By James L. Curtis, Mark A. Lies, II, Adam R. Young, Patrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis: Commission’s approval of undocumented training provides blueprint for employee misconduct claims for employers going forward.

In a July 28, 2020, Occupational Safety and Health Review Commission (OSHRC) decision, Angel Brothers Enterprises, Ltd., (Docket No. 16-0940), the Commission upheld Administrative Law Judge (ALJ) Heather A. Joys’ decision affirming a willful OSHA citation, rejected Angel Brothers Enterprises, Ltd. (Angel’s) unpreventable employee misconduct (UEM) affirmative defense, and assessed a $35,000 penalty.

Angel is a construction contractor that digs over 1,000 excavations each year. On December 8, 2015, Angel began working on the installation of a concrete drainage pipe alongside a road in LaPorte, Texas. The following day, an OSHA compliance officer (CSHO) arrived at the worksite to conduct an inspection. During the inspection, the foreman admitted to the CSHO that he had allowed an employee to work in the excavation, which was no longer benched and lacked a trench box. The Agency issued a willful violation under the trenching construction regulation.

The Company argued that the violation was the result of employee misconduct, including the difficult-to-prove area of supervisory misconduct. To establish employee misconduct, an employer must be able to show that it had (1) a safety rule in place addressing the hazard, (2) effective training on that safety rule, (3) adequate supervision of employees for compliance with that safety rule, and (4) effective enforcement of violations of the safety rule. Supervisory misconduct requires a further showing of unforeseeable conduct on the part of the supervisor.

As to the UEM element requiring effective enforcement of safety rules, the ALJ held that Angel did not effectively enforce its safety rules upon discovering violations. Specifically, the ALJ focused on the employer’s failure to identify or correct an employee’s answers to three questions about cave-in protection on a “Pre-Task Plan” form for the project on three consecutive days. ALJ Joys considered this three-day pattern analogous to the facts in Dana Container, Inc., 25 BNA OSHC 1776 (No. 09-1184, 2015), aff’d, 847 F.3d 495 (7th Cir. 2017), in which the Commission found that a consistent failure to correct errors on “entry permit” forms demonstrated a lack of enforcement.

Though the Commission affirmed that the employer had not proved UEM, the Commission provided helpful guidance on the elements required for proving the UEM defense. Judge Joys held that Angel could not prove adequate communication of the safety rule, because its training was on-the-job, verbal, not fully documented, and contradicted by other testimony. The Commission instead found the evidence “more than sufficient to meet Angel’s burden of proving adequate communication,” despite the lack of documentation. The Commission relied on testimonial evidence of toolbox talks, orientation training sessions, competent person training, and Spanish-language instruction for Spanish-speaking employees.

Employee misconduct is the most common defense to OSHA citations. Employers should be aware that many citations are defensible and should be contested or appealed, particularly where they result from incidences of employee misconduct. Though OSHA is a document-driven agency, the Commission has confirmed that training documentation cannot and need not exist in a written form for all safety training that takes place. Employers should consult with counsel to develop any defense to OSHA citations.

For more detail as to other steps an employer must take based upon the specific risk level identified during the initial exposure assessment, please contact the authors, your Seyfarth attorney, or any member of the Workplace Safety and Health (OSHA/MSHA) Team.

By Jeryl L. Olson, Patrick D. JoyceKay R. Bonza, and Craig B. Simonsen

Seyfarth Synopsis: On August 5, 2020, the U.S. Environmental Protection Agency (EPA or Agency) released a final memorandum on “Guidance on Plantwide Applicability Limitation Provisions Under the New Source Review Regulations.”

The guidance memorandum is, according to EPA, intended to increase the use of an air permitting option little-used by, but potentially favorable to industry, by improving understanding of PAL by stakeholders. According to EPA, confusion caused by previous guidance has led to a relative low adoption rate in the 17 years PALs have been in existence; from industry’s prospective however, the process for obtaining a PAL is formidable, particularly because state permitting agencies have little or no experience with PALs and are reluctant to take the “leap of faith” necessary to make PALs attractive to industry.

PALs are an optional, flexible permitting mechanism that involves the establishment of a plantwide emissions limit, (in tons per year), for specific pollutants. Once established, changes to facility operations that affect that pollutant can forego New Source Review (“NSR”),  a costly and time consuming process for industry. The PAL provides a permittee the ability to manage process changes (modifications) without triggering major NSR and the need to conduct project-by-project major NSR applicability analyses. To qualify a PAL, EPA’s regulations require a source to conduct monitoring, recordkeeping and reporting of the actual emissions of a PAL pollutant on a 12-month rolling basis (which most sources do already).

While industry is generally familiar with the option, EPA’s guidance appears to be  intended to address specific concerns raised by non-permittee “stakeholders” on the PAL provisions and to generally improve the understanding of PALs by the public. According to EPA, particular concerns raised by stakeholders are addressed in the guidance, and include discussions of : (1) PAL Permit Reopening, (2) PAL Expiration, (3) PAL Renewal, (4) PAL Termination, (5) Monitoring Requirements for PALs, (6) Emission Factor Adjustment, (7) Validation Testing, (8) Missing Monitoring Data, (9) Baseline Actual Emissions for Replacement Units, and (10) General Advantages of PALs and Other Considerations.

For more information on this or any related topic please contact the authors, your Seyfarth attorney, or any member of the Seyfarth Environmental Compliance, Enforcement & Permitting Team.

Seyfarth Synopsis: Today we will begin posting a monthly summary of our Workplace Safety and Environmental blogs posted over the month, as a way to keep you connected and aware of the latest thought leadership. As always, readers are encouraged to reach out to our authors with and comments or questions raised from the blogs.

First Employer Cited For Violating Washington’s Safe Start Order

Seyfarth Synopsis: The Department of Labor and Industries issued its first citation against an employer for violating Washington’s Safe Start Order.

EPA Ends Enforcement Discretion Policy for COVID-19 Pandemic on August 31

Seyfarth Synopsis: On June 29, 2020, U.S. Environmental Protection Agency (EPA) issued a memorandum regarding termination of the COVID-19 temporary enforcement policy. EPA has selected August 31, 2020 as the termination date for its temporary enforcement policy. Also updated were EPA’s Frequent Questions About the Temporary COVID-19 Enforcement Policy.

OSHA Updates FAQs on Face Masks in the Workplace

Seyfarth SynopsisThe Occupational Safety and Health Administration has updated its frequently asked questions and answers to advise employers about the use of face masks in the workplace.

EPA Proposes Amendments to Air Toxics Standards for Industrial, Commercial, and Institutional Boilers and Process Heaters NESHAP

Seyfarth Synopsis: The U.S. Environmental Protection Agency has released a pre-publication copy of its proposed amendments to the Air Toxics Standards for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Source Facilities, 40 CFR Part 63. The proposed rules establish new emissions limits for a large number of chemicals, and impose significant obligations on affected parties utilizing a variety of boilers.

Virginia Adopts Emergency Workplace Safety Regulations

Seyfarth Synopsis: In late May, Virginia Governor Ralph Northam directed the state’s Department of Labor and Industry to develop emergency temporary standards to prevent workplace exposure to COVID-19. Those rules were adopted on July 15, 2020.

By Benjamin D. BriggsPatrick D. Joyce, Adam R. Young, and Craig B. Simonsen

Seyfarth Synopsis: In late May, Virginia Governor Ralph Northam directed the state’s Department of Labor and Industry (DLI) to develop emergency temporary standards to prevent workplace exposure to COVID-19. Those rules were adopted on July 15, 2020. 

Federal OSHA has only issued guidance related to COVID-19 compliance, proceeding with enforcement under existing regulations and the General Duty Clause. 22 states, including Virginia, operate State Plans that enforce safety standards against private employers and have the authority to issue their own safety regulations.

Governor Northam, in a July 15, 2020, news release, announced the adoption of statewide emergency workplace safety standards in response to the Novel Coronavirus (COVID-19). “These first-in-the-nation safety rules will protect Virginia workers by mandating appropriate personal protective equipment, sanitation, social distancing, infectious disease preparedness and response plans, record keeping, training, and hazard communications in workplaces across the Commonwealth.”

The Virginia Department of Labor and Industry’s 14-member Safety and Health Codes Board voted to approve an emergency temporary standard (ETS) on infectious disease prevention. The ETS will remain in effect for six months and sunsets either six months after its effective date (which was July 27, 2020), or when it is superseded by a permanent rule.

Notably, the Emergency Rule includes a provision that protects employers who comply with guidance from the Centers for Disease Control and Prevention (CDC) related to mitigation of COVID-19 in the workplace. To the extent employers in Virginia comply with CDC guidelines that are as stringent as or more stringent than the provisions in Virginia’s Emergency Rule, they will be deemed in compliance with the Emergency Rule.

The Emergency Rule requires employers to analyze job tasks on a task-by-task basis (not on an employee-by-employee basis as originally proposed). Similar to Federal OSHA’s Guidance on Preparing Workplaces for COVID-19, the Emergency Rule breaks exposure risk levels into four categories: “very high,” “high,” “medium,” and “lower.” “Very High” risk jobs include activities that involve aerosol-generating procedures or working with known COVID-19 patients or specimens. “High” risk jobs include activities in the healthcare, first responder, medical transport, and mortuary services industries. “Medium” risk jobs are those that involve working in close-quarters with others or those with regular contact with the public such as educational settings, grocery stores, correctional settings, personal care, fitness, public transportation, and healthcare settings where exposure to COVID-19 is not expected. “Lower” risk jobs are those that do not fit into one of the other categories.

Employers with job tasks classified as “Very High” or “High,” as well as employers with greater than 10 employees with job tasks classified as “Medium” must prepare an Infectious Disease Preparedness and Response Plan, as outlined in the Emergency Rule.

Employers with job tasks at all risk levels must conduct an exposure assessment, notify employees of risks associated with COVID-19, notify employees that they should not report to work if they have or are suspected to have COVID-19, educate employees on how to prevent exposure to COVID-19 as well as the signs and symptoms of the illness, inform employees how to report to the employer of COVID-19 symptoms or that they have been confirmed positive with COVID-19. The Emergency Rule also contains provisions related to flexible sick-leave policies and notifying contractors and building owners of confirmed COVID-19 cases. Finally, all employers must prepare return to work policies and procedures including methods to identify COVID-19 cases, conduct workplace disinfection, and implement other measures that are protective of employee safety and health.

Virginia is leading the State Plan states (and federal OSHA) with its complex and comprehensive COVID regulations.  The Washington State Department of Occupational Safety and Health issued its own temporary emergency rule in late-May, though it is not as complex or comprehensive as Virginia’s Emergency Rule.

For more detail as to other steps an employer must take based upon the specific risk level identified during the initial exposure assessment, please contact the authors, your Seyfarth attorney, or any member of the Workplace Safety and Health (OSHA/MSHA) Team.

By Jeryl L. Olson, Rebecca A. DavisAndrew H. PerellisPatrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis: The U.S. Environmental Protection Agency (EPA or Agency) has released a pre-publication copy of its proposed amendments to the Air Toxics Standards for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Source Facilities, 40 CFR Part 63. The proposed rules establish new emissions limits for a large number of chemicals, and impose significant obligations on affected parties utilizing a variety of boilers.

The current version of the national emission standards for the control of hazardous air pollutants (NESHAP) were finalized with amendments in 2013 for the purpose of controlling hazardous air pollutants (HAP) at major sources from new and existing industrial, commercial, and institutional boilers and process heaters. The currently proposed amendments are EPA’s response to three separate remands from decisions of the United States Court of Appeals for the District of Columbia Circuit.

The first two remands both arise out of the 2016 case of U.S. Sugar Corp. v. EPA. In the first remand, the Court sought further explanation for emission standards for subcategories of boilers where it determined EPA had improperly excluded certain units in calculating maximum achievable control technology (MACT) floor emission limits. In the second remand, the U.S. Sugar Corp. Court also remanded for EPA to provide further explanation regarding its decision to use carbon monoxide (CO) as a surrogate for organic HAP emissions. The third remand was from March 2018 where, in the case of Sierra Club, et al. v. EPA, the Court remanded for “further explanation EPA’s decision to set a limit of 130 ppm CO as a minimum standard for certain subcategories of boilers.”

To address the first remand the amendments propose 34 recalculated MACT emission limits for certain subcategories of boilers. To resolve the other two remands, the proposed amendments provide the Court with an explanation on available control technologies to reduce organic HAP emissions without involving CO, and to address whether the best performing boilers might be using alternative control technologies to reduce organic HAP. The proposed amendments also explain “EPA’s decision to establish 130 parts per million (ppm) as the lowest (i.e., most stringent) emission limit for CO consistent with the requirements of the Clean Air Act.”

While according to the Agency, the proposed changes will protect air quality and reduce emissions of HAPs, the Agency also admits the rules, if adopted, will only reduce HAPS by 244 tons per year, at a cost to industry of more than $21.5 million (that is, a cost of $88,000 per ton of reduction).

The Agency notes that if “anyone contacts us requesting a public hearing on or before [5 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER], it will hold a virtual public hearing. Comments may be submitted to Docket ID No. EPA-HQ-OAR-2002-0058, or by email to a-and-r-docket@epa.gov, Attention Docket ID No. EPA-HQ-OAR-2002-0058.

For more information on this or any related topic please contact the authors, your Seyfarth attorney, or any member of the Seyfarth Environmental Compliance, Enforcement & Permitting Team.

By James L. CurtisAdam R. Young, and Craig B. Simonsen

Seyfarth Synopsis: The Occupational Safety and Health Administration (OSHA) has updated its frequently asked questions and answers to advise employers about the use of face masks in the workplace.

We had blogged previously about face masks at work. See DOL Issues FAQs About Face Coverings, Surgical Masks, and Respirators in the Workplace, Nothing Comes Close To The Golden Coast: California Requires Masks, New York Issues Executive Order Requiring Employers to Provide Essential Workers with Face Masks, and New CDC Face Mask Guidance Raises Liability Issues.

Now the OSHA FAQs indicate that “OSHA generally recommends that employers encourage workers to wear face coverings at work. Face coverings are intended to prevent wearers who have COVID-19 without knowing it (i.e., those who are asymptomatic or pre-symptomatic) from spreading potentially infectious respiratory droplets to others. This is known as source control.” Consistent with the Centers for Disease Control and Prevention (CDC) recommendation for all people to wear cloth face coverings when in public and around other people, “wearing cloth face coverings, if appropriate for the work environment and job tasks, conserves other types of personal protective equipment (PPE), such as surgical masks, for healthcare settings where such equipment is needed most.”  OSHA explains that:

Employers have the discretion to determine whether to allow employees to wear cloth face coverings in the workplace based on the specific circumstances present at the work site. For some workers, employers may determine that wearing cloth face coverings presents or exacerbates a hazard. For example, cloth face coverings could become contaminated with chemicals used in the work environment, causing workers to inhale the chemicals that collect on the face covering. Over the duration of a work shift, cloth face coverings might also become damp (from workers breathing) or collect infectious material from the work environment (e.g., droplets of other peoples’ infectious respiratory secretions). Workers may also need to use PPE that is incompatible with the use of a cloth face covering (e.g., an N95 filtering facepiece respirator).

OSHA concludes that where cloth face coverings are not appropriate in the work environment or during certain job tasks, “employers can provide PPE, such as face shields and/or surgical masks, instead of encouraging workers to wear cloth face coverings. Like cloth face coverings, surgical masks and face shields can help contain the wearer’s potentially infectious respiratory droplets and can help limit spread of COVID-19 to others.”

While OSHA offers face shields as an alternative where face coverings are not feasible, no federal agencies have certified face shields as an equally effective alternative means of protection.  The CDC explains that “it is not known if face shields provide any benefit as source control to protect others from the spray of respiratory particles. CDC does not recommend use of face shields for normal everyday activities or as a substitute for cloth face coverings.”

For more information on this or any related topic, please contact the authors, your Seyfarth attorney, or any member of the Workplace Safety and Health (OSHA/MSHA) Team.

By Andrew H. PerellisJeryl L. OlsonPatrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis: On June 29, 2020, U.S. Environmental Protection Agency (EPA) issued a memorandum regarding termination of the COVID-19 temporary enforcement policy. EPA has selected August 31, 2020 as the termination date for its temporary enforcement policy. Also updated were EPA’s Frequent Questions About the Temporary COVID-19 Enforcement Policy.

In support of the U.S. Government’s overall response to the COVID-19 pandemic, EPA previously issued a temporary enforcement discretion policy, COVID-19 Implications for EPAs Enforcement and Compliance Assurance Program (3/26/2020), that applied to civil violations during the COVID-19 outbreak. See our earlier blog, EPA Enforcement Discretion Policy for COVID-19 Pandemic, for detailed discussion of the temporary policy.

EPA has now announced that this temporary policy will terminate on August 31, 2020, and EPA will return to its pre-COVID enforcement guidelines. This means that the EPA will not base any exercise of enforcement discretion on this temporary policy for any noncompliance that occurs after August 31, 2020.

According to EPA, it is terminating its temporary policy because “new federal guidelines and directives have been issued to support both the public health response and economic recovery efforts, and many parts of the country have already taken steps to relax social distancing restrictions in parts or all of individual states, with the goal of returning to normal operations. As state and local restrictions are relaxed or lifted, so too may the restrictions that potentially impede regulatory compliance, reducing the circumstances in which the temporary policy may apply.”

For more information on this or any related topic please contact the authors, your Seyfarth attorney, or any member of the Seyfarth Environmental Compliance, Enforcement & Permitting Team.

By Helen M. McFarland and Amanda J. Hailey

Seyfarth Synopsis: The Department of Labor and Industries (L&I) issued its first citation against an employer for violating Washington’s Safe Start Order.

As set forth in our May 28, 2020 blog postProhibited Business Activities and Conditions for Operations,” the State of Washington is enforcing its Emergency COVID-19 Safety Rules.

The Department of Labor and Industries (L&I) recently issued its first citation to a fitness gym that operated in violation of Governor Inslee’s Safe Start phased reopening plan. The Gym was cited and fined $9,639 for noncompliance.

The facility operates in Yakima county, which has many active cases of coronavirus (COVID-19) and currently remains in Phase 1 of the Governor’s Safe Start plan. During this phase, only essential businesses and other limited operations may remain open.  L&I learned of the facility’s violations after receiving complaints and a direct referral from the Yakima Health District. The company was contacted many times before L&I went out to conduct its investigation.

Employees at Washington’s Emergency Operations Center (EOC) have been contacting businesses about compliance with the rules. When employers refuse to follow the Safe Start plan, L&I may send a warning letter to let the business know that it is at risk of being fined if it remains open. Employers who remain in noncompliance may receive a visit from a Department of Occupational Health (DOSH) inspector, who will conduct an inspection and may issue a citation.

This serves as an important reminder. Employers should not rush to re-open beyond the boundaries of Washington’s Safe Start Plan. Operating outside the plan puts businesses at risk of citations and fines.

For more information on this or any related topic, please contact the authors, your Seyfarth attorney, or any member of the Workplace Safety and Health (OSHA/MSHA) Team.

By James L. Curtis, Mark A. Lies, II, Patrick D. Joyce, Adam R. Young, and Craig B. Simonsen

Seyfarth Synopsis: OSHA Administrator Loren Sweatt recently blogged related to heat illness in the workplace as “forecasters are calling for above-average heat in some parts of the country and scorching temperatures in July and August.” Sweatt suggests six items to keep in mind as employers prepare for a hot summer.

We had previously blogged, Heat Illness Strikes Back: Return to Work’s Untold Story, that as we approach the heat of the summer season and as employers begin to return to work (RTW) after months of COVID-19 quarantine, workers may be out of shape, out of practice on workplace safety procedures, and may have to rebreathe hot air through face coverings. As employers focus on COVID-19 RTW efforts, they should remain aware of risks of safety rule violations, injuries, and heat illness. Loren Sweatt, OSHA’s Acting Administrator, recently blogged on this topic.

In Sweatt’s blog, she provided six tips to prepare employers and employees for a hot summer:

  1. Memorize these three words: “Water. Rest. Shade.” Ideally, workers should drink cool water as often as possible, but they may need sports beverages containing balanced electrolytes if they are sweating for several hours at a time. Employers should make sure workers can access shaded or air-conditioned rest areas to cool down as needed.
  2. New and temporary workers are most at risk. The body needs time to build a tolerance to heat, which is why more than 70% of outdoor heat fatalities occur during a worker’s first week of working in warm or hot environments. The process of building tolerance is called “acclimatization.” Learn how to create a heat illness prevention plan and be sure to supervise new employees until they are fully acclimatized.
  3. Indoor workers also can suffer from heat illness. Kitchens, laundries, warehouses, foundries, boiler rooms and many other indoor work environments can become dangerously hot. See a list of industries where OSHA considers workers to be at high risk.
  4. Use engineering controls or modify work practices to protect employees. For example, try increasing ventilation using cooling fans, schedule work at a cooler time of the day, and rotate job functions among workers to minimize heat exposure. Find additional best practices from OSHA here.
  5. Familiarize everyone at your workplace with the signs and symptoms of heat illness and make sure everyone knows what to do in an emergency.
    • Common heat exhaustion signs are: dizziness, headaches, cramps, sweaty skin, nausea and vomiting, weakness and a fast heartbeat. Heat stroke symptoms may include red, hot, dry skin; convulsions; fainting; very high temperature and confusion.
    • Pair workers with a buddy to observe each other for early signs and symptoms of heat illness.
    • Employees should call a supervisor for help if they believe someone is ill – and 911 if a supervisor is not available, or if someone shows signs of heat stroke.
  6. Download the OSHA-NIOSH Heat Safety App on your iPhone or Android device to help calculate the heat index at your worksite. The app provides specific recommendations for planning work activities and preventing heat illness based on the estimated risk level where you are working.

As workers continue to return to work after a prolonged absence due to COVID-19, employers should be extra vigilant in refreshing employee training, especially as it relates to heat illness prevention and other safety requirements that could have slipped an employee’s mind while they were in quarantine. Return to work may necessitate generalized retraining on core safety rules.

For more information on this or any related topic, please contact the authors, your Seyfarth attorney, or any member of the Workplace Safety and Health (OSHA/MSHA) Team.

By Jaclyn Gross and Chantelle C. Egan

Seyfarth Synopsis: As counties begin loosening local restrictions and summer approaches, and in an effort to preempt a rise in COVID-19 cases, the California Department of Public Health issued a directive mandating that residents statewide wear face coverings.

Before last week, California only recommended that residents wear face coverings as a precautionary measure with COVID-19, and the State left it in local governments’ hands to decide whether a mandatory requirement was necessary. As summer heats up and tempts residents to spend more time outside and congregate, Governor Newsom and the California Department of Public Health have issued a mandatory face covering directive to mitigate the spread of COVID-19 throughout California.

Masks on Top!

Under this new directive, unless a resident is specifically exempted, face coverings must be worn statewide in the following “high-risk” circumstances:

  • Inside of, or in line to enter, any indoor public space;
  • Obtaining services from the healthcare sector in settings including, but not limited to, a hospital, pharmacy, medical clinic, laboratory, physician or dental office, veterinary clinic, or blood bank;
  • Waiting for or riding on public transportation or paratransit or while in a taxi, private car service, or ride-sharing vehicle;
  • Engaged in work, whether at the workplace or performing work off-site, when:
    • Interacting in-person with any member of the public;
    • Working in any space visited by members of the public, regardless of whether anyone from the public is present at the time;
    • Working in any space where food is prepared or packaged for sale or distribution to others;
    • Working in or walking through common areas, such as hallways, stairways, elevators, and parking facilities;
    • In any room or enclosed area where other people (except for members of the person’s own household or residence) are present when unable to physically distance.
  • Driving or operating any public transportation or paratransit vehicle, taxi, or private car service or ride-sharing vehicle when passengers are present. When no passengers are present, face coverings are strongly recommended.
  • While outdoors in public spaces when maintaining a physical distance of 6 feet from persons who are not members of the same household or residence is not feasible.

West Coast Represent: County, City, and Industry Guidance

While the statewide directive does not specifically address California employers’ obligations, employers should keep in mind that more restrictive local orders will control. Accordingly, if a county or citywide order mandates wearing face coverings under additional sets of circumstances, or orders employers to provide face coverings to employees, the business must still abide by those requirements. Likewise, FAQs also issued last week direct Californian employees to industry guidance for additional situations warranting mask wearing at work.

Workplace Solutions

We are continuing to monitor California COVID-19 developments. If you have questions, please be sure to visit Seyfarth’s COVID-19 Resource Center, or contact your favorite Seyfarth attorney directly.

Edited by Coby Turner