OSHA recently identified the 10 most frequently cited standards from FY 2012 (October 1, 2011 through September 30, 2012). There were no surprises on the list, and it was consistent with years past with only a slight shuffling in the order.

OSHA posts on its website the list of top 10 violations (it has not

By Eric J. Conn, Head of the OSHA Practice Group

Back in September, we posted an article critiquing OSHA’s Severe Violator Enforcement Program (“SVEP”) in general, and the newly announced “exit criteria” in particular.  Since that time, in the beginning of October, OSHA updated its embarrassing SVEP Log that it maintains for public consumption

By Eric J. Conn, Head of the OSHA Practice Group

The U.S. Court of Appeals for the District of Columbia Circuit recently provided some much-needed clarification to the meaning of “Willful” with respect to violations of the Occupational Safety and Health Act, in the case of Dayton Tire v. Secretary of Labor, No.

By Eric Conn, Head of the OSHA Practice Group

We recently had an article published by the Washington Legal Foundation entitled “OSHA Continues Trend of Informally Imposing New Rules.”  The article expanded on an earlier post here on the OSHA Law Update Blog regarding OSHA’s attempts to circumvent Formal Notice and Comment

By Eric J. Conn

In what seems to be a trend, OSHA has again delayed its rulemaking process for an Injury and Illness Prevention Program (commonly known as I2P2) standard. The announcement came during a National Advisory Committee on Occupational Safety and Health meeting in late June.  According to OSHA officials, we should not expect

This week, Washington Legal Foundation published an article  regarding OSHA’s New Enterprise-Wide Approach to Enforcement, authored by EBG attorneys Eric J. Conn and Alexis M. Downs.  The article expands on a February 2012 post entitled “Enterprise Enforcement: OSHA’s Attack on Employers with Multiple Locations,” here on the OSHA Law Update Blog.

The gist of

Last week, EHS Today Magazine ran our article in which we delve into more detail about OSHA’s amended Hazard Communication Rule (“HazCom”), and the integration of the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (“GHS”).  Check out the full article here, in which we detailed 10 important things employers need

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

By Casey M. Cosentino and Eric J. Conn

On March 20, 2012, the U.S. Court of Appeals for the Seventh Circuit vacated an ALJ’s decision penalizing Caterpillar Logistics Services, Inc. for allegedly failing to record an employee’s “work-related” musculoskeletal disorder (“MSD”) on the Company’s OSHA 300 log.  Caterpillar Logistics Services, Inc. v. Sec’y of Labor,

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