Investigations/Inspections

By Jeryl L. OlsonRebecca A. DavisIlana R. Morady, Patrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis: We noted earlier this year that the American Society for Testing and Materials (ASTM) was in the process of updating its Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process. The ASTM Standard
Continue Reading Updated ASTM Standard for Phase I Environmental Site Assessments Just Released

By Jeryl L. OlsonRebecca A. DavisPatrick D. Joyce, Ilana R. Morady, and Craig B. Simonsen

Seyfarth Synopsis: The ASTM is in the process of updating its Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process.

A Phase I Environmental Site Assessment is a report, following ASTM Standards, that identifies recognized
Continue Reading Revision to ASTM Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process

By Edward V. Arnold

Seyfarth Synopsis: On June 1, 2020, the Criminal Division of the US Department of Justice (DOJ) released an updated guidance document for white-collar prosecutors on the evaluation of corporate compliance programs. The document, entitled “Evaluation of Corporate Compliance Programs,” updates a prior version issued in April 2019, and seeks to better assist prosecutors in assessing
Continue Reading Department of Justice Issues Updated Guidance on Evaluation of Corporate Compliance Programs

By Benjamin D. BriggsJames L. Curtis, and Craig B. Simonsen

Seyfarth Synopsis: OSHA’s enforcement budget increase to drive increase in 2021 inspections. 

The OSHA FY 2021 Congressional Budget Justification shows that in FY 2020 OSHA will receive an additional $12.7 million in funding that it will use to increase its Compliance Safety and Health Officer ranks
Continue Reading OSHA FY 2021 Congressional Budget Anticipates More Inspections to Come

By Mark A. Lies, II and Adam R. Young

Seyfarth Synopsis: OSHA facility visits and corresponding employee interviews can be a vexing scenario. OSHA employee interviews are a source of OSHA monetary citations. Unfortunately, most employers do not realize this potential source of liability and do not prepare their employees for the interviews. In their recent article on the
Continue Reading OSHA Employee Interviews-Leveling the Playing Field

By Jeryl L. Olson, Ilana R. MoradyKay R. Bonza, and Craig B. Simonsen

Seyfarth Synopsis:  On December 20, 2019, the National Defense Authorization Act for Fiscal Year 2020 (NDAA) was signed into law, including provisions for adding certain per- and polyfluoroalkyl substances (PFAS) to the EPA’s Toxic Release Inventory (TRI) list of reportable chemicals under
Continue Reading NDAttention – National Defense Authorization Act (NDAA) Adds Per- and Polyfluoroalkyl Chemicals to TRI

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 and Craig B. Simonsen

Seyfarth Synopsis: OSHA has just released the Agency’s enforcement and compliance inspection numbers, which show a “significant increase” over 2018.

The U.S. Department of Labor’s Occupational Safety and Health Administration’s (OSHA) released fiscal year (FY) 2019 inspection numbers, that show an increase over last year — from 32,023 in FY 2018


Continue Reading OSHA Inspection Numbers Increased in FY 2019

By Jeryl L. Olson, Patrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis:  EPA, in an Advance Notice of Proposed Rulemaking, requests comments on adding certain per- and polyfluoroalkyl substances (PFAS) to the TRI chemical list.

The U.S. Environmental Protection Agency (EPA) has asked industry stakeholders to provide comments on a proposal to add per- and polyfluoroalkyl
Continue Reading EPA Advance Notice of Proposed Rulemaking on Per- and Polyfluoroalkyl Chemicals

By James L. Curtis and Craig B. Simonsen

Seyfarth Synopsis: OSHA has just updated its “Protecting Temporary Workers” website, for staffing agencies and their clients (i.e., host employers). The page reminds these employers that they are jointly responsible for a  temporary employee’s safety and health .

We have blogged previously about OSHA’s enforcement activities and guidance documents
Continue Reading OSHA Releases Two New Temporary Worker Guidance Documents