Lawrence Halprin Quoted in Inside OSHA Article on OSHA Enforcement Policies

Keller and Heckman Partner Lawrence Halprin was quoted in the Inside OSHA article, “OSHA Will Step Up ‘Instance-By-Instance’ Citations to Boost Enforcement.” The article explores major changes in OSHA’s enforcement policies, including prioritizing “instance-by-instance” citations, and mentions the publication, “OSHA Increasing Fines Through Major Changes in Enforcement Policies,” authored by Lawrence. According to Lawrence, “the new policy will likely lead to additional litigation over citations, including cases that could test whether OSHA has the authority to make its changes and how they should be considered by administrative law judges in assessing whether a proposed penalty is appropriate.” Lawrence also discussed OSHA’s next potential actions, which “may be to summarily amend some of its standards (as it did some years ago), without imposing any additional compliance obligations on employers, to permit instance-by-instance or non-grouped citations where the current language of the standards would not support that approach.”

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