Multi-Worksite Safety: Steps To Avoid Citations And Achieve Compliance Under OSHRC Enterprise-Wide Abatement Decision
|Date / Time:
A 2015 Occupational Safety and Health Review Commission (OSHRC) ruling indicates that OSHA may have the authority to order abatement measures beyond specific measures identified in a citation(s). The practical impact means OSHA has increased enforcement authority across an enterprise.
For example: During an OSHA inspection, a transportation company’s facility was cited for failure to comply with the OSHA powered industrial truck standard and the proposed fine was $330,000. In addition to the 14 violations at that specific facility, OSHA also required enterprise-wide abatement for the other violations in question.
In the past, inspection findings usually applied to only the facility where the inspection occurred. New regulations, however, could be changing to have major implications for organizations with multiple facilities.
Join us for an in-depth discussion with attorney Tracy Moon and safety professional Abby Ferri about minimizing compliance headaches at multi-worksites and strategies to stay in compliance with the latest OSHA regulations.
About Your Presenters:
- Interpret the recent OSHRC enterprise-wide abatement decision and determine how it could affect your multi-worksite safety program
- Explain to senior management the implications of the recent OSHRC decision as it relates to your multi-worksite safety program
- Consider important trends as they relate to your multi-worksite safety program resulting from the decision, such as:
- OSHA follow-inspections and repeat violations at sister facilities
- pursuit of enterprise-wide abatement provisions in settlement agreements
- aggressive implementation of OSHA’s Severe Violator Enforcement Program
- Evaluate multi-worksite safety program strategies for assuring full OSHA compliance and minimizing your organization’s exposure to enterprise-wide enforcement
- Perform audits to identify potential areas of concern in your multi-worksite safety program
- Use the results of internal audit findings and agency inspections to address areas of concern
- Ensure that your facilities are properly prepared for an OSHA inspection in order to minimize exposure to enterprise-wide concerns
Tracy Moon, Esq.
Fisher & Philips LLP
Tracy L. Moon, Jr., Esq. is a partner in the Atlanta office of Fisher & Phillips LLP. He represents employers in all aspects of labor and employment law. His experience includes representation of employers before state and federal trial and appellate courts in matters under Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act, Americans With Disabilities Act, Family and Medical Leave Act, and a variety of state law wrongful discharge, contract and tort claims. Mr. Moon also represents employers before the National Labor Relations Board and other government agencies, including the EEOC and OSHA. Mr. Moon counsels and trains employers on labor and employment law, including conducting on-site compliance inspections and in-house management training programs. He is a frequent speaker at various employment and labor law programs.
Safety & Risk Control Consultant
The Ferri Group LLC
Abby Ferri, CSP is an independent risk control, safety, and health consultant. She earned her Master’s Degree in Environmental Health and Safety, is an OSHA Outreach Trainer for Construction since 2003, and became a Certified Safety Professional (CSP) in 2008. She employs an intellectual, practical, and creative approach to the toughest health, safety, and environment challenges.
In Ms. Ferri’s current role she is responsible for risk control, program development, training and regulatory compliance for construction, manufacturing, healthcare, hospitality, and retail clients throughout the United States and Canada. Her previous experience included managing all aspects of corporate safety, health, and environment programs in the construction industry and managing a large book of nationwide accounts in the insurance industry. Ms. Ferri has provided risk control, safety, health, and environmental consulting services for general contractors, subcontractors, fabrication facilities, manufacturing, healthcare, hospitals, retail, hospitality, restaurant, beverage and other construction and general industry workplaces.
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|Keywords For This Course:|
Examples of enterprises with multiple sites in different locations, OSHA pursuit of companywide abatement provisions, Severe Violator Enforcement Program, Repeat violations and multiple sites, Willful violations and multiple sites, Fatalities and multiple sites, Fines and penalties and multiple sites, Failure to abate violations and multiple sites, High emphasis hazards and multiple sites, Past violation implications and multiple sites, Application and enforcement of the multiple site policy
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