OSHA's Enterprise Abatement Enforcement: Defend Against Companywide Violations Across Multiple Worksites
|Date / Time:
Alert: OSHA has launched its enterprise enforcement approach for companies that have multiple locations, which is quite concerning to safety managers nationwide. And for good reason: where OSHA used to direct citations to a specific facility, their new corporate-wide penalty approach means companies with multiple facilities across many locations—such as national retail stores, grocery chains, manufacturers, and hotel chains—are particularly vulnerable to increased scrutiny.
Still, all companies should be weary. OSHA’s definition is broad, so if your organization is operating more than one facility, you are likely a potential target.
So what’s the best way to minimize the impact of enterprise enforcement approach exposure? Prepare ahead of time by developing effective strategies that comprehensively address each of the potential areas of concern.
Join us to learn how successful companies are already developing effective and comprehensive strategies. Our presenter, seasoned safety lawyer Adele Abrams, will walk you through how the new enforcement approach works, what to do to protect your organization, and how best to respond if affected by the enforcement initiative.
About Your Presenter:
- How to determine if your organization would be considered a multi-site organization
- How to assess the advantages and disadvantages of being considered a multi-site organization
- The implications of companywide penalty assessment as it relates to:
- The general duty clause
- Recordkeeping issues
- The severe violator enforcement program (SVEP)
- The whistleblower SVEP (WSVEP)
- Corporate safety training programs
- Training and audits
- Corporate wide settlement agreements (CSA)
- Joint employer liability
- Record retention
- Contractor utilization issues
- How to evaluate “at risk” job classifications as they relate to companywide penalty assessment
- How to assess the implications of OSHA’s increased fines and penalties initiative as it relates to the enterprise enforcement approach
- The implications of the enterprise enforcement approach on OSHA Audit Policy and safe harbor on voluntary self-audits
- Strategies for minimizing the potential impact of the enterprise enforcement approach
Adele Abrams, Esq.
Law Offices of Adele L. Abrams P.C.
Adele Abrams, Esq., CMSP, is an attorney, safety professional and firm president of the Law Offices of Adele L. Abrams P.C. who is recognized as a national expert on occupational safety and health. Ms. Abrams heads a ten-attorney firm that represents employers and contractors nationwide in OSHA and MSHA litigation, and provides safety and health training, auditing, and consultation services. She is a Certified Mine Safety Professional, and a Department of Labor–approved trainer. Ms. Abrams is on the adjunct faculty of Catholic University in Washington, DC, where she teaches employment and labor law.
Ms. Abrams is also a professional member of the American Society of Safety Engineers, and is co-author of several safety-related textbooks. She is chair of the National Safety Council’s Business & Industry Division committee on regulatory and legal affairs. She is admitted to the Bars of MD, DC and PA, as well as multiple federal courts including the US Supreme Court.
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|Keywords For This Course:|
Multi-site organizations, Multi-site organization definition, Penalties and multi-site organizations, General duty clause and multi-site organizations, Severe Violator Enforcement Program and multi-site organizations
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