News & Analysis as of

Administrative Law Judge (ALJ) Employer Liability Issues Occupational Safety and Health Administration

Fisher Phillips

Hospital and Management Company Both Liable for Same OSHA Violation at Shared Worksite: What Can You Do to Avoid “Single-Employer”...

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A recent federal appeals court ruling illustrates the risks of “single-employer” liability for OSHA citations for common business arrangements today. These involve separate companies that perform different functions but share...more

Fisher Phillips

Frequently Asked Questions for Employers About OSHA (Updated for 2025)

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Even the most experienced employers are sure to have questions from time to time about the nation’s workplace safety agency – the Occupational Safety and Health Administration (OSHA). That’s where we come in. The Fisher...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Recent Federal OSHA Workplace Violence Case Provides a Road Map on General Duty Clause in Workplace Violence Cases

On October 25, 2021, a customer named Jacob Bergquist, with a history of violating the Boise Towne Square Mall’s firearms ban, opened fire at the mall. The shooting in the Idaho mall led to the deaths of a Professional...more

Jackson Lewis P.C.

Challenging OSHA Violations at Occupational Safety and Health Review Commission Is Worth the Effort

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It is more important than ever that employers understand the serious long-term, non-monetary consequences of settling or accepting Occupational Safety and Health Administration (OSHA) citations. One danger of settling OSHA...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

OSHRC Unanimously Vacates Machine-Guarding Citation, and then Two More

On September 21, 2020, the Occupational Safety and Health Review Commission (OSHRC) unanimously vacated a machine-guarding citation on the ground that the injured operator had deliberately bypassed the guard that the employer...more

Seyfarth Shaw LLP

Commission Confirms that Employers May Have Employee Misconduct Where Training of Safety Rule Was Verbal and On-the-Job

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Seyfarth Synopsis: Commission’s approval of undocumented training provides blueprint for employee misconduct claims for employers going forward....more

Morgan Lewis - Up & Atom

Whistleblower Complaint Dismissed Based on Employer’s Reasonable Steps to Ensure Employee Safety

The US Department of Labor (DOL) Administrative Review Board (ARB) recently issued a decision in the case of Evans v. US Environmental Protection Agency, ARB Case No. 2017-0008, ALJ Case No. 2008-CAA-00003 (ARB Mar. 17,...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

No Good Deed Goes Unpunished: D.C. Circuit Holds Employer That Failed to Implement Its Own Safety Program Violated the General...

The United States Court of Appeals for the District of Columbia Circuit recently issued a decision that should be of concern to every employer and safety professional. The case involved an employer that had ambitious but...more

Seyfarth Shaw LLP

Fifth Circuit Provides New Grounds for Employers to Pursue Late Notices of Contest to OSHA Citations

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Seyfarth Synopsis: The United States Court of Appeals for the Fifth Circuit held that an untimely Notice of Contest to an OSHA citation was permissible due to “excusable neglect” by the employer, on account of a single...more

Hahn Loeser & Parks LLP

OSHRC’s Recent Ruling Provides Important Guidance on Limiting Controlling Employer Liability on Multi-Employer Worksites

On Feb. 1, 2019, the Occupational Safety and Health Review Commission (OSHRC) reversed an OSHA citation issued to Suncor Energy (U.S.A.) Inc., as the controlling employer, for a fall protection violation. In this ruling, the...more

Hahn Loeser & Parks LLP

OSHRC’s recent ruling provides important guidance for employers on heat exposure and the general duty clause

On Feb. 28 the Occupational Safety and Health Review Commission (OSHRC) reversed a citation issued to A.H. Sturgill Roofing, Inc. for the heat-related death of an employee, finding that all of the elements of proof of the...more

Seyfarth Shaw LLP

Commission Decisions Confirm that Employers Must Take Action to Protect Employees from Workplace Violence

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Seyfarth Synopsis: In recent decisions—including Secretary of Labor v. Integra Health Management, Inc., No. 13-1124 (OSHRC Mar. 4, 2019)—the Occupational Safety and Health Review Commission (OSHRC) has upheld violations of...more

Seyfarth Shaw LLP

Final Update From The 2019 ABA Occupational Safety And Health Law Committee Midwinter Meeting

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We attended the ABA Occupational Safety and Health Law Meeting last week in San Juan, Puerto Rico. Present are representatives from the OSH Review Commission, the MSH Review Commission, and the Solicitor’s Office. ...more

Seyfarth Shaw LLP

Fifth Circuit Last To Uphold OSHA’s Multi-Employer Worksite Doctrine

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Seyfarth Synopsis: We had blogged previously that OSHA appealed an Administrative Law Judge (ALJ) ruling that severely limited OSHA’s Multi-Employer Worksite Doctrine and citation of a “controlling employer” general...more

Fisher Phillips

Web Exclusive - May 2018: The Top 14 Labor And Employment Law Stories

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It’s hard to keep up with all the recent changes to labor and employment law. While the law always seems to evolve at a rapid pace, there have been an unprecedented number of changes for the past few years—and this past month...more

Parker Poe Adams & Bernstein LLP

Ignorance of OSHA Requirements Does Not Preclude Willful Violation

Employers found to have committed repeat or willful violations of Occupational Safety and Health Administration standards are subject to citation penalties of 10 times those for ordinary violations, and in some cases...more

Seyfarth Shaw LLP

OSHA Review Commission Back in Business

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Seyfarth Synopsis: The Occupational Safety & Health Review Commission (Review Commission) issued two orders this month — the first we have heard from the Review Commission since April 27, 2017. The orders followed, on...more

Littler

DOL Flip-Flop: SOX's Anti-Retaliation Provisions Apply to Overseas Conduct After All

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In a late-August decision with potentially far-reaching implications for foreign and multinational employers, the United States Department of Labor Administrative Review Board (ARB) held that the Sarbanes-Oxley Act's (SOX)...more

Seyfarth Shaw LLP

“Controlling Employer” Doctrine Reviewed and Vacated by OSHRC Law Judge

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Seyfarth Synopsis: In an interesting outcome, an OSHRC Administrative Law Judge recently vacated a citation to an alleged “controlling employer” based on 5th Circuit precedent – despite being contrary with OSHA policy and...more

Fisher Phillips

Safety Agency Applies Federal Law To Bar Employer Safety Violation Citation - Agency’s Application of 5th Circuit Appeals Court...

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The federal agency that reviews OSHA safety violation cases, also known as the OSH Review Commission, recently adopted the decision of one of its Administrative Law Judges who applied 5th Circuit precedent to reject a safety...more

Alston & Bird

Employee Benefits & Executive Compensation Advisory: The ACA: New Concerns for Employer Plan Sponsors Under the Fair Labor...

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The Affordable Care Act (ACA) anti-retaliation provisions have been in effect for several years, but have so far largely gone unnoticed. Now that employees can get financial assistance through the Health Insurance...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Eighth Circuit Rejects OSHA’s Interpretation of Guarding Standard in Worker Fatality Appeal

On October 13, 2015, the Eighth Circuit Court of Appeals ruled in favor of Loren Cook in an 8–4 en banc decision in the carefully-watched machine guarding case of Perez v. Loren Cook Company, Eighth Circuit Court of Appeals,...more

Seyfarth Shaw LLP

Eighth Circuit Rejects OSHA’s Attempt to Expand the Scope of its Machine Guarding Standard

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In a review of an Occupational Safety & Health Review Commission (OSHRC) decision, the U.S. Court of Appeals for the Eighth Circuit ruled this week to vacate a $490,000 penalty for failure to employ machine guards to prevent...more

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