OSHA Publishes Employer Injury and Illness Data Collected Under the E-Recordkeeping Rule

By Eric J. Conn, Dan C. Deacon, and Beeta B. Lashkari As the world continues to focus its attention on all things COVID-19 related – especially as the Centers for Disease Control and Prevention learns more and more about the virus and updates its guidelines — earlier this month, OSHA quietly published a treasure trove … Continue reading OSHA Publishes Employer Injury and Illness Data Collected Under the E-Recordkeeping Rule

REMINDER: February 1, 2020 Deadline to Prepare, Certify, & Post OSHA 300A Annual Summaries of Work-Related Injuries: 5 Common Mistakes Employers Make

By Lindsay A. DiSalvo, Dan C. Deacon, and Eric J. Conn This is your yearly reminder about the important February 1st deadline to prepare, certify and post your OSHA 300A Annual Summary of workplace injuries and illnesses, for all U.S. employers, except those with ten or fewer employees or those whose NAICS codes are in … Continue reading REMINDER: February 1, 2020 Deadline to Prepare, Certify, & Post OSHA 300A Annual Summaries of Work-Related Injuries: 5 Common Mistakes Employers Make

Delinquent State OSH Plans, Particularly Cal/OSHA, Catch-up with Fed OSHA’s E-Recordkeeping Rule

By Eric J. Conn and Dan C. Deacon When fed OSHA promulgated the Final Rule to “Improve Tracking of Workplace Injuries and Illnesses” (aka the E-Recordkeeping Rule) in 2016, it built into the Rule a mandate that all State Plans adopt substantially identical requirements to the final E-Recordkeeping Rule within six months after its publication.  … Continue reading Delinquent State OSH Plans, Particularly Cal/OSHA, Catch-up with Fed OSHA’s E-Recordkeeping Rule

2019 Update on OSHA’s E-Recordkeeping and Significant Injury Reporting Rules [Webinar Recording]

On February 12, 2019 Lindsay DiSalvo and Dan Deacon from Conn Maciel Carey LLP’s national OSHA Practice presented a webinar regarding: “Updates About OSHA’s E-Recordkeeping and Significant Injury Reporting Rules.“ OSHA’s controversial E-Recordkeeping Rule has been challenged and criticized by stakeholders since its inception, and finally, in January 2019, the Trump Administration unveiled its Final … Continue reading 2019 Update on OSHA’s E-Recordkeeping and Significant Injury Reporting Rules [Webinar Recording]

OSHA’s New Site-Specific Targeting Enforcement Program [Webinar Recording]

On March 19, 2019 Amanda Walker, Aaron Gelb and Dan Deacon of Conn Maciel Carey LLP‘s national OSHA Practice presented a webinar regarding: “OSHA’s New Site-Specific Targeting Enforcement Program.“ More than two years after OSHA published the E-Recordkeeping Rule, the agency finally revealed some of its plans for how it will utilize employers’ 300A injury … Continue reading OSHA’s New Site-Specific Targeting Enforcement Program [Webinar Recording]

Delinquent State OSH Agencies Adopt E-Recordkeeping; Calif. Employers to Submit 2017 Injury Data by Year End

By Andrew Sommer, Megan Shaked, and Dan Deacon As we have reviewed previously on the OSHA Defense Report, federal OSHA’s Rule to “Improve Tracking of Workplace Injuries and Illnesses” (aka the E-Recordkeeping Rule) requires small employers that operate in certain “high hazard industries” and all large employers to proactively submit their electronic injury and illness … Continue reading Delinquent State OSH Agencies Adopt E-Recordkeeping; Calif. Employers to Submit 2017 Injury Data by Year End

BREAKING NEWS: OSHA Issues Final Amended Rule Scaling Back Electronic Injury Recordkeeping

By Eric J. Conn and Dan C. Deacon Yesterday OSHA announced and today OSHA officially published its Final Rule amending its Electronic Recordkeeping Rule.  After years of advocacy for change to (or to rescind) OSHA’s controversial Obama-era rule to “Improve Tracking of Workplace Injuries and Illnesses” (aka the E-Recordkeeping Rule), and a transition to the de-regulatory platform … Continue reading BREAKING NEWS: OSHA Issues Final Amended Rule Scaling Back Electronic Injury Recordkeeping

OSHA’s New Site-Specific Targeting Inspection Initiative

By Dan C. Deacon and Eric J. Conn After years of wondering how OSHA could possibly manage and use data collected under the 2016 E-Recordkeeping Rule, the agency has finally revealed its hand.  Last month, OSHA launched its Site-Specific Targeting 2016 (“SST-16”) inspection plan, which outlines the agency’s strategy to target establishments for inspection based … Continue reading OSHA’s New Site-Specific Targeting Inspection Initiative

The Due Date for Round 2 of Injury Data Submissions under OSHA’s E-Recordkeeping Rule is Upon Us

The July 1, 2018 deadline for large employers (250+ employees at a single work site) and smaller employers (20-249 employees) in certain so-called “high hazard industries” to submit injury and illness data to OSHA is less than a week away.  We have been tracking closely the Trump Administration’s treatment of OSHA’s new E-Recordkeeping and Anti-Retaliation … Continue reading The Due Date for Round 2 of Injury Data Submissions under OSHA’s E-Recordkeeping Rule is Upon Us

REMINDER: Feb. 1st Deadline to Prepare, Certify, & Post OSHA 300A Annual Summaries of Work Related Injuries: 5 Common Mistakes Employers Make

By Lindsay A. DiSalvo, Dan C. Deacon, and Eric J. Conn Check out an updated 2020 version of this article here. This is your yearly reminder about the important February 1st deadline to prepare, certify and post your OSHA 300A Annual Summary of workplace injuries and illnesses, for all U.S. employers, except those with ten or … Continue reading REMINDER: Feb. 1st Deadline to Prepare, Certify, & Post OSHA 300A Annual Summaries of Work Related Injuries: 5 Common Mistakes Employers Make

Tug-of-War Between Fed OSHA and the State OSH Plans over the E-Recordkeeping Rule

By Eric J. Conn, Dan Deacon, and Beeta Lashkari A fascinating jurisdictional tug-of-war has broken out between federal OSHA and a few fed OSHA approved State OSH Programs, in relation to OSHA’s Final Rule to “Improve Tracking of Workplace Injuries and Illnesses” (aka the E-Recordkeeping Rule).  The E-Recordkeeping Rule requires large employers and smaller employees … Continue reading Tug-of-War Between Fed OSHA and the State OSH Plans over the E-Recordkeeping Rule

OSHA Announces Proposed Changes to its Controversial E-Recordkeeping Rule — Industry Comments Are Needed

By the OSHA Practice at Conn Maciel Carey LLP After years of advocacy for change to (or to rescind) OSHA’s controversial Obama-era rule to “Improve Tracking of Workplace Injuries and Illnesses” (aka the E-Recordkeeping Rule), and a transition to the de-regulatory platform of the Trump Administration, OSHA has taken a step (hopefully just the first step) … Continue reading OSHA Announces Proposed Changes to its Controversial E-Recordkeeping Rule — Industry Comments Are Needed

Latest on OSHA’s E-Recordkeeping and Anti-Retaliation Rule [Webinar Recording]

On May 15, 2018, Amanda Strainis-Walker and Dan C. Deacon of Conn Maciel Carey’s national OSHA Practice Group presented a webinar: “The Latest on OSHA’s E-Recordkeeping and Anti-Retaliation Rule.“ OSHA’s controversial Electronic Recordkeeping and Anti-Retaliation Rule was promulgated in May 2016.  Despite a barrage of negative comments during the rulemaking, multiple enforcement deferrals, and two … Continue reading Latest on OSHA’s E-Recordkeeping and Anti-Retaliation Rule [Webinar Recording]

Fate of Midnight Obama-era OSHA Rules [Webinar Recording]

On June 18, 2019, Kate McMahon, Micah Smith, Dan Deacon, and Beeta Lashkari of Conn Maciel Carey‘s national OSHA Practice presented a webinar regarding the “Fate of Various Obama-era OSHA Rules.” In the final days (and even hours) of the Obama Administration, OSHA promulgated several significant regulatory changes.  For example, after several decades, it updated … Continue reading Fate of Midnight Obama-era OSHA Rules [Webinar Recording]

State Plan Implementation of OSHA’s E-Recordkeeping Data Submission Rule

By Eric J. Conn and Dan C. Deacon OSHA’s Final Rule to “Improve Tracking of Workplace Injuries and Illnesses” (aka the E-Recordkeeping Rule) requires employers of  certain sizes that fall into certain categories to proactively submit electronic injury and illnesses data to OSHA through its new web portal – the “Injury Tracking Application.”  The new … Continue reading State Plan Implementation of OSHA’s E-Recordkeeping Data Submission Rule

In the Wake of Criticism of the E-Recordkeeping Anti-Retaliation Rule, OSHA Issues New “Guidance”

By Eric J. Conn and Beeta B. Lashkari On May 11, 2016, OSHA published its Final Rule for injury and illness recordkeeping electronic data submissions — what we refer to as the E-Recordkeeping Rule. The rule fundamentally changed OSHA’s long-standing injury and illness recordkeeping program by requiring injury and illness data to be proactively shared … Continue reading In the Wake of Criticism of the E-Recordkeeping Anti-Retaliation Rule, OSHA Issues New “Guidance”

OSHA’s Policy of Public Shaming: Status and Future under the Trump Admin. [Webinar Recording]

On August 21, 2018, Eric J. Conn and Aaron R. Gelb of Conn Maciel Carey’s national OSHA Practice Group presented a webinar: “OSHA’s Policies of Public Shaming: the Status under the Trump Admin. and the Future.“ As a small budget agency, OSHA has long looked for policies that will leverage individual enforcement actions to have … Continue reading OSHA’s Policy of Public Shaming: Status and Future under the Trump Admin. [Webinar Recording]

Important Cal/OSHA Issues that California Employers Must Track [Webinar Recording]

On July 10, 2018, Conn Maciel Carey attorneys Andrew J. Sommer, Eric J. Conn, and Megan S. Shaked presented a webinar: “Key Cal/OSHA Issues that California Employers Must Track.” The state of California’s Division of Occupational Safety and Health, better known as Cal/OSHA, is perhaps the most aggressive and enforcement-heavy approved state OSH Program in … Continue reading Important Cal/OSHA Issues that California Employers Must Track [Webinar Recording]

Fate of Obama-Era OSHA Regulations and Enforcement Policies Under the Trump Administration

By Eric J. Conn and Micah Smith In the final days and weeks of the Obama Administration, OSHA promulgated several significant regulatory changes.  For example, after several decades, it finally completed its update to the Walking Working Surfaces Standard (the regulation covering slips, trips and falls).  It also published a controversial Electronic Injury Data Submission … Continue reading Fate of Obama-Era OSHA Regulations and Enforcement Policies Under the Trump Administration

Announcing Conn Maciel Carey’s 2019 OSHA Webinar Series

We are now two years into the Trump Administration, and we have seen a mixed bag of changes in the OSHA enforcement and regulatory landscape. We have watched some late Obama-era OSHA rules get repealed by the Congressional Review Act or delayed and amended through deregulatory rulemaking.  We have seen some efforts to boost up … Continue reading Announcing Conn Maciel Carey’s 2019 OSHA Webinar Series

OSHA’s E-Recordkeeping Deadline Extended Again – Stroke of Midnight December 31, 2017

By Eric J. Conn The December 15, 2017 deadline for large employers and small employers in certain “high hazard industries” to submit injury and illness data to OSHA has just passed, but it is not too late to submit injury data without being cited by OSHA for missing the deadline.  OSHA announced today that will … Continue reading OSHA’s E-Recordkeeping Deadline Extended Again – Stroke of Midnight December 31, 2017

Status of OSHA’s Electronic Recordkeeping Rule – 1st Deadline (Dec. 15) to Submit Injury Data is Upon Us

By Eric J. Conn and Dan C. Deacon The December 15, 2017 deadline for large employers and small employers in certain “high hazard industries” to submit injury and illness data to OSHA is less than a month away.  We have been tracking closely the Trump Administration’s treatment of OSHA’s new E-Recordkeeping and Anti-Retaliation Rule, and … Continue reading Status of OSHA’s Electronic Recordkeeping Rule – 1st Deadline (Dec. 15) to Submit Injury Data is Upon Us

Announcing Conn Maciel Carey’s 2020 OSHA Webinar Series

We are three years into the Trump Administration, and we have seen a mixed bag of change and business as usual at OSHA in enforcement and rulemaking. We watched late Obama-era OSHA rules get repealed, delayed, or amended and a modest boost in compliance assistance—the sort of policy shifts you expect to see in a … Continue reading Announcing Conn Maciel Carey’s 2020 OSHA Webinar Series

REMINDER: Feb. 1st Deadline to Certify and Post OSHA 300As: Four Common Mistakes Employers Make

By Eric J. Conn Check out an updated 2020 version of this article here. This is your annual reminder about the important annual February 1st deadline to prepare, certify and post your OSHA 300A Annual Summary of workplace injuries and illnesses, for all U.S. employers, except those with ten or fewer employees or those whose … Continue reading REMINDER: Feb. 1st Deadline to Certify and Post OSHA 300As: Four Common Mistakes Employers Make

The Latest on OSHA’s Electronic Recordkeeping and Anti-Retaliation Rule [Webinar Recording]

On September 12, 2017, Eric J. Conn and Dan C. Deacon of Conn Maciel Carey’s national OSHA Practice presented a webinar regarding the Latest on OSHA’s Electronic Recordkeeping and Anti-Retaliation Rule. OSHA’s controversial Electronic Injury and Illness Recordkeeping data submission rule, along with new Anti-Retaliation elements, has thus far survived a barrage of negative stakeholder comments … Continue reading The Latest on OSHA’s Electronic Recordkeeping and Anti-Retaliation Rule [Webinar Recording]