On April 16, 2020, OSHA issued an Enforcement Memorandum addressing new challenges employers face in meeting OSHA regulatory obligations. In a nutshell, the Enforcement Memorandum provides that when employers have made good faith attempts but are unable to comply with testing, training, reviews, and audits because of the Coronavirus pandemic, OSHA “shall take such efforts into strong consideration in determining whether to cite a violation.” Alternatively, if an employer cannot demonstrate any efforts to comply or why compliance could be a greater hazard, OSHA may issue a citation...