Workforce Bulletin

This week, Washington Legal Foundation published an article  regarding OSHA's New Enterprise-Wide Approach to Enforcement, authored by EBG attorneys Eric J. Conn and Alexis M. Downs.  The article expands on a February 2012 post entitled "Enterprise Enforcement: OSHA's Attack on Employers with Multiple Locations," here on the OSHA Law Update Blog.

The gist of the article and the prior blog post is that companies that operate multiple facilities in different locations, such as national retail and grocery chains, grain cooperatives, large national nursing and medical care ...

By Alexis M. Downs and Eric J. Conn

Companies that operate multiple facilities in different locations, such as national retail stores, grocery chains, manufacturers, and hotel chains, need to be aware of three new OSHA enforcement trends with enterprise-wide consequences:

• A rise in follow-up inspections and Repeat violations at sister facilities within a corporate family;
• OSHA’s increasing pursuit of company-wide abatement provisions in settlement agreements; and
• OSHA’s recent requests for enterprise-wide relief from the Occupational Safety and Health Review ...