News & Analysis as of

Interpretive Letters Occupational Safety and Health Administration

Constangy, Brooks, Smith & Prophete, LLP

OSHA Is Still Enforcing 4-Hour Rule For OSHA 300 Logs, But Reins In Area Offices On “Double Reporting”

With the number of on-site inspections and citations declining during the 2020 pandemic, it appeared that the Occupational Safety and Health Administration began issuing more citations for recordkeeping-related...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Medical...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a January 2nd interpretive letter a question regarding the application of the Hazardous Materials Regulations (“HMR”) to...more

Kilpatrick

OSHA Rescinds Policy Allowing Union Access to Nonunionized Facilities

Kilpatrick on

On April 25, 2017, the Occupational Safety and Health Administration (“OSHA”) rescinded a four-year-old policy allowing unions to participate in OSHA safety and health inspections at nonunionized facilities. Under a...more

Fisher Phillips

OSHA Withdraws Fairfax Memo

Fisher Phillips on

OSHA has provided notice, in the context of an on-going federal lawsuit, (National Federation of Independent Businesses v. Dougherty, N.D. Tex., No. 16-2568, 4/27/17), that it has rescinded the interpretation letter and...more

Seyfarth Shaw LLP

Business Group Challenge to OSHA Interpretation Survives Motion to Dismiss and Leaves Serious Questions About Continued Viability...

Seyfarth Shaw LLP on

Seyfarth Synopsis: In a victory for employers, a Texas federal court has refused to dismiss a lawsuit challenging an OSHA interpretation under which non-employee union representatives were permitted to participate in OSHA...more

Jackson Lewis P.C.

Alcohol-Related Workplace Injuries Recordable, OSHA Says

Jackson Lewis P.C. on

Employers are not exempt from the Occupational Safety and Health Administration’s reporting rule for on-the-job injuries linked to alcohol intoxication even though the injured employee’s consumption of alcoholic beverages...more

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