By Adam R. Young, Daniel R. Birnbaum, Matthew A. Sloan, James L. Curtis, and Craig B. Simonsen
Seyfarth Synopsis: OSHA has announced new rules requiring a broad range of employers to electronically submit additional injury and illness information in 2024.
Despite many delays and lawsuits from affected stakeholders, OSHA announced today that it will
Continue Reading OSHA Expands Electronic Injury/Illness Data Reporting and Recordkeeping Requirements
By Adam R. Young, A. Scott Hecker, Patrick D. Joyce, James L. Curtis, and Craig B. Simonsen
Seyfarth Synopsis: OSHA requires employers to upload certain information to its Injury Tracking Application (ITA) each year by March 2. This year, OSHA is transitioning employer login information from individual accounts to “login.gov” and all employers must connect their
Continue Reading Employers Must Update Injury Tracking Application (ITA) Account and Submit OSHA Form 300A Summaries Through Login.govBy Brent I. Clark, James L. Curtis, Adam R. Young, A. Scott Hecker, Patrick D. Joyce, and Craig B. Simonsen
Seyfarth Synopsis: As we previously blogged, the federal Occupational Safety and Health Administration issued a notice of proposed rulemaking to expand requirements for employers to submit OSHA forms via its Injury Tracking Application
Continue Reading OSHA Aims to Boost Injury Reporting Rule Compliance with its Injury Tracking Application Enforcement Program
By James L. Curtis, Adam R. Young, Mark A. Lies, II, Ilana R. Morady, Patrick D. Joyce, and Craig B. Simonsen
Seyfarth Synopsis: OSHA intends to restore an Obama-era requirement that employers submit OSHA 300 logs and OSHA 301 reports electronically, ostensibly to improve the Agency’s data and to potentially target employers with injury
Continue Reading Reverse Course! OSHA Again to Require Employers to Electronically Submit OSHA 300 Logs and 301 Reports
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. Briggs, James L. Curtis, Patrick D. Joyce, and Craig B. Simonsen
Seyfarth Synopsis: On April 10, 2020, OSHA released new interim guidance to Compliance Safety and Health Officers (CSHOs) for enforcing the requirements of 29 CFR Part 1904 with respect to recording occupational illnesses, related specifically to cases of the Coronavirus Disease (COVID-19).
Continue Reading OSHA Publishes Enforcement Guidance on Recording Cases of COVID-19
By Jeryl L. Olson, Kay R. Bonza, and Craig B. Simonsen
Seyfarth Synopsis: The U.S. Chemical Safety and Hazard Investigation Board (CSB) has proposed new accidental chemical release reporting requirements that are broad in scope and would cover additional chemicals, lower threshold quantities, and more areas within a stationary source than existing regulatory release reporting requirements already
Continue Reading ANOTHER Chemical Release Reporting Obligation????
By Brent I. Clark, James L. Curtis, Patrick D. Joyce, Adam R. Young, and Craig B. Simonsen
Seyfarth Synopsis: Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in specific industries with historically high rates of occupational injuries and
Continue Reading OSHA Tweets Out a Reminder – Summary of Work-Related Injuries and Illnesses Form 300A for Calendar Year 2019 are Due March 2
By Ilana R. Morady and James L. Curtis
Seyfarth Synopsis: Effective January 1, 2020, Cal/OSHA is revising its injury reporting obligations to be more aligned with the injury reporting obligations under federal OSHA.
As most employers with California operations know, Cal/OSHA has unique injury/illness reporting requirements that differ from the Federal OSHA reporting requirements. These differences are important, and
Continue Reading Changes to Cal/OSHA Reporting Requirements Go Into Effect January 1, 2020
By Brent I. Clark, Adam R. Young, and Craig B. Simonsen
Seyfarth Synopsis: According to several states that have sued the Occupational Safety and Health Administration in Federal Court, the Agency did not provide sufficient justification to rollback the electronic reporting rule for large employers. Complaint, State of New Jersey, et al., v. Acosta, No.
Continue Reading Six States Sue – Alleging that Trump Administration Electronic Reporting Rule is Unlawful