OSHA Enforcement

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Many businesses across the country have implemented on-site occupational health clinics to address occupational injuries and illnesses, as well as address common employee health needs.  While on-site occupational health clinics can provide many benefits for employers and their employees, they also can present significant compliance challenges for companies in the areas of employee benefits, privacy, leave management, and, of course…

On March 1, 2012, OSHA announced a change to its organizational structure related to its Whistleblower Protection Program (WPP).  The WPP will now report directly to the Assistant Secretary of OSHA, currently Dr. David Michaels, instead of the Director of the Directorate of Enforcement Programs.

The WPP is in charge of investigating workplace retaliation complaints made by…

Employers covered by OSHA’s recordkeeping rule must prepare and post the OSHA Form 300A, “Summary of Work-Related Injuries and Illnesses,” by February 1 and keep the form posted until April 30.  The form must be posted at each establishment covered, in a conspicuous place where notices to employees are customarily posted.

After the form is completed, but before…

Over the last several months, OSHA has continued – and expanded – its practice of publicizing “Industry/Hazard Alerts” on its web site. These Alerts are designed to notify employers in certain industries of hazards that are of particular concern to the Agency. In part, OSHA is using this technique to ensure industry recognition and knowledge of hazards…

During a particularly busy September, OSHA issued three new enforcement directives that employers should review:

Enforcement Procedures for Investigating or Inspecting Workplace Violence Incidents.  On September 8, 2011, OSHA issued its first ever directive instructing compliance officers on how to conduct inspections that occur as a result of workplace violence incidents.  The directive "clarifies and expands" OSHA policies in…

As sports fans begin their annual football watching, rivalry matches, and tailgating, most forget that sporting teams are often “employers” or associated with an “employer.” Like other employers, Colleges and Universities, School Districts, and Professional Sports Teams must comply with Occupational Safety and Health Act (“OSHA”) standards.

These employer obligations recently were spotlighted in a…

In a case of first impression, the Occupational Safety and Health Review Commission has established a three-part test for employers claiming third-party safety and health audits protected from disclosure by the attorney-client privilege. Applying underlying legal principles of privilege to the technical area of safety and health assessments, the Commission has set forth steps that all…