DOL's PRO Good Guidance Rule, IRAP, and Hazard-Order Rollbacks: Weakening Worker Protections
Project 2025 proposes reinstating the PRO Good Guidance rule to limit enforcement actions based on guidance documents, recreating the Industry-Recognized Apprenticeship Program (IRAP) outside registered standards, and amending hazard-order regulations to allow teenagers into dangerous jobs with parental consent. These actions would weaken worker safety enforcement, reduce apprenticeship quality, and increase youth injury risks.
Project 2025's DOL proposals aim to weaken worker protections by restricting enforcement tools, diluting apprenticeship standards, and exposing teenagers to hazardous labor. The PRO Good Guidance rule (rescinded by Biden in July 2021) would limit DOL's use of nonbinding guidance in enforcement actions, reducing clarity for small businesses and accountability for violations on sites like construction and warehousing. IRAP (rescinded December 2021) would let trade groups and schools self-certify apprenticeships without federal wage, safety, or training standards, creating a two-tier system lacking protections for vulnerable workers. Most critically, amending hazard-order regulations to let teens under 18 (with parental consent) work in 17 currently prohibited hazardous occupations—like roofing or power-equipment operation—ignores NIOSH data showing 18 worker deaths in 2020 for under-18s (CDC/NIOSH), posing a direct threat to youth life and safety.
The humanitarian alternative
Instead of deregulation, the Department of Labor should strengthen enforcement of existing hazard orders for young workers, expand registered apprenticeships through targeted funding for transportation sectors (including transit maintenance and freight logistics), and maintain PRO Good Guidance-style rules that make guidance documents accessible but retain their enforceability to protect workers from unsafe conditions.
Original source — excerpted
project2025 Project 2025 ch. 19: Department of Transportation (pp 626-628)"— 593 — Department of Labor and Related Agencies rely on the vagueness of the law to bring enforcement activity against businesses that fail to meet an inspector or agency head’s personal standard. This is not fair to regulated parties and results in disfavored companies bearing the brunt of the agencies’ enforcement efforts even though their behavior may be within the main- stream of employer behavior. l Labor agencies should provide compliance assistance to help businesses and workers better understand the agencies’ position on their own rules and should do so in a way that makes it easier to follow those rules. This frees people to focus on their work rather than slogging through an ever-growing body of laws, rules, and guidance documents generated by the agencies. Clear and Restrictive Rules on Guidance Documents. Federal agencies not only issue regulations to fill in gaps left by legislation, but also supplement those reg - ulations with “guidance” documents that occupy a unique and often confusing area between law and “helpful advice.” Unfortunately, wielded by overzealous enforcement agents, such guidance, some of it even hidden from public view, morphs into b…"