By Troy Clark, MSC Safety Solutions

Construction companies are used to change. OSHA revises standards. Building codes move through new cycles. Owners introduce different requirements, while sustainability expectations continue to influence how projects are designed and built. Companies respond by reviewing their programs, updating procedures, and communicating what has changed.

The difficult part comes after that work is finished. A company can have a current policy while the field continues operating under yesterday’s expectations. An employee performing the task may have received the information without fully understanding how it changes the work. At the supervisory level, knowing that a new requirement exists is different from knowing what needs to happen before the crew gets started.

For subcontractors, this matters because regulatory compliance eventually becomes field execution. The regulation can establish the requirement. Someone still has to build the work correctly.

Regulatory Change Eventually Reaches the Craft

OSHA’s construction PPE rule provides a straightforward example. OSHA revised 29 CFR 1926.95 to explicitly require employers to select personal protective equipment that properly fits each affected employee. The change became effective January 13, 2025. OSHA has explained that improper fit can reduce the protection PPE is intended to provide and can introduce additional hazards.

Updating the company PPE program addresses the administrative requirement, but consider what the change looks like at the employee level. A worker using gloves that are too large can lose dexterity while handling small fasteners. Safety glasses that fit poorly can leave gaps in protection. Fall protection equipment also has to fit the person who will wear it rather than simply being available in the gang box.

Now the issue looks different. Purchasing practices become part of implementation. The employee issuing the equipment needs to understand fit, and the person supervising the work needs to recognize when something is wrong. An inspection conducted weeks later should be able to determine whether the change actually reached the people using the equipment.

The regulation started in Washington. Compliance ended up on the jobsite.

Look at What the Work Requires

Hazard Communication shows another side of the same problem. OSHA updated the Hazard Communication Standard in 2024, including revisions involving hazard classifications, labels, and safety data sheets. In January 2026, OSHA extended several compliance dates by four months while additional guidance was being developed.

The safety department can study the revised standard and update the written program. For the employee using a chemical product, the issue is much more practical. Different hazard information can affect how the product is handled or what protection is appropriate. A supervisor planning the activity needs enough information to account for those conditions before the container is opened and the crew begins work.

Companies are generally good at proving that information was delivered. There are training rosters, toolbox talks, email notifications, and revised documents. Those records serve a purpose, but they answer a different question than whether the workforce can perform under the new requirement.

Field observation provides another kind of evidence. Watch the task after the training has been completed. Listen to how the supervisor explains the work. Ask an employee to explain the hazard associated with the product being used. The answers quickly show whether the information moved beyond the classroom.

That should influence how companies respond to future regulatory changes. Before deciding what training is needed, determine what will actually be different about the work. A minor wording change and a new work practice deserve different responses.

When a Code Change Becomes Rework

OSHA is only part of the regulatory picture for subcontractors. Building and energy codes continue to evolve as new editions are published and jurisdictions decide what they will adopt. The 2024 International Energy Conservation Code is the latest IECC edition, and the U.S. Department of Energy has completed its technical analysis of the updated code.

The field experiences a code through the plans, specifications, submittals, and inspection requirements rather than through a publication date or adoption cycle.

Imagine a crew installing a detail the same way it was installed successfully on previous projects. The material looks familiar and the work appears routine, but the current project requires a different detail. The installation reaches inspection before anyone recognizes the difference. Finished work now has to be opened, removed, or corrected.

The immediate conversation will probably be about rework. The larger issue is how the requirement reached the crew in the first place.

Changes involving energy performance or sustainability can create the same type of challenge. A project can introduce unfamiliar products or different installation requirements. Documentation expectations can also affect the subcontractor’s work. Depending on the contract, sustainability requirements can reach procurement decisions long before material arrives in the field.

Some code revisions require little additional training, while others change how the work is performed. The subcontractor needs a process for identifying which changes affect field performance and getting that information to the right people before installation begins.

Safety, quality, and production are tied closely together at that point. Correct work protects more than compliance. It reduces the labor spent doing work twice and limits the schedule pressure created when completed work has to be corrected.

Training Is Only Part of the Response

Construction training often becomes an event. Employees attend a class, the instructor covers the required material, and a roster documents completion. That model works for documenting training, but workforce development requires another step.

The employee has to use the information.

For a simple change, a short field discussion and demonstration could be enough. A different type of equipment or an unfamiliar installation process deserves more attention. The response should be based on what employees are expected to do after the training rather than how quickly the company can put everyone through a presentation.

Verification can also be simple. A supervisor can watch the employee perform the task and correct a misunderstanding before it becomes normal practice. An experienced craft worker can demonstrate the new method while explaining what changed. Safety and quality personnel can focus inspections on the affected work for a period after implementation.

Training is complete when the employee can apply the change correctly in the field.

Supervisors Are Part of the Process

Subcontractors should pay particular attention to supervisors when regulatory requirements change. The field supervisor is often the person who has to turn a company expectation into tomorrow morning’s work plan.

Many supervisors earned their positions because they were good at their trade. They knew how to build the work and could keep a crew productive. Promotion gradually added responsibilities that were different from the craft skills that originally made them successful. Regulatory compliance became part of the job along with leadership and planning.

A policy update alone does little to develop those capabilities.

If a new requirement affects an installation, the supervisor needs that information while planning the activity rather than after an inspector identifies the problem. When different PPE is required, the supervisor should understand the expectation before seeing an employee improperly equipped in the field. New materials deserve the same attention before they are distributed to the crew.

Regulatory implementation becomes much stronger when supervisors are developed as part of the process instead of being treated as another distribution point for information.

Go Look at What Happened

After a significant change has been implemented, someone should go look at the work.

An inspection or audit can determine whether the process produced the intended result. That requires looking beyond the presence of a policy or signed training record. Spend time where the affected work is taking place and compare the written expectations with what is happening in front of you.

Sometimes the process will work exactly as intended. In other cases, several employees will interpret the same requirement incorrectly. The field may expose a practical issue that was never apparent when the procedure was written. A supervisor could also be following an older practice because that is how the work has always been performed.

That information has value beyond the individual finding. When several people make the same mistake, the company should examine the process that produced it. Correcting one employee addresses the condition in front of you. Understanding why the expectation failed to reach several employees can prevent the condition from appearing across multiple projects.

Regulatory changes will continue. New code editions will be adopted, OSHA standards will evolve, and project requirements will place new expectations on subcontractors. Keeping the written program current will always be part of doing business.

The field is where a company finds out whether the change actually worked.

If the crew is still performing yesterday’s work under today’s requirement, the paperwork was only the first step.

About the author

Troy Clark leads MSC Safety Solutions and its family of companies, including Colorado Crane Operator School, Crane Qualified, MSC Workforce Development, and Prolevari. He writes and speaks on leadership and workforce development, sharing a philosophy shaped by decades in construction safety: Safety is a Byproduct of Workforce Development. Troy’s work centers on building safer job sites by building stronger people.