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Updates about OSHA’s Egregious Enforcement and Severe Violator Enforcement Program
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

Apr 13, 2023 01:00 PM in Eastern Time (US and Canada)

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Eric J. Conn
Chair, OSHA • Workplace Safety Practice Group, Conn Maciel Carey LLP
Eric J. Conn is a Founding Partner and Chair of CMC's national OSHA • Workplace Safety Group. Mr. Conn spent a decade of his 20+ year career practicing alongside the former first General Counsel of the OSH Review Commission. He represents employers in inspections, investigations and enforcement actions involving OSHA, the CSB, MSHA, EPA and state and local safety-related agencies. He handles all aspects of OSHA litigation and conducts and directs workplace safety audits, delivers safety training, and helps employers develop and implement compliant safety and health programs. He writes and speaks extensively on safety & health law issues, including curating the award-winning OSHA Defense Report blog and authoring chapters in OSHA Treatises. He is proud to have presided over CMC’s OSHA Practice when it was recognized as one of only three “Band 1” Rated OSHA Law Firms by Chambers USA in 2022. Eric was also recognized as one of only nine Band 1 rated OSHA law practitioners nationwide.
Aaron R. Gelb
Partner, Labor • Employment and OSHA • Workplace Safety Practice Groups, Conn Maciel Carey LLP
Aaron R. Gelb is the partner in charge of Conn Maciel Carey’s Chicago office and leads the firm’s Midwest OSHA practice, representing employers during inspections, investigations, and enforcement actions involving fed OSHA and state OSH programs. In addition to managing the full range of litigation against OSHA, Aaron reviews safety policies and procedures, manages audit programs, and helps develop and present training on a variety of topics. Aaron serves as the primary workplace safety and health education provider to the Illinois Manufacturers Association and is a frequent speaker on such matters throughout the United States. Aaron also has extensive experience litigating equal employment opportunity matters in federal and state courts, having tried numerous cases to verdict and defended employers before the EEOC as well as fair employment agencies nationwide.
Darius Rohani-Shukla
Associate, Labor • Employment and OSHA • Workplace Safety Practice Groups, Conn Maciel Carey LLP
Darius Rohani-Shukla is an Associate in the firm’s Labor • Employment and OSHA • Workplace Safety Practice Groups in Washington, DC. Mr. Rohani-Shukla brings experience handling all aspects of litigation at a practice focused specifically on United States federal employment laws. He also supports clients on a multitude of occupational safety and health law issues, including counseling on compliance with OSHA rules and standards, and representing employers in OSHA inspections, investigations, and enforcement actions.