A federal appeals court has ruled that the Occupational Safety and Health Administration (OSHA) cannot require employers to record work-related mental illnesses under a key federal workplace safety law, marking a significant legal setback for the agency’s oversight authority.
The decision, issued by the U.S. Court of Appeals for the Fifth Circuit, stems from a dispute involving Exxon Mobil and an employee who developed post-traumatic stress disorder (PTSD) after helping firefighters during a refinery fire in Texas.
Court Ruling
In the opinion, Judge Cory Wilson concluded that OSHA’s authority under the Occupational Safety and Health Act does not extend to requiring employers to document mental illnesses as workplace injuries.
The court found that the law’s reference to “illnesses” should be interpreted as applying only to physical conditions rather than psychological ones.
Wilson wrote that while OSHA’s interpretation may be plausible, the better reading of the statute limits its authority to physical work-related illnesses and injuries.
Refinery Fire
The case centers on a December 3, 2021, fire at Exxon Mobil’s Baytown refinery near Houston.
According to court records, an employee identified only as Employee 2 entered a burning facility twice alongside firefighters to help locate and close critical valves after a pipe rupture sparked a massive fire.
Although he was not a trained firefighter, the employee assisted emergency crews in hazardous conditions while wearing borrowed firefighting gear.
After the incident, he experienced symptoms including anxiety, nightmares, depression, hypervigilance, and emotional distress.
PTSD Diagnosis
The employee sought treatment through Exxon Mobil’s employee assistance program and was diagnosed with PTSD by a licensed therapist.
Additional evaluations by his primary care physician and another trauma specialist reached the same conclusion.
Exxon later requested further evaluations, including an independent review, after questioning whether the condition qualified as a work-related illness.
One psychologist hired through the company’s review process concluded the employee did not meet the criteria for PTSD.
OSHA Investigation
After the employee’s union raised concerns, OSHA investigated whether Exxon had failed to record the PTSD diagnosis as a workplace illness.
The agency cited Exxon for violating federal recordkeeping requirements, and an OSHA administrative judge upheld the citation.
Exxon appealed, arguing that the Occupational Safety and Health Act does not require employers to document work-related mental illnesses.
The Fifth Circuit agreed with the company, overturning OSHA’s position.
Broader Impact
The ruling applies within the Fifth Circuit, which covers Texas, Louisiana, and Mississippi.
Legal experts say the decision could reduce the number of reported workplace illnesses in those states because employers would no longer be required to include qualifying mental health conditions in OSHA injury logs.
The decision also reflects the changing legal landscape following the U.S. Supreme Court’s 2024 ruling that ended the Chevron doctrine, which had required courts to give greater deference to federal agencies’ interpretations of ambiguous laws.
Without that precedent, courts now independently interpret federal statutes, potentially limiting the authority of regulatory agencies such as OSHA.
Ongoing Debate
The ruling has drawn attention because it touches on broader questions about how workplace mental health should be treated under federal law.
Supporters of OSHA’s interpretation argue that psychological injuries such as PTSD can result directly from workplace events and should be documented alongside physical injuries.
The Fifth Circuit, however, concluded that Congress did not clearly authorize OSHA to require employers to record mental illnesses under the current language of the Occupational Safety and Health Act.
FAQs
What did the Fifth Circuit rule?
It ruled OSHA cannot require reporting of workplace mental illnesses under the law.
What case led to the decision?
The ruling stemmed from Exxon Mobil’s dispute over an employee’s PTSD diagnosis.
What condition did the employee develop?
The employee was diagnosed with post-traumatic stress disorder (PTSD).
Which states are affected by the ruling?
The Fifth Circuit covers Texas, Louisiana, and Mississippi.
Does the ruling apply nationwide?
No. The decision directly applies within the Fifth Circuit’s jurisdiction.
