By Jeryl L. OlsonKay 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

By Brent I. ClarkJames 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

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.

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

By Joshua M. HendersonIlana R. MoradyJames L. Curtis, and Craig B. Simonsen

Seyfarth Synopsis: On November 6, 2018, the California Office of Administrative Law approved Cal/OSHA’s emergency regulation for the electronic submission of CY 2017 Form 300A on Occupational Injuries and Illnesses.  Covered employers will be required to submit

By Joshua M. HendersonIlana R. MoradyJames L. Curtis, and Craig B. Simonsen

Seyfarth Synopsis: CalOSHA published a news release TODAY, on a new emergency regulation for the electronic submission of CY 2017 Form 300A on Occupational Injuries and Illnesses.  CalOSHA submitted the rule yesterday, and will allow public comments

By: Brent I. ClarkJames L. Curtis, Kay R. Bonza, and Craig B. Simonsen

Seyfarth SynopsisThe Occupational Safety and Health Administration (OSHA) has initiated a Site-Specific Targeting 2016 (SST-16) Program using the injury and illness information electronically submitted by employers to initiate OSHA inspections.  OSHA Directive No. 18-01, CPL 02

By Joshua M. HendersonIlana R. Morady, and Craig B. Simonsen

Seyfarth Synopsis:  Last week, Governor Brown signed into law Assembly Bill No. 2334, Occupational Injuries and Illness, Employer Reporting Requirements, and Electronic Submission.

A six-month statute of limitations period currently applies to all citations issued under Cal/OSHA. Assembly Bill 2334