Managing OSHA

Critical but practical advice for when OSHA comes knocking.

Managing OSHA



Arent Fox OSHA Team Hosts Webinar on Possible Changes to the EPA RMP Rule

On August 7, 2014, Arent Fox OSHA Group leader, Mark Dreux, and AcuTech Group, Inc. Technical Manager, Michael Hazzan, presented a webinar on the possible changes to the EPA RMP rule (40 CFR 68) proposed by EPA in their RFI of July 31, 2014, including changing the list of covered chemicals, third party audits, defining RAGAGEP, expanding MI programs, safer technologies & alternatives (or IST by another name), use of the safety case model in RMP, among others.


Arent Fox OSHA Team Hosts Webinar on Proposed Changes to PSM Standard and RMP Rule

On June 26, 2014, Arent Fox OSHA Group leader, Mark Dreux, and AcuTech Group, Inc. Technical Manager, Michael Hazzan, presented a webinar on the recommended changes to the PSM Standard and RMP Rule from the Executive Order 13650 Working Group. In the webinar, Mr. Dreux and Mr. Hazzan boil down the Working Group’s interim report and offer critical insight on the recommended regulatory changes and what they could mean for the refining and chemical industries.

Readers can access the full webinar presentation (along with slides) by clicking here.


Webinar on OSHA’s and EPA’s Plans to Modernize PSM and RMP


Properly Evaluating an OSHA Citation: Should You Contest the Citation?

For the last twenty-five years, I have defended companies in OSHA enforcement actions. No matter how large or small the action, employers should always begin by evaluating the potential financial impact the OSHA citation could have on the company. From that evaluation, employers can then decide the amount of resources that are needed to defend it.

Some factors like the proposed monetary penalty are straightforward to calculate. But there are five other factors which really turn on the specific facts of each case and need to be evaluated carefully to determine the true potential financial impact: 1) the cost in time and capital to abate the alleged hazard in the citation, 2) the impact that the OSHA citation could have upon collateral litigation and parallel regulatory inspections, 3) the potential for repeat OSHA citations, 4) the characterization of the citation as "willful," and 5) the impact that safety violations may have upon the company in competing for new projects.

By considering these factors, you can evaluate the potential financial impact of the citation and allocate the appropriate resources to defend it, accordingly.


Tips for Preparing for your OSHA PSM Inspection

On June 5, I had the privilege of speaking at the Texas Chemical Council’s Environmental, Health & Safety Seminar at the Moody Gardens Convention Center in Galveston, Texas. For those of you who were not able to join us, I have uploaded my slide presentation “Tips for Preparing for your OSHA PSM Inspection”.

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Arent Fox LLP, founded in 1942, is internationally recognized in core practice areas where business and government intersect. With more than 350 lawyers, the firm provides strategic legal counsel and multidisciplinary solutions to clients that range from Fortune 500 corporations to trade associations. The firm has offices in Los Angeles, New York, San Francisco, and Washington, DC.