April 2010

OSHA has updated its Recordkeeping National Emphasis Program (NEP).  The NEP, initated originally in September, 2009, was designed to investigate whether, and to what extent, injuries and illnesses are being underreported by employers.  The original NEP, as well as the revision, targets employers with low rate establishments operating in historically high rate industries.  Click here for a Special

In moves designed to enhance the effectiveness of its enforcement activities, OSHA has unveiled a new “Severe Violator Enforcement Program” and a memorandum to Regional Administrators that has the effect of increasing penalties for employers receiving citations. These enhancements are further evidence of OSHA’s emphasis on enforcement and all employers must take note.

Severe Violator Enforcement

In a recently issued memorandum to Regional Administrators and State Plan Designees, OSHA has clarified its policy for citing the general industry personal protective equipment (PPE) standard, 29 CFR 1910.132(a), for failure to provide and use flame resistant clothing (FRC) in oil and gas well drilling, servicing, and production-related operations.  In the March 19 memorandum, OSHA provides

OSHA has embarked on a new National Emphasis Program (NEP) targeting hexavalent chromium in the workplace, along with other toxic substances found in conjunction with hexavalent chromium.  OSHA’s intent with the NEP is to "target workplaces with occupational exposures to hexavalent chromium" and certain other toxic substances (e.g., antimony, arsenic, cadmium, lead, iron oxide) to encourage compliance with applicable standards.