OSHA’s Local Emphasis Program for Midwest Food Manufacturers [Webinar Recording]

On Wednesday, March 1, 2023, Conn Maciel Carey hosted a special bonus webinar in our 2023 OSHA Webinar Series regarding OSHA’s LEP for Midwest Food Manufacturers.

Presented by
Conn Maciel Carey LLP with Special Guest

 Steve Hawkins
(Former Head of Tennessee OSHA)

OSHA is now conducting inspections in Illinois (and Ohio) as part of a new Local Emphasis Program (LEP) for the Food Manufacturing Industry announced in late 2022. This LEP empowers Illinois OSHA offices to inspect food manufacturing and processing sites with a focus on machine guarding hazards, the employer’s hazardous energy control program, and the sanitation program (hazard communication and Group LOTO). OSHA has the ability under this LEP to conduct inspections for all referral and complaints, formal or non-formal, which contain allegations of potential worker exposure to serious hazards associated with operating food production machinery or performing service, maintenance, and sanitation tasks on food processing and ancillary equipment.

Establishments can be selected for an inspection even if they have an exemplary safety record, have not been the subject of any complaints, and have not recently reported a serious incident. This discussion covered what to expect and how to prepare your company for an OSHA inspection.

Attendees heard directly from FDR Safety’s Steve Hawkins, former Head of Tennessee OSHA, and Aaron Gelb, Head of Conn Maciel Carey’s Midwest OSHA Practice. Together they answered the following questions: Continue reading

[Webinar] OSHA’s Local Emphasis Program for Midwest Food Manufacturers

On Wednesday, March 1, 2023 at 10 a.m. CST / 11 a.m. EST, join us for a special bonus webinar in Conn Maciel Carey’s 2023 OSHA Webinar Series regarding OSHA’s LEP for Midwest Food Manufacturers.

Presented by
Conn Maciel Carey LLP with Special Guest

 Steve Hawkins
(Former Head of Tennessee OSHA)

OSHA is now conducting inspections in Illinois (and Ohio) as part of a new Local Emphasis Program (LEP) for the Food Manufacturing Industry announced in late 2022. This LEP empowers Illinois OSHA offices to inspect food manufacturing and processing sites with a focus on machine guarding hazards, the employer’s hazardous energy control program, and the sanitation program (hazard communication and Group LOTO). OSHA has the ability under this LEP to conduct inspections for all referral and complaints, formal or non-formal, which contain allegations of potential worker exposure to serious hazards associated with operating food production machinery or performing service, maintenance, and sanitation tasks on food processing and ancillary equipment.

Establishments can be selected for an inspection even if they have an exemplary safety record, have not been the subject of any complaints, and have not recently reported a serious incident. Join us for this discussion about what to expect and how to prepare your company for an OSHA inspection.

Attendees will hear directly from FDR Safety’s Steve Hawkins, former Head of Tennessee OSHA, and Aaron Gelb, Head of Conn Maciel Carey’s Midwest OSHA Practice. Together they will answer the following questions: Continue reading

OSHA Launches Regional Emphasis Program Focused on Storage Tank Cleaning Operations

By Aaron R. Gelb

On August 2, 2021, OSHA announced a new Regional Emphasis Program (“REP”) focused on transportation tank cleaning operations in the rail and truck shipping industries.  This is the second REP launched in Region 5 in less than a month; on June 14, 2021, OSHA commenced an REP to address hazardous noise levels in the Midwest. Employers who perform tank cleaning operations in Region 5, which covers Illinois, Ohio, Wisconsin, Michigan, Minnesota and Indiana, would be well-advised to dust off their copy of Conn Maciel Carey LLP’s OSHA Inspection Toolkit and take the necessary steps to ensure they are ready for the inspections that will begin before the end of the year.

Why Is OSHA Targeting Tank Cleaning Operations?

In the REP and accompanying press release, OSHA places a special emphasis on the dangers posed by the exposure to toxic fumes from cleaning chemicals or stored products that can build up inside a storage tank, as well as risks of fire or explosion when a worker must handle volatile materials in confined spaces.  Additionally, OSHA warns that the workers cleaning these tanks may “face many serious and potentially deadly hazards caused by toxic fumes from chemicals, decaying crops, waste and other substances that can expose workers to suffocation, fires and explosions.” OSHA also highlighted several fatal accidents that occurred in the Midwest, noting that Region 5 has investigated 23 worker deaths and 97 incidents in the transportation and tank cleaning industries since 2016.  According to OSHA, the hazards most often found during these inspections involved the failure to prevent the inhalation of harmful substances and to follow procedures for permit-required confined space requirements.

Which Employers Will Be Targeted? Continue reading

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 the Walking Working Surfaces Standard (the regulation covering slips, trips and falls).  It also published a controversial Electronic Injury Data Submission Rule, two new occupational health exposure standards for silica and beryllium, and brought the U.S. Hazard Communication Standard (the chemical right-to-know regulation) more in line with the United Nation’s Globally Harmonized System of Classification and Labeling of Chemicals.  To name a few.

But, as a new administration took the reigns at the Department of Labor, many wondered what would be the fate of these “midnight rules”?  While many agency regulations have been subject to additional rulemaking (or even rule-rescinding), as expected given Pres. Trump’s promise for deregulation, others have remained untouched.  This webinar will review the status of these OSHA Rules and where they may be headed.

Participants in this webinar learned about:

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Low Hanging Grapes – Cal/OSHA Standards Frequently Cited Against Winemakers

By Andrew J. Sommer and Lindsay A. DiSalvo

With the harvest upon us in California wine country, now is a great time to remind wineries and vineyards operating within the Golden Gate of those Cal/OSHA standards most often cited against this industry.  The California Division of Occupational Safety and Health (Cal/OSHA), which is charged with enforcing the state’s workplace safety standards, frequently cites wine industry businesses for failing to comply with several California-unique standards, cal-osha-wine-5such as the heat illness prevention rule and chemical right-to-know hazard communication requirements, as well as failing to comply with confined space and respiratory protection standards. We highlight these key Cal/OSHA standards and their impact on the wine industry.

Vineyards Vexed by Heat Illness Prevention Standard

California has adopted a Heat Illness Prevention Standard (§3395), which initially in 2005 was an emergency regulation. DOSH considers enforcement of the heat illness prevention standard to be a “special emphasis” and, as such, during every compliance inspection involving work sites that may be subject to this requirement, Cal/OSHA inspectors are expected to inquire about and evaluate employers’ Heat Illness Prevention Plan. This is an area of particular scrutiny in the wine industry, where vineyard employees frequently work outdoors, often in high heat conditions. Continue reading

New GHS Hazard Communication Standard: Roll-out Issues [Webinar Recording]

On Wednesday, May 11, 2016, Kathryn M. McMahon and Dan C. Deacon of Conn Macial Carey’s national OSHA Practice Group presented a webinar regarding the final roll-out of OSHA’s new GHS Hazard Communication Standard as part of the Firm’s 2016 OSHA Webinar Series.

Perhaps the most significant safety related regulatory reform during the Obama Administration has been the amended Hazard Communication Standard, bringing OSHA’s chemical Right-to-Know regulation more in line with the United Nation’s Globally Harmonized System of Classification and Labeling of Chemicals (“GHS”).  The new GHS HazCom standard fundamentally changes how employers must classify chemicals in the workplace, and requires all new chemical labels and Safety Data Sheets (formerly MSDSs).

The new GHS HazCom Standard had a seemingly long roll-out period, but time has flown by, and many of the key deadlines under the new rule have already past, and the final deadlines are now upon us.

This webinar explained the new Hazard Communication standard, identified some of the key issues with the new HazCom rule that have surfaced during the roll-out, and explained what employers need to do to come into compliance.  Participants learned about the following:

  •  Background about OSHA’s new GHS Hazard Communication Standard
  • Important elements of the new rule that employers need to know
  • Key implementation deadlines and enforcement deferrals
  • Developing issues uncovered during the roll-out of the new rule
  • Best practices for coming into compliance with the new GHS HazCom Standard

Click here to view a recording of the webinar.

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2015 OSHA Webinar Series – Archive of Recordings

Webinar Series 1
Today’s OSHA has increased enforcement to levels never seen before, from increased inspections and citations to dramatically higher penalties, from more criminal referrals to a heavy dose of public shaming.  It is more important than ever to be prepared. This complimentary webinar series has been designed to give employers the tools they need to avoid becoming an OSHA-enforcement poster child.
We have recorded and will continued to record each of the webinars, and as we move through the year and conduct these webinars, we are pleased to provide links below to the recordings.  There are also links below to the registration pages for the remaining webinars in the series.  Check out the completed webinars and plan to join us for all or some of the rest of the series.

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