The federal safety agency recently unveiled new initiatives aimed at “impactful enforcement . . . in the form of increased citations and penalties.” Changes to how the Occupational Safety and Health Administration (OSHA) uses...more
Until 2015, it was the practice of the Occupational Safety and Health Administration (OSHA) to look back only three years to establish “repeat” violations under the Occupational Safety and Health Act (OSH Act). In 2015, OSHA...more
Four years ago, in a letter of interpretation addressed to Steve Sallman of the United Steelworkers of America (the Sallman Letter), the federal Occupational Safety and Health Administration (OSHA) changed more than 35 years...more
U.S. OSHA recently released its new Field Operations Manual (“Manual”), with several changes of particular importance to oil and gas operations. The Manual is the field guidance that directs the work of OSHA’s Compliance,...more
U.S. OSHA recently released its new Field Operations Manual (“Manual”). The Manual is the field guidance that directs the work of OSHA’s Compliance, Safety & Health Officers (“CSHOs”) commonly referred to as “OSHA...more
The Occupational Safety and Health Administration (OSHA) has just released a substantial update to its Field Operations Manual (FOM), CPL 02-00-159 (October 1, 2015). The FOM is a reference document for OSHA field personnel...more