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 organizations, manufacturers, hotel groups, and many others, need to be aware of four new Occupational Safety and Health Administration (OSHA) enforcement trends that have important corporate-wide consequences:
- A rise in follow-up inspections and Repeat violations at sister facilities within a corporate family;
- OSHA's pursuit of company-wide abatement provisions in settlement agreements;
- OSHA's requests for enterprise-wide relief from the Occupational Safety and Health Review Commission; and
- Implementation of OSHA's Severe Violator Enforcement Program (SVEP), which incorporates elements of each of the above.
The full article explains these four initiatives and how OSHA is implementing them.