OSHA violations characterized as Repeat or Willful will soon carry penalties exceeding $150,000 each. You may be wondering, however, what exactly leads OSHA to characterize a violation as Repeat or Willful, and why are they important beyond their high-dollar cost? No doubt, you heard that OSHA changed the Severe Violator Enforcement Program (SVEP) in September 2022, making it easier to place employers into the program and saddle them with all the negative consequences associated with it even though the citations which prompted the referral are not yet final orders. And the word around the Beltway is that OSHA will soon be revising its “Egregious” enforcement policy which it has been using to generate multi-million-dollar enforcement actions.
This webinar explains the legal standard for Repeat, Willful and Egregious violations, the potential consequences for receiving them, and how OSHA’s enforcement policies have resulted in a significant increase in the frequency with which we see these aggravated characterizations.
Participants in this webinar will learn:
• The legal standards OSHA must meet to establish Repeat and Willful violations
• Background and details about OSHA's Egregious / Per-Instance Enforcement Policy
• Policy changes that have resulted in more Repeat and Egregious violations
• Impacts of these aggravated characterizations, including qualifying into the Severe Violator Enforcement Program, facing criminal charges, etc.
• What employers should do to avoid Repeat and Willful citations