By Brent I. ClarkJames L. CurtisAdam R. YoungDaniel R. Birnbaum, and Craig B. Simonsen

Seyfarth Synopsis: On June 28, 2021, OSHA published a Compliance Directive, DIR 2021-02 (CPL 02), covering inspection procedures and enforcement policies for the Emergency Temporary Standard for COVID-19. The new directive sheds light on OSHA’s thought process
Continue Reading OSHA Adopts Directive for Inspection Procedures and Enforcement Policies for COVID-19 ETS, Shedding Light on Enforcement Priorities Related to Medical Removal Pay Provisions

By Brent I. ClarkJames L. CurtisAdam R. YoungA. Scott HeckerPatrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis: On March 12, 2021, OSHA published its COVID-19 National Emphasis Program – Coronavirus Disease 2019 (COVID-19), DIR 2021-01(CPL-03) (3-12-21).  The Directive lays-out OSHA’s policies and procedures implementing a National Emphasis Program
Continue Reading OSHA Adopts COVID-19 National Emphasis Program

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, OSHA Updates Emphasis Program on
Continue Reading OSHA Updates National Emphasis Program on Amputations in Manufacturing Industries

By Brent I. Clark and Craig B. Simonsen

White Square Button with Arm AmputeeLast week OSHA issued its updated National Emphasis Program on Amputations (NEP). Instruction CPL 03-00-019 (June 30, 2015). Take that juxtaposed against OSHA’s citation in a recent case where on his first day on the job a 21-year-old employee suffered severe burns and the loss of four fingers.

National Emphasis Program on


Continue Reading OSHA Updates Emphasis Program on Amputations – Cites Employer and Places It on Severe Violators List

By James L. Curtis and Craig B. Simonsen

OSHA has just released a new Instruction for its Field Operations Manual that describes policies and procedures for implementing a National Emphasis Program to identify and reduce or eliminate the incidence of adverse health effects associated with occupational exposure to isocyanates.

The Instruction, National Emphasis Program – Occupational Exposure to Isocyanates


Continue Reading OSHA Issues National Emphasis Program on Occupational Exposure to Isocyanates

By James L. Curtis and Craig B. Simonsen

The Occupational Safety and Health Administration (OSHA) recently announced a new National Emphasis Program (NEP) for chemical facilities.  The NEP is intended to protect workers from catastrophic releases of highly hazardous chemicals. The NEP replaces OSHA’s 2009 pilot Chemical Facility National Emphasis Program (Pilot Program) which established policies and procedures for inspecting


Continue Reading OSHA National Emphasis Program for Chemical Facilities