By Eric J. Conn and Casey M. Cosentino Following a March 20, 2012 Press Release, on March 26, 2012, OSHA issued its much anticipated final Hazard Communication Rule (“HazCom”), which integrates the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (“GHS”) into OSHA’s old Hazard Communication Standard (“HazCom” or “HCS”). The new HazCom Standard… Continue Reading
Category Archives: Process Safety Management
Subscribe to Process Safety Management RSS FeedCSB to Increase Participation of Non-Management Employees – At the Expense of Employers
By Forrest G. Read, IV and Eric J. Conn The U.S. Chemical Safety and Hazard Investigation Board (CSB) announced earlier this month a new policy disguised as a nod to enhancing employee participation in CSB investigations, but which may actually represent a dramatic limitation in the investigation rights of both employees and employers. The new… Continue Reading
Managing an OSHA Inspection: Answers to 5 Frequently Asked Questions
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. * * * * * * * … Continue Reading
10 Things You Must Know About OSHA’s Nationwide Chemical Facilities PSM NEP
By Eric J. Conn, Head of the OSHA Practice Group at Epstein Becker & Green At the end of November 2011, OSHA announced that it had extended nationwide what had been a limited pilot enforcement program targeting chemical facilities’ compliance with OSHA’s Process Safety Management Standard in a few Regions of the country. This new Chemical… Continue Reading
OSHA Targets Manufacturers, Nursing Care Facilities, and Chemical Plants
By Eric J. Conn What do manufacturers, nursing homes, and chemical companies have in common? They all represent industries receiving special enforcement scrutiny from today’s OSHA. OSHA is targeting manufacturers under a major Recordkeeping Enforcement National Emphasis Program (Recordkeeping NEP). OSHA launched the Recordkeeping NEP at the end of 2009, originally selecting inspection targets across… Continue Reading