(from Conn Maciel Carey) On January 26, 2023, OSHA announced that it will substantially sharpen OSHA’s enforcement "teeth." Specifically, OSHA dramatically expanded the circumstances when it can issue “instance-by-instance” citations to employers, and also discouraged the grouping of similar citations under a single penalty. For example, when an employer fails to ensure that all employees wear a hard hat at a construction site, OSHA will no longer issue one citation but instead issue ten citations with ten separate penalties for each of the ten employees observed without a hard hat.
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