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On January 26, 2024, OSHA published a revised enforcement manual for Process Safety Management of Highly Hazardous Chemicals (“Manual”). The Manual reflect OSHA’s first revisions to its prior directive issued in 1994 which is specifically identified as cancelled and superseded by the Manual.

OSHA highlights significant changes in the Manual as:• Removal of the Appendix

Pursuant to the Federal Civil Penalties Inflation Adjustment Act, OSHA increases the maximum penalties for serious and other-than-serious violations from $15,625 per violation to $16,131 per violation. In addition, the maximum penalty for willful or repeat violations increased from $156,259 per violation to $161,323 per violation. The increases became effective as of January 16, 2024.

As we head into the New Year, it is a good time for businesses to review OSHA’s cold stress guidance (link below). OSHA reminds employers that monitoring the wind chill temperature and workers’ physical condition while performing tasks will help them assess cold stress exposure and assist them in developing strategies to ensure work can

Guest Author: Norm Keith, B.A.(Econ), J.D., LL.M. Mr. Keith is a leading management-side employment and labor lawyer, the author of 12 books, 8 of which deal with OHS, and is a senior partner at the law firm of KPMG Law LLP, and may be reached at: nkieth@kpmg.ca.

The enduring legal legacy of the Westray Mine

OSHA recently shared preliminary data for its Top 10 list in fiscal year 2023 which ended September 30, 2023. They are listed below in order of most frequently cited:

  • Fall Protection – General Requirements (1926.501)
  • Hazard Communication (1910.1200)
  • Ladders (1926.1053)
  • Scaffolding (1926.451)
  • Powered Industrial Trucks (1910.178)
  • Lockout/Tagout (1910.147)
  • Respiratory Protection (1910.134)
  • Fall Protection – Training
  • As technology evolves, unfortunately, so do ways to hack that technology. The recent cyberattacks in several casinos in Las Vegas are just one recent example of the growing concern of cyberattacks on businesses and the tremendous consequences and liability that may result from such attacks.Could OSHA be one such concern? At first blush, any direct

    According to a recent OSHA standard interpretation letter, probably yes. In the May 17, 2023 letter, an employee drove the company vehicle on a public roadway between service calls. As the employee approached a car accident, the driver who caused the accident entered the company’s vehicle, shot the employee, stole the vehicle, and fled the

    On July 17, 2023, OSHA released its final rule expanding its electronic recordkeeping and reporting requirements. As expected, the rule largely mimics OSHA’s 2022 proposal and takes effect January 1, 2024. The rule requires establishments with 100 or more employees in certain high-hazard industries, i.e., industry classification, to electronically submit information from their Form 300

    Creating a strong safety culture in a business has many components. It requires the commitment and participation of the executive management team and all supervisory and non-supervisory employees throughout the organization. A critical part of accomplishing this requires conducting internal and/or third-party safety and health audits on a routine basis and whenever business needs otherwise