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Category Archives: OSHA Compliance

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OSHA Says You Should Train Employees on How to Do Their Laundry

Posted in OSHA Compliance

By Meagan Newman and Adam R. Young

On June 1, 2015, federal OSHA released an Interpretation Letter requiring that employers train employees on the laundering requirements of fire retarding (FR) and arc-rated clothing.

The question, submitted to OSHA by the United Association of Plumbers and Pipefitters, sought OSHA’s enforcement position on the Personal Protective Equipment (PPE) Standard, 29 C.F.R. § … Continue Reading

OSHA Updates “General Industry Digest”

Posted in OSHA Compliance

By Brent I. Clark, Adam R. Young, and Craig B. Simonsen

Federal OSHA has recently revised and re-published its “General Industry Digest” (Digest). OSHA 2201-08R 2015.

The Digest gives an overview of OSHA’s general industry standards to aid employers, supervisors, workers, and safety and health professionals in achieving compliance.

The Digest provides summaries of the “standards … Continue Reading

OSHA Implications Under the NLRB’s New Expansive Definition of Joint Employer

Posted in OSHA Compliance

By Meagan Newman, Ilana R. Morady, and James L. Curtis

Last week on our Employer Labor Relations Blog we wrote about a recent ruling of the National Labor Relations Board in the Browning-Ferris Industries (BFI) case that vastly expanded the definition of joint employer.

The case involved two companies, BFI and Leadpoint. Under a contract with BFI, Leadpoint … Continue Reading

IFA Seeks OSHA Explanation of Applying a New Joint Employer Standard

Posted in Investigations/Inspections, OSHA Compliance

By James L. Curtis, Craig B. Simonsen, and Ronald J. Kramer

The International Franchise Association (IFA) has filed a Freedom of Information Act (FOIA) request with the Occupational Safety & Health Administration (OSHA) asking for the rationale behind questions that its inspectors are asking franchise owners, which appear designed to establish joint employer relationship between franchisors and local … Continue Reading

OSHA Updates Emphasis Program on Amputations – Cites Employer and Places It on Severe Violators List

Posted in Investigations/Inspections, OSHA Compliance, OSHA Enforcement

By Brent I. Clark and Craig B. Simonsen

Last week OSHA issued its updated National Emphasis Program on Amputations (NEP). Instruction CPL 03-00-019 (June 30, 2015). Take that juxtaposed against OSHA’s citation in a recent case where on his first day on the job a 21-year-old employee suffered severe burns and the loss of four fingers.

National Emphasis Program on Continue Reading

Cal/OSHA District Offices Taking Expansive View of Injury/Illness Reporting Requirements

Posted in California, OSHA Compliance

By Mark A. Lies, II and Ilana R. Morady

As many employers know, California frequently does things a little differently than other jurisdictions. Cal/OSHA is no exception.

When it comes to injury/illness reporting, Cal/OSHA (a.k.a. “the Division”) requires “any serious injury or illness, or death” to be reported within 8 hours to the nearest District Office. Serious injury or illness … Continue Reading

DHS Chemical Facilities Take Note GAO Suggested Need For Enhanced Enforcement

Posted in Chemical Safety, Emergency Planning, Environmental Compliance, OSHA Compliance

By Andrew H. Perellis and Craig B. Simonsen

The U.S. Government Accountability Office (GAO) has just issued a report on Critical Infrastructure Protection with a finding that Department of Homeland Security (DHS) action is needed to verify chemical facility information and to better manage its compliance process. Report to Congress, GAO-15-614 (July 2015).

Risk Level for Facilities

The Report states … Continue Reading

OSHA Directive on Inspection Procedures for the Hazard Communication Standard

Posted in Chemical Safety, OSHA Compliance

By Meagan Newman and Craig B. Simonsen

OSHA has just announced a compliance Directive on “Inspection Procedures for the Hazard Communication Standard,” CPL 02-02-079 (July 9, 2015).

We had previously blogged that June 1, 2015 was the deadline for compliance with the all new hazardous communication (HazCom) standard (29 CFR section 1910.1200) (HCS 2012) requirements, with exceptions for … Continue Reading

OSHA Enforcement Memo and Interim Policy on the Process Safety Management Retail Exemption

Posted in Chemical Safety, OSHA Compliance

By Meagan Newman and Craig B. Simonsen

The Occupational Safety and Health Administration issued yesterday an enforcement memo (Memo) and an interim policy (Policy) on the PSM retail exemption.

Tho Memo revised OSHA’s interpretation of the exemption of retail facilities from coverage of the Process Safety Management of Highly Hazardous Chemicals (PSM) standard (29 CFR 1910.119). The revision, … Continue Reading

Healthcare Employers to Get Even More Attention from OSHA

Posted in Investigations/Inspections, OSHA Compliance, Workplace Violence

By James L. Curtis and Craig B. Simonsen

OSHA has released an “Inspection Guidance for Inpatient Healthcare Settings,” that will focus its inspectors attention to musculoskeletal disorders, workplace violence, bloodborne pathogens, tuberculosis, and slips, trips, and falls.

The Guidance focuses on hazards that were included in OSHA’s recently-concluded National Emphasis Program on Nursing and Residential Care Facilities, CPL Continue Reading