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OSHA Publishes General Industry Emergency Temporary Standard

OSHA’s long-awaited general industry COVID-19 emergency temporary standard (“ETS”) was officially published today and became effective immediately for employers in those states without “state OSHA” plans. However, employers...more

OSHA Publishes Its Advance Notice of Proposed Rulemaking for Heat Stress

On October 27, 2021, OSHA published an Advance Notice of Proposed Rulemaking (“ANPRM”) to initiate a comment period to gather diverse perspectives and expertise on heat stress issues such as heat stress thresholds, heat...more

NYS DOL Publishes Model Airborne Infectious Disease Exposure Prevention Plan Under HERO

On July 6, 2021, the Department of Labor for the state of New York published its model Airborne Infectious Disease Exposure Prevention Plan (the Model Plan) under the New York Health and Essential Rights Act (HERO), which was...more

NYS DOL Publishes Model Airborne Infectious Disease Exposure Prevention Plan Under HERO

On July 6, 2021, NYS DOL published its Airborne Infectious Disease Exposure Prevention Plan under the New York Health and Essential Rights Act (“HERO”), signed into law on May 5, 2021, Governor Cuomo. In addition to the...more

OSHA Issues Enforcement Guidance For Electronic Recordkeeping Rule And Promises Aggressive Enforcement

As discussed in a previous blog, covered employers were required to electronically submit 300A data for the calendar year 2020 between January 2, 2021, through March 2, 2021. In a recent standard interpretation dated May 6,...more

To Mask Or Unmask; That Is The Question

Every business in the United States has been asking itself these past few days whether to drop any requirements it may have for visitors or employees to wear face masks since the CDC changed its COVID-19 guidance related to...more

An Infectious Disease Prevention Plan And Workplace Safety Committee: Two New Significant Requirements Under New York’s HERO Act

On May 5, 2021, Governor Cuomo of New York signed the New York Health and Essential Rights Act (the “Act”) into law which amends the New York Labor Law. The Act creates occupational safety and health standards in the private...more

OSHA’s COVID-19 ETS Expected Soon – Too Little, Too Late?

On April 26, OSHA sent its COVID-19 emergency temporary standard (ETS) to the Office of Management and Budget’s Office of Information and Regulatory Affairs (OIRA) for review. OIRA is the regulatory “gatekeeper” that is...more

OSHA Adds a New Consideration for Employers Related to Adverse Reactions to Vaccines

It is probably safe to say that as more businesses continue to reopen without restrictions and there is increased availability to vaccine supplies, many employers are considering whether they want to implement a mandatory...more

Adverse Vaccine Reaction: An OSHA Recordable Event Or Not?

As more businesses reopen without restrictions and increased availability of vaccine supplies, many employers contemplate a mandatory vaccine policy. The decision turns on individualized facts to each organization, such as...more

Employers are being Cited by OSHA for Failing to Comply with the Respiratory Protection Standard and Not just Healthcare Industry...

Both federal and state OSHA regulators have been regularly citing employers for failure to comply with their respective respiratory protection standards in connection with COVID-19 inspections and these citations have not...more

OSHA Clarifies No Need For “Double” Reporting Of Related Injuries/Illnesses

Under OSHA’s Recording and Reporting Occupational Injuries and Illnesses regulation, employers are required to affirmatively notify OSHA when an employee suffers a work-related hospitalization, amputation, or loss of an eye...more

Odds Increase On OSHA Issuing COVID-19 Emergency Temporary Standards

Shortly after President Biden took office, he signed an Executive Order directing OSHA to, among other things, determine whether emergency temporary standards (ETS) on COVID-19 are necessary; and if so, to issue them by March...more

OSHA’s Return To Public Shaming

Prior to the Trump administration, OSHA commonly engaged in the practice of “public shaming.” In other words, if an OSHA investigation found a relatively serious safety violation, it would issue a press release identifying...more

Employment Law Now V-89- New OSHA Guidance on Covid-19 [Audio]

In today's episode, Mike Schmidt is joined by his colleague and the Chair of Cozen O'Connor's OSHA Practice Group, John Ho, to talk about the new guidance (finally?) issued by OSHA on the Covid-19 pandemic. What did the...more

What You Need To Know About OSHA’S Updated COVID-19 Guidance

On January 29, 2021, OSHA issued revised COVID-19 updated guidance for employers following an executive order issued by President Biden directing the agency to do so. The guidance contains many suggestions that employers are...more

OSHA Issues Revised COVID-19 Guidance: What It Means And What’s Next

Almost immediately after taking office, President Biden issued an Executive Order requiring OSHA to publish revised COVID-19 guidance for employers, among other things. The revised guidance contains many suggestions that...more

OSHA: Recordkeeping Reminder, Higher Penalties And 2021 Predictions

Happy New Year! A New Year means increased maximum penalties for OSHA citations. As of January 16, 2021, the maximum penalties for serious, other-than-serious and posting requirements is now $13,653 per violation; $13,653 per...more

Be Wary Of OSHA “Approved” PPE

OSHA’s long-standing position is that it does not approve or endorse particular products. Moreover, the determination of compliance with OSHA’s standards cannot be based on an evaluation of the equipment or devices alone....more

Injuries At Voluntary Charitable Events: Recordable Under OSHA?

It is that time of year again where many businesses provide their employees with the opportunity to participate in various charitable events in the spirit of giving. Doing so may raise a number of employment-related issues...more

OSHA’s Most Frequently Cited Standards In COVID-19 Investigations

With a new administration on the horizon, it seems likely OSHA may revisit whether it will issue emergency COVID-19 regulations, something Secretary of Labor Scalia has repeatedly stated is not necessary despite heavy...more

The Interplay Between OSHA And Wrongful Death, Tort, And Gross Negligence Claims In The COVID-19 Era

OSHA practitioners who have handled citations involving fatalities or severe injuries are most likely no strangers to considering how these citations including the alleged violation description might affect collateral...more

OSHA Does an Abrupt Turn In Issuing New Guidance on Recording COVID-19

On May 19, 2020, the Occupational Safety and Health Administration (OSHA) published revised enforcement guidance detailing when employers must record COVID-19 illnesses. ...more

OSHA Changes COVID-19 Recordkeeping Requirements For Employers (Again)

On May 19, 2020, the Occupational Safety and Health Administration (“OSHA”) published revised enforcement guidance detailing when employers must record COVID-19 illnesses. The new guidance reverses course on prior guidance...more

Understanding OSHA’s New Guidance On Recording COVID-19 Cases And Related Employee Privacy Concerns

On April 10, 2020, OSHA issued additional guidance for employers on their obligations to record COVID-19 cases. Prior to this guidance, OSHA made clear that COVID-19 cases may be recordable if a worker is infected as a...more

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