By Mark A. Lies, II,  Brent I. ClarkAdam 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. 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 will allow the California Division
Continue Reading California Enacts New Record-Keeping Mandates in Response to Changing Federal Program

By James L. CurtisKay R. Bonza, and Craig B. Simonsen

Seyfarth Synopsis:  OSHA today published a proposed rule to amend the injury and illness recordkeeping rules by rescinding the requirement for establishments with 250 or more employees to electronically submit information from OSHA Forms 300 and 301.  OSHA is amending provisions of the “Improve Tracking of
Continue Reading Roller Coaster Rulemaking: OSHA Publishes Proposed Rule to Reduce Injury and Illness Electronic Reporting Requirements

By James L. CurtisPatrick D. Joyce, and  Craig B. Simonsen

Seyfarth Synopsis: OSHA reminded specific employers on Monday that the deadline for electronically submitting their 2017 Form 300A data to OSHA is July 1, 2018.

Electronic submission of 2017 Form 300A data is due by July 1, 2018 for establishments with 250 or more employees that
Continue Reading Reminder – Specific Employers are Required to Electronically Submit 2017 Injury and Illness Data by July 1

By Mark A. Lies, IIAdam R. Young, and Craig B. Simonsen

Seyfarth Synopsis: A recent Eastern District of Wisconsin case held that an OSHA 11(c) retaliation claim will survive summary judgment where the employer failed to comply with its own investigation procedures.

In Acosta v Dura-Fibre, No. 17-C-589, 27 OSHC 1179 (ED Wis. May 30,
Continue Reading Failure To Follow Company’s Own Internal Procedures Can Be Used Against It In OSHA 11(c) Retaliation Case

By Brent I. ClarkJames L. Curtis, Benjamin D. Briggs, Mark A. Lies, IIIlana R. Morady, Patrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis:  OSHA’s has indicated in a news release that it “will continue accepting 2016 OSHA Form 300A data through the Injury Tracking Application (ITA) until midnight on December
Continue Reading OSHA Accepting 2016 Electronically Submitted Injury, Illness Reports through December 31 AND Intends to Significantly Revise the Rule

By Brent I. ClarkJames L. CurtisBenjamin D. BriggsMark A. Lies, IIIlana R. Morady, and Patrick D. Joyce,

Seyfarth Synopsis:  OSHA’s has indicated in a news release that it “intends to publish a notice of proposed rulemaking to reconsider, revise, or remove portions” of the “Improve Tracking of Workplace Injuries
Continue Reading OSHA Intends to “Reconsider, Revise, or Remove Portions” of Injury and Illness E-Reporting Rule Next Year

By Brent I. ClarkJames L. CurtisBenjamin D. BriggsMark A. Lies, IIIlana R. Morady, and Patrick D. Joyce

Seyfarth Synopsis:  As most employers probably know by now, OSHA’s revised recordkeeping rule requires certain employers to electronically file injury and illness data with OSHA. Originally the reporting deadline was July 1, 2017.
Continue Reading OSHA Extends E-Reporting Deadline to December 15, 2017

By James L. Curtis and Craig B. Simonsen

Seyfarth Synopsis: OSHA has proposed to delay the reporting compliance deadline, until December 1, 2017,  for certain employers to electronically file injury and illness data.

Under OSHA’s revised recordkeeping rules certain employers are required to electronically file injury and illness data with OSHA.  As we noted previously in our blog, the
Continue Reading OSHA Delays Electronic Filing Date for Injury and Illness Records Until December 1, 2017

By James L. Curtis

iStock_000004162096LargeSeyfarth Synopsis: OSHA has announced that it will be proposing a delay to the July 1, 2017 deadline for certain employers to electronically file injury and illness data.

Under OSHA’s revised recordkeeping rules certain employers are required to electronically file injury and illness data with OSHA.  As we noted previously in our blog, the rule
Continue Reading Breaking News: OSHA Proposes to Delay Electronic Submission of Injury and Illness Records