EHS Law Insights

Comment and analysis by Reed Smith lawyers on the latest developments in Environmental Health & Safety

Latest from EHS Law Insights - Page 2

The Occupational Safety and Health Administration (OSHA) recently released two memos instructing enforcement officers on “instance-by-instance” citations and de-grouping violations to deter infractions. 

OSHA’s prior policy on instance-by-instance citations, published in 1990, applied just to willful citations. The new guidance identifies several