By Eric J. Conn
Below is a set of important questions that we are frequently asked by clients when OSHA unexpectedly shows up at their doorsteps. These questions and many more are also addressed in our OSHA Inspection Checklist desk reference guide.
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Scenario 1: An OSHA Compliance Safety and Health Officer (CSHO) arrives unannounced to begin an inspection, but the employer’s representative whom the employer desires to manage the OSHA inspection is not present at the workplace. Can the employer request that the CSHO return later or wait to start the inspection … Continue Reading
By Alexis M. Downs and Eric J. Conn
Companies that operate multiple facilities in different locations, such as national retail stores, grocery chains, manufacturers, and hotel chains, need to be aware of three new OSHA enforcement trends with enterprise-wide consequences:
- A rise in follow-up inspections and Repeat violations at sister facilities within a corporate family;
- OSHA’s increasing pursuit of company-wide abatement provisions in settlement agreements; and
- OSHA’s recent requests for enterprise-wide relief from the Occupational Safety and Health Review Commission.
Follow-up Inspections and Repeat Violations:
The most significant trend impacting employers with multiple locations is OSHA’s recent fascination with Follow-up … Continue Reading
By Casey M. Cosentino and Eric J. Conn
On June 2, 2011, OSHA launched an enforcement National Emphasis Program focused on employers and hazards in the Primary Metals Industries (“Primary Metals NEP”). Establishments in the primary metals industries are those involved in extracting and refining metals from rocks containing iron, lead, nickel, tin and other primary metals, and smelting ferrous and nonferrous metals, including ore, pig and scrap, during rolling, drawing, casting and alloying metal operations. Some products manufactured in this sector include nails, wires and cables, steel piping, sheets and bars, and copper and aluminum products.
OSHA decided that … Continue Reading