A Reprieve For Employers From Public Shaming By OSHA

Robert G. Chadwick, Jr., Managing Member, Seltzer, Chadwick, Soefje & Ladik, PLLC.

As noted in previous posts on this blog (here and here), one of the strategies employed by OSHA has been public shaming of employers who receive citations. This strategy has included agency press releases scolding employers for not protecting their employees. These press releases have often been republished by media outlets thereby reaching a wider audience.

At a 2010 conference, Dr. David Michaels, Assistant Secretary of Labor under the Obama administration, even boasted of the strategy of “regulation by shaming.” He said OSHA would undertake to issue news releases that “name employers, expose their failings, and detail the serious hazards uncovered in our inspections.”

Press releases announcing OSHA citation have continued under the Trump administration, albeit at a reduced pace. In 2020, nearly 100 such press releases have been published on the agency’s website.

New Guidance on Press Releases

On September 24, 2020, an internal Department of Labor Memorandum highlighted an important problem with the public shaming strategy: “News releases … can prove misleading if, for example, [OSHA] issues a release at the time a proceeding is first initiated, and is ultimately found to be unjustified in its enforcement action.”

Accordingly, Assistant Secretary of Labor Patrick Pizzella announced a new policy: “[I]n general, enforcement agencies should not issue news releases before achieving a successful outcome.” “In most cases the appropriate time for a release will be the point in time:

  • After a court or other tribunal has rendered judgment or issued a decision;
  • After a conviction or plea agreement has been obtained;
  • After an agency has entered into a settlement or conciliation agreement with the named party regarding remedies or the payment of a penalty; or
  • After the time for contesting a finding (such as a citation) has elapsed and the party has not contested or requested to negotiate.

Under the new policy, if OSHA wants to issue a press release, the agency must first consult with the DOL Office of the Solicitor. The final decision is at the discretion of the DOL, not OSHA.

COVID-19-Related Press Releases Continue

Perhaps as a result of public criticism of OSHA’s response to the COVID-19 pandemic, the new policy has a limited exception: “An extraordinary circumstance that might warrant a news release at the time a proceeding is initiated would be a case alleging a serious violation that is potentially widespread and which the [DOL] has not addressed in a prominent way previously, so that instructing the public through a news release could significantly further worker protection.”

As late as October 23, 2020, therefore, OSHA was still publishing a list of coronavirus violations.

The 2020 Election

If Trump is reelected President, the new policy will likely last another four years. What will become of the policy, however, if Joe Biden is elected President? Will OSHA return to the previous strategy of public shaming employers even without a successful outcome? Stay tuned to this blog for further updates.

Robert G. Chadwick, Jr. frequently speaks to non-profit organizations regarding occupational safety and health issues. To contact him for a speaking engagement, please e-mail him at rchadwick@realclearcounsel.com.

Tracking COVID-19-Related Citations By OSHA

[UPDATE: On Oct. 2, 2020, the OSHA website began listing OSHA-related citations. See the link here].

Many State OSHA agencies have been active this year in citing employers for safety violations related to COVID-19. Federal OSHA, however, has only recently begun to cite employers for such violations. The purpose of this post is to track these federal citations thereby underscoring for employers the new emphasis being placed by the agency on COVID-19.

So far, OSHA’s focus has been directed at meat packing plants and hospitals.

July 21, 2020 – OHNH EMP LLC

OSHA inspected three OHNH EMP facilities in Ohio: Pebble Creek Healthcare Center in Akron, and Salem West Healthcare Center and Salem North Healthcare Center in Salem. OSHA announced on July 21, 2020 it had cited each location for an alleged serious violation of two respiratory protection standards: allegedly failing to develop a comprehensive written respiratory protection program and allegedly failing to provide medical evaluations to determine employees’ ability to use a respirator in the workplace. OSHA proposed a penalty of $40,482.

Sept. 8, 2020 – Nautchaug Hospital

On Sept. 8, OSHA issued a citation against Nautchaug Hospital in Connecticut, which alleges: On or about, April 25, 2020, employees who provided direct care to a suspect COVID-19 patient were not provided adequate respiratory protection and were potentially exposed to SARS-CoV-2 virus.” The citation proposes a penalty of $11,566. 

Sept. 10, 2020 – Smithfield Packaged Meats Corp.

At least 1,294 workers employed at Smithfield Packaged Meats Corp., in Sioux Falls, South Dakota, contracted coronavirus, and four employees died from the virus in the spring of 2020.On Sept. 10, 2020 OSHA announced it had cited Smithfield for alleged violations of the general duty clause of the OSH Act. OSHA proposed a penalty of $13,494. Smithfield has announced its intention to contest the citation.

Sept. 10, 2020 – Christus Shreveport-Bossier Health System

Earlier this year, employees of the Christus Shreveport Health System complained to OSHA of exposures to COVID-19 due to improper protection protocols. On Sept. 10, 2020, OSHA announced it had cited Christus for alleged personal protective equipment violations. OSHA proposed a penalty of $13,494. Christus has announced its intention to contest the citation.

Sept. 11, 2020 – JBS Foods

Onn Sept. 11, 2010, OSHA demonstrated that meat packing companies are a national emphasis for inspections and citations. OSHA announced it had cited JB Foods for alleged violations of the general duty clause of the OSH Act. OSHA proposed a penalty of $15,615.

Sept. 11, 2020 – CarePlus Bergen Inc. d/b/a Bergen New Bridge Medical Center 

On Sept. 11, 2020, OSHA announced it had cited CarePlus Bergen, Inc. d/b/a Bergen New Bridge Medical Center in New Jersey for allegedly violating respiratory protection standards. The citation was prompted by a coronavirus-related inspection. OSHA proposed a penalty of $9,639.

Sept. 11, 2020 – Hackensack Meridian Health Residential Care Inc. 

Based on a coronavirus-related inspection, OSHA announced on Sept, 11, 2020 it had cited Hackensack Meridian Health Residential Care, Inc. for an alleged serious violation for failure to provide respirators to resident-care employees for a period of time in March 2020. Employees were caring for residents who were exhibiting symptoms of coronavirus. OSHA also cited the employer for the alleged failure to conduct respirator fit testing, effective training and compliant medical evaluations, during the period after the employer began providing respirators to the employees and requiring their use. OSHA cited one other-than-serious violation for the facility’s alleged failure to establish a fit-test record for qualitative fit tests. OSHA proposed a penalty of $28,070.

Sept. 11, 2020 – Roudebush VA Medical Center

OSHA cited Roudebush VA Medial Center in Indiana for failing to provide appropriate PPE and failing to protect employees from COVID-19, particularly non-medical staff.

Sept. 16, 2020 – Georgetown Dental LLC 

On Sept. 16, 2020, OSHA announced it had cited Georgetown Dental, PLLC for allegedly failing to provide medical evaluations and fit testing for employees required to wear N-95 respirators as protection against coronavirus; lack of written programs related to respiratory protection, bloodborne pathogen exposure control and chemical hazard communication; insufficient bloodborne pathogen training and controls; and inadequate eyewash stations. OSHA proposed penalties of $9,500. The company has paid the penalty in full and abated the citations.

Robert G. Chadwick, Jr. frequently speaks to non-profit organizations regarding occupational safety and health issues. To contact him for a speaking engagement, please e-mail him at rchadwick@realclearcounsel.com.

Coronavirus Crisis: OSHA Steps Up Enforcement As Businesses Reopen

By Robert G. Chadwick, Jr., Managing Member, Seltzer, Chadwick, Soefje & Ladik, PLLC.

Effective May 26, 2020, OSHA is rescinding the Interim Enforcement Response Plan for Coronavirus Disease 2019 (COVID-19), published by the agency on April 13, 2020 (See April 15, 2020 Post), and the Enforcement Guidance for Recording Cases of Coronavirus Disease 2019 (COVID-19), published by the agency on April 10, 2020. As businesses reopen, OSHA will instead be guided by two revised enforcement policies.

Inspection Priorities

First, under an Updated Interim Enforcement Plan for Coronavirus Disease 2019 (COVID-19, OSHA will resume in-person inspections of workplaces. The agency will continue to prioritize COVID-19 cases. “Particular attention for on-site inspections will be given to high-risk workplaces, such as hospitals and other healthcare providers treating patients with COVID-19, as well as workplaces, with high numbers of complaints or known COVID-19 cases.”

OSHA will continue to provide enforcement priority to “[h]igh and very high exposure risk jobs.” In this regard, the Updated Plan says:

“High and very high exposure risk jobs are those with high potential for exposure to known or suspected sources of SARS-CoV-2 that occurs during specific medical, postmortem, or laboratory procedures. Workplaces considered to have job duties with high risk of exposures to COVID-19 include, but are not limited to, hospitals treating suspected and/or confirmed COVID-19 patients, nursing homes, emergency medical centers, emergency response facilities, settings where home care or hospice care are provided, settings that handle human remains, biomedical laboratories, including clinical laboratories, and medical transport. The aerosol-generating procedures, in particular, present a very high risk of exposure to workers. The aerosol-generating procedures for which engineering controls, administrative controls, and personal protective equipment (PPE) are necessary include, but are not limited to, bronchoscopy, sputum induction, nebulizer therapy, endotracheal intubation and extubation, open suctioning of airways, cardiopulmonary resuscitation and autopsies.”

 OSHA standards that may be investigated by OSHA as to COVID-19 include:

  •    Recording and Reporting Occupational Injuries and Illness (29 CFR 1904)
  •    General Requirements – Personal Protective Equipment (29 CFR 1910.132)
  •    Eye and Face Protection (29 CFR 1910.133)
  •    Respiratory Protection (29 CFR 1910.134)
  •    Sanitation (29 CFR 1910.141)
  •    Specification for Accident Prevention Signs and Tags (29 CFR 145)
  •    Access to Employee Exposure and Medical Records (29 CFR 1910.145)
  •    General Duty Clause

Recording COVID-19 Cases

Second, under Revised Guidance for Recording Cases of Coronavirus Disease 2019 (COVID-19),  COVID-19 is a recordable illness if:

  1. The case is a confirmed case of COVID-19, as defined by the Centers for Disease Control (CDC);
  2. The case is work-related as defined by 29 C.F.R. 1904.5; and
  3. The case involves one or more of the general recording criteria set forth in 29 C.F.R. 1904.7.

The Revised Guidance acknowledges the difficulty of determining whether a COVID-19 illness is work-related. Still, OSHA maintains that an employer must conduct a reasonable investigation as to whether the disease was contracted at work. In this regard the Revised Guidance states:

“Employers, especially small employers, should not be expected to undertake extensive medical inquiries, given employee privacy concerns and most employers’ lack of expertise in this area. It is sufficient in most circumstances for the employer, when it learns of an employee’s COVID-19 illness, (1) to ask the employee how he believes he contracted the COVID-19 illness; (2) while respecting employee privacy, discuss with the employee his work and out-of-work activities that may have led to the COVID-19 illness; and (3) review the employee’s work environment for potential SARS-CoV-2 exposure. The review in (3) should be informed by any other instances of workers in that environment contracting COVID-19 illness.”

Even after a reasonable investigation, it may still not be entirely clear whether COVID-19 was contracted at work.  In this regard, the Revised Guidance provides:

  • COVID-19 illnesses are likely work-related when several cases develop among workers who work closely together and there is no alternative explanation.
  • An employee’s COVID-19 illness is likely work-related if it is contracted shortly after lengthy, close exposure to a particular customer or coworker who has a confirmed case of COVID-19 and there is no alternative explanation.
  • An employee’s COVID-19 illness is likely work-related if his job duties include having frequent, close exposure to the general public in a locality with ongoing community transmission and there is no alternative explanation.
  • An employee’s COVID-19 illness is likely not work-related if she is the only worker to contract COVID-19 in her vicinity and her job duties do not include having frequent contact with the general public, regardless of the rate of community spread.
  • An employee’s COVID-19 illness is likely not work-related if he, outside the workplace, closely and frequently associates with someone (e.g., a family member, significant other, or close friend) who (1) has COVID-19; (2) is not a coworker, and (3) exposes the employee during the period in which the individual is likely infectious.

Reading Between The Lines

OSHA has already been facing intense political pressure to take more decisive action to safeguard workers in the wake of the COVID-19. This pressure will only become more intense as business previously subject to state and local closure orders reopen.  Employers should thus expect OSHA to be considerably more active in the remaining months of 2020.

Most employers already know, moreover, that OSHA obligations do not exist in a vacuum. OSHA inspections and illness recordings are sure to impact exposures other than OSHA citations, such as wrongful death actions, criminal prosecutions and workers’ compensation claims.

Robert G. Chadwick, Jr. frequently speaks to non-profit organizations regarding occupational safety and health issues. To contact him for a speaking engagement, please e-mail him at rchadwick@realclearcounsel.com.

Coronavirus Crisis: OSHA Establishes Interim Inspection Priorities

By Robert G. Chadwick, Jr., Managing Member, Seltzer, Chadwick, Soefje & Ladik, PLLC.

On April 13, 2020, the Occupational Safety & Health Administration (“OSHA”) published an Interim Enforcement Response Plan for Coronavirus Disease 2019 (COVID-19). The Plan identifies “[h]igh and very high exposure risk jobs” which will receive priority by the agency in its enforcement activities during the crisis. The Plan states:

“High and very high exposure risk jobs are those with high potential for exposure to known or suspected sources of SARS-CoV-2 that occurs during specific medical, postmortem, or laboratory procedures. Workplaces considered to have job duties with high risk of exposures to COVID-19 include, but are not limited to, hospitals treating suspected and/or confirmed COVID-19 patients, nursing homes, emergency medical centers, emergency response facilities, settings where home care or hospice care are provided, settings that handle human remains, biomedical laboratories, including clinical laboratories, and medical transport. The aerosol-generating procedures, in particular, present a very high risk of exposure to workers. The aerosol-generating procedures for which engineering controls, administrative controls, and personal protective equipment (PPE) are necessary include, but are not limited to, bronchoscopy, sputum induction, nebulizer therapy, endotracheal intubation and extubation, open suctioning of airways, cardiopulmonary resuscitation and autopsies.”

 Several OSHA standards may apply to workplace hazards created by COVID 19:

  •    Recording and Reporting Occupational Injuries and Illness (29 CFR 1904)
  •    General Requirements – Personal Protective Equipment (29 CFR 1910.132)
  •    Eye and Face Protection (29 CFR 1910.133)
  •    Respiratory Protection (29 CFR 1910.134)
  •    Sanitation (29 CFR 1910.141)
  •    Specification for Accident Prevention Signs and Tags (29 CFR 145)
  •    Access to Employee Exposure and Medical Records (29 CFR 1910.145)
  •    General Duty Clause

Robert G. Chadwick, Jr. frequently speaks to non-profit organizations regarding occupational safety and health issues. To contact him for a speaking engagement, please e-mail him at rchadwick@realclearcounsel.com.

Are Employee Homes Subject To OSHA Inspections & Reporting?

By Robert G. Chadwick, Jr. , Managing Member, Seltzer, Chadwick, Soefje & Ladik, PLLC.

In the wake of the COVID-19 threat, many employees are working from improvised home work sites. So, what does this mean for OSHA compliance and enforcement?

In 2000, OSHA issued a Directive which purports to answer this question.

Inspections of Home Offices

Under the Directive, OSHA clarified that it would not conduct inspections as to office work activities in a home-based work site. Such activities include filing, scanning, copying, printing, telephone calls, reading, writing and computer work. The Directive states: “OSHA will not hold employers liable for employees’ home offices, and does not expect employers to inspect the home offices of their employees.”

Inspections of Other Home Work Sites

The Directive nevertheless states: “OSHA will .. conduct inspections of other home-based worksites, such as home manufacturing operations, when OSHA receives a complaint or referral that indicates that a violation of a safety or health standard exists that threatens physical harm, or that an imminent danger exists, including reports of a work-related fatality.” The directive adds: “Employers are responsible in home work sites for hazards caused by materials, equipment, or work processes which the employer provides or requires to be used in an employee’s home.”

Injury and Illness Reporting

The limitations on OSHA inspections do not affect the reporting of work-related injuries and illnesses. In this regard, the Directive states: “Employers who are required, because of their size or industry classification, by the OSH Act to keep records of work-related injuries and illnesses, will continue to be responsible for keeping such records, regardless of whether the injuries occur in a factory, in a home office, or elsewhere, as long as they are work-related and meet the [applicable] recordability criteria …”

Robert G. Chadwick, Jr. frequently speaks to non-profit organizations regarding occupational safety and health issues. To contact him for a speaking engagement, please e-mail him at rchadwick@realclearcounsel.com.

Company Owner In Contempt After Company Fails To Pay $2.2M OSHA Fine

By Robert G. Chadwick, Jr., Managing Member, Seltzer, Chadwick, Soefje & Ladik, PLLC.

On January 3, 2020, the Eleventh Circuit Court of Appeals entered an order holding Great White Construction, Inc., Florida Roofing Experts, Inc. and owner Travis Slaughter in contempt for failing to pay $2,202,049 in OSHA penalties previously affirmed by the Court on October 2, 2017 and June 5, 2018.

The contempt order states the companies and Mr. Slaughter “shall be subject to coercive sanctions, including incarceration, and such other relief as this Court deems just and proper, for any noncompliance after 10 days after the date of this order.”

The January 3, 2020 judgment underscores the authority of federal courts to enforce their orders. Moreover, the judgment shows that companies ignore assessed OSHA penalties at their own peril.

January 3, 2020 Order

Robert G. Chadwick, Jr. frequently speaks to non-profit organizations regarding occupational safety and health issues. To contact him for a speaking engagement, please e-mail him at rchadwick@realclearcounsel.com.

OSHA’s Top Ten Most Frequently Cited Standards – 2019

By Robert G. Chadwick, Jr., Managing Member, Seltzer, Chadwick, Soefje & Ladik, PLLC.

On September 10, 2019, at the National Safety Council 2019 Congress and Expo, Patrick Kapust, Deputy Director of OSHA’s Directorate of Enforcement Programs, provided a preliminary list of OSHA’s top ten most frequently cited standards for fiscal year 2019 (Oct. 1, 2018 – September 30, 2019). Final data will be published on the OSHA website later this year.

The preliminary list:

  1.  Fall protection, construction (29 C.F.R. § 1926.501): 6,010 violations
  2.  Hazard communication standard, general industry (29 C.F.R. § 1910.1200): 3,671 violations
  3.  Scaffolding, general requirements, construction (29 C.F.R. § 1926.451): 2,813 violations
  4.  Control of hazardous energy (lockout/tagout), general industry (29 C.F.R. § 1910.147): 2,606 violations
  5.  Respiratory protection, general industry (29 C.F.R. § 1910.134): 2,450 violations
  6.  Ladders, construction (29 C.F.R. § 1926.1053): 2,345 violations
  7.  Powered industrial trucks, general industry (29 C.F.R. § 1910.178): 2,093 violations
  8.  Fall protection – training requirements (29 C.F.R. § 1926.503): 1,773 violations
  9.  Machinery and machine guarding, general requirements (29 C.F.R. § 1910.212): 1,743 violations
  10.  Eye and face protection (29 C.F.R. § 1910.102): 1,411 violations

Of course, OSHA citations do not always become a final order if challenged in settlement discussions or a notice of contest. Still, the preliminary list is instructive as to the focus of the agency in scheduling and conducting inspections.

Robert G. Chadwick, Jr. frequently speaks to non-profit organizations regarding occupational safety and health issues. To contact him for a speaking engagement, please e-mail him at rchadwick@realclearcounsel.com.

Company President In Contempt After Company Fails to Pay $412,000 OSHA Fine

By Robert G. Chadwick, Jr., Managing Member, Seltzer, Chadwick, Soefje & Ladik, PLLC.

On July 24, 2019, the Third Circuit Court of Appeals entered a judgment holding a construction company and its president in contempt for failing to pay $412,000 in OSHA penalties previously affirmed by the Court in a November 15, 2012 Decree.  The judgment says the president is personally liable for the portion of the fine not paid by the company.

The company president said he construed the November 12, 2012 Decree, which named him, to apply only in his capacity as an officer or employee of the company, “not to have required [him] individually to satisfy the Decree from personal assets.”

The Third Circuit rejected this position.  The Court said “[i]t is well established that when a corporate officer fails to act on behalf of the corporation to comply with a court order, the officer too may be held in contempt.” The Court also determined the sanction fairly holds the president accountable for “[his] failure, for more than four years, to make even a nominal effort to satisfy the November 15, 2012 Decree.”

The July 25, 2019 judgment underscores the authority of federal courts to enforce their orders. Moreover, the judgment shows that the time to challenge an OSHA fine, especially as to personal liability, is before a federal court renders a decree regarding the fine, not afterwards.

Robert G. Chadwick, Jr. frequently speaks to non-profit organizations regarding occupational safety and health issues. To contact him for a speaking engagement, please e-mail him at rchadwick@realclearcounsel.com.

Beware of the Follow-Up OSHA Inspection

By Robert G. Chadwick, Jr., Managing Member, Seltzer, Chadwick, Soefje & Ladik, PLLC.

The OSHA penalty structure is specifically designed to punish employers more severely for uncorrected hazards discovered by the agency during a previous inspection. As of January 23, 2019, the maximum fine for a willful or repeat violation is $132,598; the maximum fine for failing to correct a hazard after the prescribed abatement date is $13,260 per day.

It is not surprising, therefore, that a follow-up OSHA inspection can yield significantly greater proposed penalties than an original inspection. Indeed, the largest citation ever issued by OSHA included $50.6 million in proposed fines against BP Products North America, Inc. for failing to abate hazards from a previous inspection.

To be sure, follow-up inspections have low priority for OSHA according to an agency publication.  A follow-up inspection can nevertheless be triggered by many circumstances, including (1) the nature of the employer’s operations, (2) the nature of hazards discovered during the initial inspection, (3) the failure of the employer to provide timely abatement documentation following the initial inspection, and (4) an event triggering another priority, such as an accident or complaint.

The road from an initial OSHA inspection to resolution of a citation can certainly be a difficult and costly one. For an employer which has heeded the lessons of the initial inspection, a follow-up inspection can be a mere annoyance. For an employer which has not heeded these lessons, however, a follow-up inspection can be devastating.

Robert G. Chadwick, Jr. frequently speaks to non-profit organizations regarding occupational safety and health issues. To contact him for a speaking engagement, please e-mail him at rchadwick@realclearcounsel.com.

Are You Following The Correct OSHA Standard?

By Robert G. Chadwick, Jr., Managing Member, Seltzer, Chadwick, Soefje & Ladik, PLLC.

In February 2016, Bergelectric Corporation (“Bergelectric”)  was installing solar panels on the roof of a hangar at the Marine Corps Air Station in San Diego, California. The roof of the hangar was low-sloped and six feet or more above a lower level. Bergelectric employees were using warning lines and a safety monitor as prescribed by 29 C.F.R. § 1926.501(b)(10) of OSHA’s fall protection standard, which applies to employees performing roofing work on low-sloped roofs.

On February 24-25, 2016, OSHA conducted an inspection of the worksite. Based on the inspection, the agency issued a citation alleging a violation of 29 C.F.R. § 1926.501(b)(1) of OSHA’s fall protection standard, which requires employees working near the unprotected sides and edges of certain roofs to be protected by guardrail systems, safety net systems or personal fall arrest systems (“PFAS”).

Bergelectric contested the citation.  Although it did not dispute the absence of guardrail systems, safety net systems or PFAS, the company alleged its worked was governed by the safety standard for roofing work on low-sloped roofs, rather than the stricter standard applicable to unprotected sides and edges.  The Occupational Safety & Health Review Commission nevertheless upheld the citation, and Bergelectric filed a Petition for Review with the Ninth Circuit Court of Appeals.

In a June 6, 2019 Per Curiam Opinion, the Ninth Circuit denied Bergelectric’s Petition for Review.  In doing so, the court noted that the installation of solar panels did not fall within the definition of “roofing work” in 29 C.F.R. § 1926.500(b).  That regulation defines “roofing work” as “the hoisting, storage, application, and removal of roofing materials and equipment, including related insulation, sheet metal, and vapor barrier work, but not including the construction of the roof deck.”  The Court determined that the solar panels had “no connection to roofing and were, instead, simply the installation of a system that often happens to sit atop a roof.”

Without question, OSHA standards are voluminous and complex.  As the experience of Bergelectric demonstrates, an employer nevertheless interprets these standards at its own peril. Even a good faith effort to comply with safety standards can, if proved erroneous, result in an OSHA citation.

To minimize the risk of a citation, it is thus prudent for employers to evaluate whether their work may be subject to stricter OSHA standards than called for by current safety protocols.  If necessary, legal counsel should be consulted.  Such a review may avoid learning the hard way, as did Bergelectric, that the employer should have been following a stricter OSHA standard. Even if it is determined that the current safety protocols are correct, such an effort would help bolster the defense of an erroneously issued citation (which OSHA has been known to do) and show the commitment of the employer to compliance with OSHA directives.

Robert G. Chadwick, Jr. frequently speaks to non-profit organizations regarding occupational safety and health issues. To contact him for a speaking engagement, please e-mail him at rchadwick@realclearcounsel.com.