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MSHA Citations Upheld by Administrative Law Judges Before April 3, 2018 May Be Invalid

Over the last few years, there has been debate regarding whether ALJs are “inferior officers” under the Appointments Clause of the Constitution. This provision provides that officers, including inferior officers, may only be...more

OSHA Issues Guidance on How to Cite Employers That Failed to Electronically Submit Injury and Illness Information

On February 21, the Occupational Safety and Health Administration (OSHA) issued new interim enforcement procedures, provided below, regarding failure to submit electronic injury and illness records. In 2016, OSHA adopted a...more

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