Severe Violator Enforcement Program

By Brent I. Clark and Craig B. Simonsen

shutterstock_206483089Thomas Galassi, Director of OSHA’s Directorate of Enforcement Programs, through a very short Memorandum (Memo), announced that OSHA has just added employers in the Oil and Gas Production Services and Drilling and Well Servicing industries to its High-Emphasis Hazards in the Severe Violator Enforcement Program.

We have written previously about steady growth
Continue Reading OSHA Adds “Upstream Oil and Gas” to List for Severe Violator Enforcement Program

By Benjamin D. Briggs, Ilana R. Morady, and Kerry M. Mohan

To cap off the winter ABA conference, on Friday the conference discussed recent OSHA Review Commission decisions involving deference given to the Secretary’s interpretation, heat illness, and combustible dust.

Chief Judges Rooney (OSHRC) and Lesnick (MSHRC) discussed ethical and professional behavior before the Court, reminding attorneys to
Continue Reading Update from the ABA OSHA/MSHA Conference

By James L. Curtis and Craig B. Simonsen

OSHA has recently posted to its website its Severe Violator Enforcement Program (SVEP) White Paper and concludes that “employers have been paying attention”.

The SVEP, which became effective on June 18, 2010, was intended to focus enforcement efforts on “recalcitrant employers” who demonstrate indifference to the health and safety of their employees

Continue Reading OSHA Publishes Severe Violator “White Paper”

By James L. Curtis and Craig B. Simonsen

The Occupational Safety and Health Administration (OSHA) has just published a Guidance on removing employers from the Severe Violator Enforcement Program (SVEP). As we noted in a previous blog, since the SVEP has been in effect over 300 employers have been designated as severe violators. However, until now, there has not

Continue Reading Procedures for Removal from the OSHA Severe Violator Enforcement Program List

By James L. Curtis and Craig B. Simonsen

In the two years since the start of the Occupational Safety and Health Administration’s (OSHA) Severe Violator Enforcement Program (SVEP), CPL 02-00-149 (June 18, 2010), the list of severe violators has grown considerably. The SVEP Directive defines severe violators as those “employers who have demonstrated indifference to their OSH Act obligations by

Continue Reading OSHA Severe Violator Enforcement Program Employers List Nearly Doubles