Investigations/Inspections

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

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

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

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)

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,

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 —

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

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

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

Seyfarth SynopsisCintas Corporation has recently become the first company to reach 100 sites with OSHA’s Voluntary Protection Program (VPP) (Program) Star certification.

OSHA’s Voluntary Protection Program recognizes employers and workers in the private industry and

By Jeryl L. OlsonKay R. Bonza, and Craig B. Simonsen

Seyfarth Synopsis: New Illinois Office of State Fire Marshall (“OSFM”) regulations, (42 Ill. Reg. 10476, 10662-667, June 15, 2018, effective October 13, 2018), require that periodic operation and maintenance include recorded “walkthrough inspections” for underground storage tank (UST)