By James L. Curtis and Craig B. Simonsen
The Department of Homeland Security (DHS) has published an Advance Notice of Proposed Rulemaking (ANPR) intended to “mature” the Chemical Facility Anti-Terrorism Standards (CFATS) program, and to identify ways to make the program more effective in achieving its regulatory objectives. 79 Fed. Reg. 48693 (August 18, 2014).
The CFATS program was intended…
Continue Reading DHS Proposing to “Mature” Chemical Facility Anti-Terrorism Standards Program
By Jeryl L. Olson and Craig B. Simonsen
The U.S. Environmental Protection Agency, in response to Executive Order 13650, Improving Chemical Facility Safety and Security (EO), is publically, through a Federal Register notice, requesting public comments on “potential revisions” to its Risk Management Program. 79 Fed. Reg. 44604 (July 31, 2014).
This request is part of an effort highlighted in…
Continue Reading EPA Request for Information on Clean Air Act Accidental Release Prevention Program
By James L. Curtis and Craig B. Simonsen
The teenage summer job working at the local store is a rite of passage in most communities. Almost everyone has held a summer job at some point in their life. However, given the disturbing rise in workplace violence, teenagers can be swept up in hostile situations and end up facing down angry,…
Continue Reading OSHA Administrator Blogs on Retail Industry’s Need for Workplace Violence Training and Protections
By James L. Curtis and Craig B. Simonsen
Representatives from the U.S. Environmental Protection Agency, the Occupational Safety and Health Administration, and the Department of Homeland Security spoke today at the Air and Waste Management Association’s Annual Conference, on their collaboration on chemical facility safety and security.
The conference session speakers included Mathy Stanislaus, EPA’s Office of Solid Waste…
Continue Reading EPA, OSHA, and DHS are Collaborating on Chemical Facility Safety and Security
By James L. Curtis and Craig B. Simonsen
The U.S. Environmental Protection Agency, the U.S. Department of Labor, and the Department of Homeland Security recently published their first joint Report for the President, “Actions to Improve Chemical Facility Safety and Security – A Shared Commitment.” June 6, 2014.
The Report was issued after recent catastrophic chemical facility incidents…
Continue Reading Federal Report on “Actions to Improve Chemical Facility Safety and Security – A Shared Commitment”
By Brent I. Clark, Kerry M. Mohan, and Craig B. Simonsen
In a remarkable announcement, OSHA Administrator Dr. David Michaels has just issued a Decision on Referring Untimely 11(c) Complainants to the National Labor Relations Board (Decision), OM-14-60 (May 21, 2014).
This announcement comes just weeks after Dr. Michaels testified at a hearing before the Senate Subcommittee on…
Continue Reading OSHA Decision to Refer “Untimely 11(c) Complaints” to the NLRB
By James L. Curtis, Mark A. Lies, II, and Craig B. Simonsen
In an announcement last week, OSHA noted that falls from elevation, accounting for 269 of the 775 construction fatalities recorded in 2012, continues to be a leading cause of death for construction workers.
Dr. David Michaels, The Assistant Secretary of Labor for Occupational Safety and Health…
Continue Reading Falls in Construction: OSHA Announces “National Safety Stand-Down”
By James L. Curtis, Meagan Newman, and Craig B. Simonsen
OSHA has just released its Site-Specific Targeting 2014 (SST-14) Program (Program) Directive, which replaces its Site-Specific Targeting 2012 that we previously blogged about, and was in effect during 2013. Directive No. 14-01 (CPL 02).
The OSHA SST-14 Program is intended to direct its enforcement resources to workplaces where…
Continue Reading OSHA Issues Site-Specific Inspections Targeting Directive for 2014
By James L. Curtis and Craig B. Simonsen
The Federal Railroad Administration (FRA) is amending the Federal Track Safety Standards to promote the safety of railroad operations by enhancing rail flaw detection processes. 79 Fed. Reg. 4234 (January 24, 2014).
After review and consideration of public comments submitted on the FRA’s proposed rule on Track Safety Standards, Improving Rail Integrity…
Continue Reading Federal Railroad Administration Issues Final Federal Track Safety Standards
By Brent I. Clark, Kerry M. Mohan, and Craig B. Simonsen
The U.S. Mine Safety and Health Administration (MSHA) recently sent three mining operations notices of a pattern of violations (POV) of health or safety standards under section 104(e) of the Federal Mine Safety and Health Act of 1977 (Mine Act). The MSHA POV screening this year was the…
Continue Reading MSHA Aggressive Enforcement Activities Under the Pattern of Violation Rules
