Limits of OSHA Authority Over Mental Health Recordkeeping

This episode is a Fifth Circuit Court of Appeals opinion regarding a dispute between Exxon Mobil Corporation and the Occupational Safety and Health Administration (OSHA). The court addressed whether federal law permits OSHA to compel employers to record work-related mental illnesses, specifically focusing on a post-traumatic stress disorder diagnosis following a refinery explosion. After analyzing the statutory text and historical definitions, the judges concluded that the term "illnesses" in the Occupational Safety and Health Act refers exclusively to physical ailments. Consequently, the court vacated the agency's regulation and the specific penalty against Exxon, ruling that OSHA had exceeded its congressional authority. This decision emphasizes that administrative agencies must stay within the explicit boundaries established by the legislature, regardless of the societal merit of their regulatory goals.