It may be more entertaining to describe heated disagreement between employers, OSHA and unions, but areas of tacit agreement are more significant, at least when it comes to guaranteeing worker safety.
OSHA has limited resources and needs data to effectively target the use of those resources, so attendees were generally positive about the results of the first year of the Severe Injury Reporting requirements, 1904.39.
Allen Smith, J.D., the manager of workplace law content for SHRM. ( @SHRMlegaleditor) recently asked three attorneys, including me, to set out our wishes and cautions for OSHA in 2014, and then wrote a good (and short!) article. My responses are below, along with some comments from some construction safety experts, but please read Allen’s complete article. Allen generates good content.
After several years of received employer’s requests, OSHA’s Directorate of Enforcement Programs (DEP) issued a memorandum detailing the removal criteria for those employers currently under OSHA’s Severe Violator Enforcement Program (SVEP). This memorandum provides employers guidance on how to be removed from the SVEP, a process that has been unclear since the program was first implemented.