By Eric Conn, Head of the OSHA Practice Group
We recently had an article published by the Washington Legal Foundation entitled "OSHA Continues Trend of Informally Imposing New Rules." The article expanded on an earlier post here on the OSHA Law Update Blog regarding OSHA's attempts to circumvent Formal Notice and Comment Rulemaking by changing regulatory requirements through interpretation letters, directives, and enforcement memoranda. Here is a link to the original post.
Below is an excerpt from the expanded article, published this week in Washington Legal ...
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