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
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 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
By Brent I. Clark, James L. Curtis, Benjamin D. Briggs, Matthew A. Sloan, and Craig B. Simonsen
Seyfarth Synopsis: OSHA has just been sued for removing the requirements for establishments with 250 or more employees to electronically submit information from OSHA Form 300 (Log of Work-Related Injuries and Illnesses), and OSHA Form 301 (Injury and
Continue Reading On And On We Go – Coalition Groups Sue DOL for the Rollback Rule
By James L. Curtis, Benjamin D. Briggs, Brent I. Clark, Adam R. Young, and Craig B. Simonsen
Seyfarth Synopsis: OSHA has just issued its final rule that removes the requirement for establishments with 250 or more employees to electronically submit information from OSHA Form 300 (Log of Work-Related Injuries and Illnesses), and OSHA Form 301
Continue Reading OSHA Issues New Rule that Companies are Not Required to Submit OSHA 300 and 301 Forms Electronically
By Joshua M. Henderson, Ilana R. Morady, James 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 their Forms to Federal OSHA
Continue Reading Emergency Regulation Approved! Electronic Submission of CY 2017 Form 300A Required by December 31, 2018 for California Employers
By Joshua M. Henderson, Ilana R. Morady, James 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 until Tuesday, October 30th, with
Continue Reading Attention California Employers! Cal/OSHA Issues Notice of Emergency Regulation for Electronic Submission of CY 2017 Form 300A by December 31, 2018
By: Brent I. Clark, James L. Curtis, Kay R. Bonza, and Craig B. Simonsen
Seyfarth Synopsis: The 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, effective October 16, 2018.
By Mark A. Lies, II, Brent I. Clark, Adam R. Young, and Craig B. Simonsen
Seyfarth Synopsis: OSHA has just issued a Standard Interpretation clarifying the Obama-era guidance that prohibited incentive programs and circumscribed post-incident drug testing; “Clarification of OSHA’s Position on Workplace Safety Incentive Programs and Post-Incident Drug Testing Under 29 C.F.R. §1904.35(b)(1)(iv).”
We previously
Continue Reading OSHA Clarifies Position on Lawful Post-Incident Drug Testing and Reverses Course on Safety Incentive Programs
By Joshua M. Henderson, Ilana 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 will allow the California Division
Continue Reading California Enacts New Record-Keeping Mandates in Response to Changing Federal Program