OSHA Issues Final Walkaround Rule Allowing Non-Employee Representatives to Accompany Compliance Officers

OSHA published its final rule on the worker walkaround representative designation process on April 1, with an effective date of May 31. The rule allows third parties, including unions and community activists, to accompany OSHA inspectors on facility inspections, even in non-unionized workplaces. Along with the final rule, OSHA has published a Frequently Asked Questions guidance document about the rule that is available here.

The American Foundry Society joined in on coalition comments underscoring key concerns with the rule that were not addressed such as infringing on employers’ property rights, inviting new liabilities, and potentially compromising proprietary information. While the final rule is largely the same as the proposal, there are small changes that broaden who can qualify as an authorized representative. Multiple parties in the business community are considering legal action to challenge the rule which AFS will be actively engaged in. In addition, AFS has met with OSHA officials and congressional staff on the rulemaking. AFS plans to host a webinar the first week of May to provide an overview of the rule and steps to prepare for it if the rule ultimately takes effect.


As part of the wave of regulations hitting manufacturers in the final year of the Biden administration, we anticipate that rules expanding overtime pay and addressing crystalline silica exposure in the mining sector, including sand companies, will be finalized in the weeks ahead.


The American Foundry Society is a dynamic technical and advocacy organization that serves and represents the $50 billion metalcasting industry. AFS is the only association serving the entire industry, including all metals and processes, with a three-part focus on advocacy, education, and innovation. AFS also publishes Modern Casting and Casting Source magazines and presents Metalcasting Congress and CastExpo, the largest metalcasting trade events in North America. Founded in 1896, the organization is based in Schaumburg, Illinois, with an advocacy office in Washington, D.C. More information is available at