal backing, compliance could become less uniform.

4. The Market Response

Given that OSHA accreditation gives NRTLs credibility, they would likely lobby for a new governing body to be established ASAP. Insurance companies, industry groups, and even multinational corporations that require safety certifications would push for some form of continuity—whether through a new federal agency, state-level requirements, or international certifications.

Bottom Line: NRTLs Might Survive, But in What Form?

NRTLs wouldn’t vanish overnight, but their legal status and authority would be thrown into question. Without a direct replacement for OSHA’s accreditation role, businesses might turn to alternative testing standards, industry-led certifications, or international accreditation bodies to fill the gap.

Now, what do you think? Would companies still voluntarily use NRTLs even without OSHA, or would things get messy fast?

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