Four years after the Occupational Safety and Health Act of 1970 (OSHA) was enacted, the Supreme Court extended to safety issues the presumption of arbitrability enunciated in the Steel workers' Trilogy. Because of this decision and the fact that OSHA affects regulation of the terms and conditions of employment, removing exclusive control of the employer-employee relationship from the collective bargaining agreement, arbitrators may find themselves faced with an increasing number of grievances concerning alleged OSHA violations.\
The enactment of OSHA and other labor-related legislation has stimulated concern over the proper balance between terms of the labor contract and external law in arbitration. The judiciary's attitude toward the application of external law may well affect the futurecourse of arbitration. This article explores the impact of OSHA on arbitration, as well as the judiciary's treatment of awards based on the arbitrator's interpretation and application of the act.