Nov 14, 2025· Comment from Sloan, Lawrence; American Industrial Hygiene Association (AIHA)· OSHA-2025-0040-0025
Removing numeric benchmarks for construction lighting may lead to inconsistent illumination - particularly at night or in enclosed spaces - thereby increasing the risk of slips, trips, falls, and struck-by incidents. To mitigate these foreseeable hazards, AIHA recommends that OSHA: Adopt a performance-based requirement that includes minimum numeric lighting thresholds by task and setting, and illustrative examples aligned with current consensus standards (aligned with current IES recommendations) and require job hazard analyses for atypical work environments. If the numeric benchmarks are rescinded, issue a directive or FAQ that provides reference values for minimum lighting levels (in lux or foot-candles) by task type and work setting.