Recent OSHA Final Rule on Recordkeeping Flouts D.C. Circuit Decision

The Occupational Safety and Health Administration (OSHA) announced last week a new final rule that purportedly “clarifies an employer’s continuing obligation to make and maintain an accurate record of each recordable injury and illness.&#… Read More
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D.C. Circuit Orders OSHA to Follow Notice and Comment Requirements When Imposing New Standards on Agricultural Retailers

A fundamental principle of administrative law is that federal agencies must provide the public with reasonable notice and the opportunity to comment on proposed administrative issuances that impose substantive obligations that did not previously exis… Read More
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OSHA and FSMA (No, Not FDA This Time)

You thought FDA was the only agency implementing the Food Safety Modernization Act (FSMA), well think again. The Occupational Safety and Health Administration (OSHA) promulgated a final rule that defines whistleblower protections for employees that d… Read More
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New EPA Worker Protection Standard for Farmworkers

On September 28, the Environmental Protection Agency (EPA) issued an advance publication of its revisions to the Worker Protection Standard (WPS) for farmworkers. The revised WPS imposes new requirements for farm owners to protect workers against the… Read More
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OSHA Interim Final Rule Outlines New Whistleblower Protections for Food Company Employees

Does your Company have an up-to-date Whistleblower Protection Policy? The answer to that question has become all the more important for food-related companies in light of a new interim final rule that the Occupational Safety and Health Administration… Read More
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OSHA Games the System to Target Small Farmers

There is frequent tension between the spirit of the law versus the letter of the law. Obeying the “spirit of the law” means following the intent of those who drafted it. Following the “letter of the law” means following the la… Read More
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