D.C. Circuit Rejects Industry Challenges to Silica Rule and Remands to OSHA for Further Consideration on Medical Removal Protections

by Beveridge & Diamond PC

Beveridge & Diamond PC

The U.S. Court of Appeals for the District of Columbia rejected all industry challenges to an Obama-era rule on worker exposure to respirable crystalline silica in a December 22, 2017 ruling.  In its written decision, the court held that OSHA’s Final Rule for Exposure to Respirable Crystalline Silica (the “Silica Rule”) was supported by substantial evidence and rejected the industry claims that the rule was too stringent.  In response to a union challenge, the court agreed with the union claim that OSHA did not adequately explain its decision to omit medical removal protections from the final version of the Silica Rule, and remanded to OSHA to reconsider or further explain its decision on medical removal protections.  As a result of the Court’s ruling, construction employers must remain in compliance with all of the Silica Rule’s requirements, and general industry and maritime employers must prepare to come into compliance by June 23, 2018.


OSHA issued the Silica Rule on March 25, 2016, during the final year of the Obama administration.[1]  The rule amended the standards for workplace exposure to respirable crystalline silica that OSHA had adopted in 1971 by significantly lowering the permissible exposure limit (PEL) to 50 micrograms per cubic meter (µg/m3) of air as an eight-hour time-weighted average and requiring employers to implement additional protective measures.  These include exposure assessment, exposure control, respiratory protection, medical surveillance, hazard communication, and recordkeeping.  The Silica Rule took effect on June 23, 2016.  Construction employers were originally required to be in compliance with the Silica Rule by June 23, 2017, but OSHA extended that deadline to September 23, 2017.  General industry and maritime employers are required to come into compliance by June 23, 2018, though hydraulic fracturing employers have until June 23, 2021 to implement engineering controls.  Our previous alert outlining the Silica Rule can be accessed here.

Industry Challenges

Multiple industry groups challenged the Silica Rule on the basis that it was too stringent.  Principally, industry asserted that OSHA’s decision to lower the PEL to 50 µg/m3 to reduce the risk of health impairment was not supported by substantial evidence and that the Silica Rule was technologically and economically infeasible.  Industry also asserted that OSHA violated the Administrative Procedure Act and that OSHA lacked substantial evidence to support ancillary provisions of the rule relating to the confidentiality of medical examinations and the use of dry cleaning methods.

Union Challenges

Several unions and worker advocacy groups also challenged the Silica Rule, but on the basis that is was not stringent enough.  Specifically, they challenged the rule’s requirement that medical surveillance for construction workers be provided only if the employee has to wear a respirator for 30 days for one employer in a one-year period and OSHA’s decision to omit medical removal protections for employees from the Final Rule. 

The Court’s Decision

The D.C. Circuit heard oral argument on the challenges to the rule on September 26, 2017 and issued a per curium opinion on December 22, 2017.[2]  In the written opinion, the court rejected all of the industry challenges to the Silica Rule, leaving in place the requirements that industry deemed to be too stringent.  The court rejected the challenge by unions and worker advocacy groups pertaining to medical surveillance, but agreed that OSHA failed to adequately explain its decision to omit medical removal protections from the rule.  Due to that finding, the court remanded the Silica Rule to OSHA to reconsider or further explain its decision on medical removal protections.  The court’s key findings are summarized below.

Permissible Exposure Limit

The court upheld OSHA’s decision to lower the PEL to 50 µg/m3, rejecting the industry challenges to OSHA’s risk assessment methodology, determination that long-term silica exposure above the PEL presents a significant risk of adverse health effects, and decision to include the brick industry within the scope of the rule (and thus subject to the lowered PEL). 

With regard to OSHA’s risk assessment methodology, the court held that OSHA’s use of a no-threshold assumption (i.e., the assumption that if there is an exposure level at which workers would not be expected to develop adverse health effects, that level is below the PEL) was supported “with studies showing that risks of lung cancer exist at 36 µg/m3 and 10 µg/m3, levels lower than the PEL.”  While the court noted that industry “point[ed] to studies it claims not only show a threshold exists but also show a threshold exists above the PEL,” it determined that “OSHA has explained why it rejected Industry’s side of the debate, presented the other side of the debate, and supported it with evidence from which a reasonable conclusion could be made, as OSHA did here, that no threshold of safe exposure to silica exists.”   The court commented that it “cannot choose a particular side as the right one in a scientific dispute.”

Similarly, the court held that OSHA’s decision not to use a dose-rate effect in the model (meaning that OSHA assessed health risks based on the cumulative amount of silica exposure without accounting for the intensity of exposures) was reasonable.  According to the court, OSHA “took competing evidence, favored one side, and explained the reasons for its decision.”

With regard to OSHA’s determination on adverse health effects, the court held that “OSHA’s findings with respect to silicosis and NMRD [non-malignant respiratory disease] mortality, lung cancer mortality, and silicosis morbidity are sufficient to uphold the requisite threshold finding of a significant risk of material health impairment at the [prior] 100 µg/m3 PEL that will be reduced at the new PEL.”  The court did not address OSHA’s findings with regard to renal disease, explaining that “OSHA, through its supported findings on the other three adverse health effects, has met its burden to show that the Silica Rule regulates a significant risk of material harm.”

As to including the brick industry in the scope of the Silica Rule and making it subject to the lower PEL, the court found that OSHA “explained its rationale” for relying on a single study that supported that decision.  Accordingly, the court upheld the inclusion of that industry in the Silica Rule.

Technological Feasibility

The court held that OSHA’s determination that “there was a reasonable possibility that the new standard could be achieved by the typical employer in most operations and was thus feasible” was supported by substantial evidence.  It rejected the industry’s contention that the rule was infeasible in foundries, hydraulic fracturing, and construction.   The court noted that “[the industry] objections do not collectively undermine OSHA’s overall finding of feasibility for the typical firm in most operations nor do they meaningfully call into question the evidence on which OSHA relied.” 

With respect to foundries, the court found that “OSHA has shown that the typical firm can meet the standard in most operations,” because OSHA relied on over 1,000 data points from nearly 100 foundries and a study by the American Foundry Society showing “that the new PEL is being met in most foundry job categories.”  The court explained that “Industry’s evidence suggests, at most, that compliance will be infeasible for some foundries or in some operations,” and “[e]ven assuming that industry is correct . . . such isolated examples of infeasibility are, under our standard of review, insufficient to defeat OSHA’s finding of feasibility for the typical foundry in most . . . operations.”

With respect to hydraulic fracturing, the court held that the industry challenge to OSHA’s feasibility finding failed, “even if sufficient controls do not yet exist” to reduce exposures below the PEL in that industry.  The court explained that “[b]ecause the OSH Act is a technology-forcing statute, OSHA can also force industry to develop and diffuse new technology to meet its standard.”  Further, the court noted that “OSHA [has] identified controls, some currently available and others under development, that promise to sufficiently reduce exposure.”

With respect to construction, the court upheld OSHA’s determination of feasibility on the basis that construction employers can comply with the standard by implementing the controls listed in Table 1 of the standard and OSHA’s finding that “most employers would follow Table 1 for most tasks” and “that it would be technologically feasible for them to do so given the ready availability of Table 1 controls.”  The court also upheld OSHA’s determination that compliance was feasible for tasks not appearing on Table 1.  As with the other industries, the court held that “Industry’s insistence that compliance is infeasible for some firms in some operations some of the time cannot upend our deference to OSHA’s well-supported finding that compliance is feasible for the typical firm in most operations.”

Economic Feasibility

The court held that OSHA’s finding of feasibility was supported by substantial evidence because OSHA had determined that the annualized costs of compliance were less than one percent of revenue or ten percent of profit within each industry.  As with the issue of technological feasibility, the court rejected the industry contentions that the rule was infeasible in foundries, hydraulic fracturing, and construction.

In particular, the court rejected the industry contentions that OSHA’s finding of economic feasibility for foundries was flawed because OSHA assumed an even apportionment of costs between those required for compliance with the prior PEL and those required to further reduce exposure from the prior PEL to the new PEL; it used a per-worker assessment of costs instead of looking at costs on a per-facility basis; it excluded the cost of certain controls mentioned in its technology feasibility analysis; and it did not reflect the best available evidence.  The court determined that “OSHA’s well-supported estimates and considered rejection of alternative evidence are sufficient to justify its finding of economic feasibility.”

The court also rejected the industry contentions that for hydraulic fracturing, OSHA failed to appropriately consider declining oil prices and excluded the costs of some of the controls discussed in the technological feasibility analysis.  The court determined that “[g]iven the inherent uncertainty in forecasting future economic conditions, OSHA’s thorough consideration of industry’s concerns, and the delayed implementation timeline, OSHA’s finding that the rule is economically feasible in hydraulic fracturing finds ample support in the record.” The court also explained that “OSHA estimated only the typical cost of compliance and need not consider every single control discussed.”

Finally, the court rejected the industry contentions that in construction, the costs estimated for certain industry subgroups were too low, the assumption of a 150-day working year was too short and understated costs, and that the assumption of costs ignored that employers will not be able to follow Table 1 all of the time.  The court held that “OSHA’s ultimate conclusion was well supported” and that OSHA appropriately considered the “typical compliance costs for the ‘typical’ employer.”

Medical Removal Protection

With respect to the union challenge on medical removal protections, the court held that “OSHA was arbitrary and capricious in declining to require MRP [medical removal protection] for some period when a medical professional recommends permanent removal, when a medical professional recommends temporary removal to alleviate COPD symptoms, and when a medical professional recommends temporary removal pending a specialist’s determination.”  In reaching this decision, the court emphasized that “OSHA has not explained why MRP – critical in some standards to protect workers from having to decide between learning about their health and avoiding economic loss – is not equally critical to protect workers from having to choose between disclosing their health issues (and thus preserving their health) and avoiding economic loss.”  Accordingly, the court remanded to OSHA to reconsider or further explain its decision to omit medical removal protections in the aforementioned circumstances.

The court did, however, reject the union claim that OSHA should have included medical removal protections for employees who are unable to wear a respirator.  According to the court, the unions failed to meet “their burden to show that MRP would provide more than a de minimis benefit in this circumstance.”


Because the court rejected the industry challenges to the Silica Rule in their entirety, the rule remains in effect.  This means that the obligations of construction employers, who were required to be in compliance by September 23, 2017, remain unchanged and that general industry and maritime employers must continue to work toward the June 23, 2018 compliance deadline.  Additionally, because the court remanded the Silica Rule for further consideration on medical removal protection, employers should be prepared for future OSHA rulemaking notices on this issue.

[1] 81 Fed. Reg. 16286 (Mar. 25, 2016).

[2] North America’s Building Trades Unions v. Occupational Safety & Health Administration, No. 16-1105 (D.C. Cir. Dec. 22, 2017).  Slip opinion available here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Beveridge & Diamond PC | Attorney Advertising

Written by:

Beveridge & Diamond PC

Beveridge & Diamond PC on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.