OSHA violations characterized as Repeat or Willful can now carry penalties as high as $156,259 per citation. You may be wondering, however, what exactly leads OSHA to characterize a violation as Repeat or Willful, and why are they important beyond their high-dollar cost? No doubt, you heard that OSHA changed the Severe Violator Enforcement Program (SVEP) in September 2022, making it easier to place employers into the program and saddle them with all the negative consequences associated with it even though the citations which prompted the referral are not yet final orders. Raising the stakes even higher, OSHA announced changes to its “Instance-By-Instance” or “Egregious” enforcement policy in January 2023 that will undoubtedly lead to a significant increase in the number of multi-million-dollar enforcement actions.
This webinar explained the legal standard for Repeat, Willful and Egregious violations, the potential consequences for receiving them, and how OSHA’s enforcement policies have resulted in a significant increase in the frequency with which we see these aggravated characterizations.
Participants in this webinar learned:
- The legal standards OSHA must meet to establish Repeat and Willful violations
- Background and details about OSHA’s Egregious / Instance-By-Instance Enforcement Policy
- Policy changes that have resulted in more Repeat and Egregious violations
- Impacts of these aggravated characterizations, including qualifying into the Severe Violator Enforcement Program, facing criminal charges, etc.
- Tips for employers to avoid Repeat and Willful citations
If you would like to be registered for the entire 2023 series, click here to send us an email request and we will get you registered.
This was the 5th webinar event in Conn Maciel Carey LLP’s 2023 OSHA Webinar Series. Click here to view our full schedule and detailed program descriptions for all of the webinars scheduled for the 2023 OSHA Webinar Series.
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