By Adam R. Young, James L. Curtis, and Craig B. Simonsen

Seyfarth Synopsis: A manufacturer was issued a “willful citation” for failure to correct a machine guarding deficiency identified in a previous audit.

After the amputation, OSHA conducted an injury investigation into the Pennsylvania company’s industrial facility. OSHA uncovered that the Company had previously identified
Continue Reading Conduct Guarding Analyses Under Attorney-Client Privilege! OSHA Issues Willful Violation after Uncorrected Alleged Guarding Issue Results in Amputation

By Brent I. Clark, Kay R. Bonza, and Craig B. Simonsen

Seyfarth Synopsis:  OSHA recently updated its National Emphasis Program on Amputations in Manufacturing Industries (NEP), adding a targeting methodology for industries with high employer-reported amputation statistics. Instruction CPL 03-00-022 (Dec. 10, 2019).

We had previously blogged about the previous 2015 update, OSHA Updates Emphasis Program on
Continue Reading OSHA Updates National Emphasis Program on Amputations in Manufacturing Industries

By James L. Curtis, Benjamin D. Briggs, and Craig B. Simonsen

Safety at workBeginning January 1, 2015, OSHA changed its injury reporting rules to require employees to report to OSHA certain severe injuries and employee hospitalization within 24 hours.  We have previously blogged about that change in “OSHA Recordkeeping: Civil and Criminal Liabilities in 2015” and “OSHA
Continue Reading OSHA Publishes Evaluation of Severe Injury Reporting Program

By Brent I. Clark and Craig B. Simonsen

White Square Button with Arm AmputeeLast 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 OSHA Updates Emphasis Program on Amputations – Cites Employer and Places It on Severe Violators List

By James L. Curtis, Ilana R. Morady, and Craig B. Simonsen

As most employers are aware, OSHA implemented new injury reporting requirements under 29 CFR Section 1904.39 effective at the beginning on this year.

One requirement is that employers must now report to OSHA within 24 hours all work-related amputations and losses of an eye. However the question
Continue Reading OSHA Interpretation On New Reporting Rule For Amputations And Sight Loss