Yes. That's why Biden hasn't imposed his order.
The OSHA ETS (or EPS) rule re-interpretations that are considered "A major rule" must be clearly approved by Congress. Over 90% of these ETS re-interpretations are struck down by the courts when challenged because of the lack of clear congressional approval. This one would be easily struck down.
If Congress were to pass a law (not likely given the filibuster in the Senate), even that would likely be struck down on Constitutional grounds, but no way 1 guy, all by himself, could order every company in the United States to do anything this massive.
I sure hope you’re right.
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