By James L. Curtis and Craig B. Simonsen

After nearly nine years since its proposed rulemaking began, including substantial controversy, hearings, and public comments, OSHA has finally adopted its 428 page updated “Electric Power Generation, Transmission, and Distribution” rules. 79 Fed. Reg. 20316 (April 11, 2014).

The existing rules, now being replaced, were originally adopted in November 1972, over 40…
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