eei - osha updateesafetyline.com/eei/conference s/2017spring... · ogletreedeakins.com eei - osha...

.

ogletreedeakins.com

EEI - OSHA UPDATE April 25, 2017

Presented by: Melissa A. Bailey (Washington, D.C.)

[email protected]

202 887-0855

.

© 2016, Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

Atlanta / Austin / Berlin / Birmingham / Boston / Charleston / Charlotte / Chicago / Cleveland / Columbia / Dallas / Denver / Detroit (Metro) / Greenville

Houston / Indianapolis / Jackson / Kansas City / Las Vegas / London / Los Angeles / Memphis / Mexico City / Miami / Milwaukee / Minneapolis

Morristown / Nashville / New Orleans / New York City / Orange County / Philadelphia / Phoenix / Pittsburgh / Portland / Raleigh / Richmond

San Antonio / San Diego / San Francisco / Seattle / St. Louis / St. Thomas / Stamford / Tampa / Toronto / Torrance / Tucson / Washington, D.C. www.ogletreedeakins.com

Agenda

Update on Amended Recordkeeping Rule

Electronic submission

Status of online portal

Will OSHA still post the data?

Status of challenge to anti-retaliation provisions: Safety

incentive programs and drug testing

Volks Repeal

Legal Updates (silica, cranes, PSM, fall protection)

Silica – Status of Lawsuits

Cranes – Proposed amendments

2





Agenda (cont.)

PSM/RMP Update – status of the revisions

Amended Fall Protection Standard – impact on electric

utilities

Enforcement Update

Scott Mugno: Next Asst. Sec. of Labor?

OSHA’s Shaming Campaign: Over?

Will Trump “turn the ship?”

Case law updates – Ag Retailers

3





Update: Recordkeeping Amendments

On May 12, 2016, OSHA amended the Recordkeeping

regulation

Some employers required to electronically submit injury and

illness records to OSHA annually

Provisions requiring a “reasonable” system for employees to

report injuries and prohibiting retaliation

4





Recordkeeping Amendments

Employers with establishments of certain sizes must

submit injury and illness data electronically, including

OSHA 300 Logs and 301 forms

OSHA will post data on the internet

Because the data will be public, employers will look for

ways to deter employees from reporting injuries and

retaliate when they do

5





Filing Dates

Beginning in 2019, reports due on March 2 of each year

6





Online Portal Update

No online portal yet to submit

OSHA 300’s

OSHA missed internal

deadline to go live

First compliance deadline fast

approaching – 7/1/17

Will it get done in time?

Compliance deadline delay?

7





Publication of OSHA 300 Data

Even if online portal is finished, does OSHA still plan to

publish data online for public view?

Final rule was clear agency would make data public

Statement confirming this was recently removed from

website

Will new OSHA leadership complete the project?

Will OSHA get congressional appropriation to complete portal

and publish data?

8





Anti-Retaliation Provisions

Section 1904.35(b)(1)(iv): Anti-Retaliation

Employers “must not discharge or in any manner discriminate

against any employee for reporting a work-related injury or illness”

January 2014: Public Hearings

“Prevalent concern” was creating “motivations for employers to

under-record injuries and illnesses, since each covered

establishment’s” data would be public

“Some employers already discourage employees” from reporting by

“disciplining or taking other action against employees” who are

injured

Blanket post-accident drug testing and safety incentive plans are

ways employers deter employees and engage in retaliation

9





Proof Scheme

OSHA’s proof scheme:

The employee reported** a work-related injury or illness;

The employer took adverse action against the employee

(that is, action that would deter a reasonable employee from

accurately reporting a work-related injury or illness); and

The employer took the adverse action because the employee

reported a work-related injury or illness

** Important implication: Employee doesn’t “report” it

(broken leg at work) – provision does not apply

10





Anti-Retaliation Provisions

Drug Testing Policy

Safety Incentive Programs





Drug Testing as a Violation

How can a post-accident drug test be a violation?

Employee reports a work-related injury

Employer’s policy states: any employee who requires

medical treatment will be drug tested

Employee complains to OSHA that injury was reported and

employer retaliated by mandating drug test where it was not

warranted

12





Drug Testing: Compliance Guidance

OSHA will consider the following:

Reasonable basis for testing?

Were other employees involved in the accident tested?

Does the employer have a “heightened interest” in identifying

drug impairment given the hazardousness of the work?

Testing conducted to comply with other state and

federal laws is not retaliatory

Blanket testing to obtain workers’ compensation

discount not retaliatory

13





Drug Testing: Compliance Guidance

Examples:

Employee with carpal tunnel syndrome tested under blanket

policy – retaliatory

Employee drives forklift into stationary piece of equipment –

not retaliatory

Employer does blanket testing based on bargaining

agreement provision – test could be retaliatory; CBA offers

no protection

14





Incentive Plan as a Violation

Employer administers a policy that takes a bonus away

from employees when a recordable injury is reported

Employee reports an injury and employee or group of

employees lose a bonus

Employee complains to OSHA

Employee reported an injury

Employer took an action – taking away the bonus – that

would generally deter reporting

Employer took that step because the injury was reported

15





Incentives – Compliance Guidance

Incentive programs not banned

“If an employee reports an injury or illness, and is

subsequently denied a benefit as part of an incentive

program, this may constitute retaliatory action”

Employers should encourage programs that reward:

Worker participation in safety programs/activities

Completion of training

Reporting hazards and near misses

Participation in auditing

Compliance with work rules

16






Scenario 1 – Retaliatory

Employees not permitted to participate in monthly cash

drawing for “substantial cash prize” because one employee

reports a lost-time injury

No safety rules violated

Employer retaliated by cancelling drawing “solely because an

employee was injured and reported the injury without regard to

the circumstances surrounding the injury”

17






Scenario 2 – Not Retaliatory

Employer holds drawing for “substantial cash prize” when no

employees disciplined for violating safety rules

Employee X has lost-time injury resulting from failure to wear

fall protection

Employer cancels the drawing

Drawing cancelled because “Employee X violated a legitimate

work rule,” not because injury reported

“OSHA encourages employers to enforce legitimate workplace

safety rules by monitoring for compliance with those rules and

taking consistent, appropriate corrective action”

18






“Blended” programs

Component of employee bonus based on unit or company

meeting injury/illness rate goals

OSHA does not address these programs in compliance

guidance

VPP Memo #5 is still “good law”

19





Industry Challenges Amendments

NAM, ABC, Great American Insurance, and others

challenge reporting/anti-retaliation provisions in TX

Focus is post-accident drug testing and safety incentive

programs

Section 11(c) (OSH Act whistleblower provision) provides the

remedy for retaliation

OSHA has no authority to create a new remedy

OSHA says repeatedly that this is not new – Section

11(c) already prohibits this behavior

Does OSHA have the authority to create a new

remedy?

20





The Lawsuit

11/28: Judge denies the motion for a preliminary

injunction

Evidence from employer groups too conclusory (We

“believe that incentive programs/drug testing reduce

injuries…”)

No per se ban on testing or incentives, and “plenty of

room” to modify programs

Decision on the merits “left for another day”

21





Two Lawsuits

National Association of Home Builders of the United

States et al v. Perez et al (OK): Industry challenges

recordkeeping rule. OSHA’s counsel asks judge to

delay litigation to talk settlement

Texo ABC/AGC et al. v. Perez (TX): Same request

made by OSHA’s counsel.

22





Trump’s Options to Repeal

OSHA’s counsel waves the white flag?

DOJ may concede plaintiffs’ position and settle

More rulemaking?

Repeal through notice-and-comment rulemaking – takes time

and resources

Withdraw compliance guidance?

Withdraw all of the compliance guidance and announce that

post-accident drug testing and administration of safety incentive

programs are not violations of provisions

Unofficial “reluctance” to issue citations

23





What Happens Next?

At end of the day…Section 11(c) is still there

Even if anti-retaliation provisions are eliminated and OSHA

cannot issue a citation for retaliation, employees can always

file an 11(c) claim

Remedies are limited – if OSHA does not find cause,

employee has no right to hearing before an ALJ or District

Court

Plaintiffs’ attorneys have gotten smart: Look for another

statute that may apply to allow for a hearing,

backpay/punitive damages, reinstatement and attorney’s fees

24





Volks Recordkeeping Issue

Statute of limitations for OSHA violation: 6 months

OSHA’s position on recordkeeping

Violations are “continuing”

An injury not recorded on January 1, 2015 is still unrecorded on

January 1, 2017 – violation of the regulation

Statute of limitations for a recordkeeping violation is 5 years

plus 6 months

Volks D.C. Circuit: OSHA, you’re wrong.

OSHA circumvents court and issues new rule: 5 years plus

6 months to issue recordkeeping citations.

The end?.......

25





Volks Recordkeeping Issue

D.C. Circuit in Volks: OSHA is wrong – 6 months

means 6 months

5th Circuit in Delek: Same reasoning applies to certain

PSM violations

OSHA does not appeal

Instead, OSHA issues final rule changing the recordkeeping

regulation to “clarify” the statute of limitations

How can OSHA change its own statute of limitations?

26





Volks Regulation Repealed

Congressional Review Act – repeal regulation within

60 days of implementation

House and Senate vote to repeal regulation

President Trump repeals regulation on 4/3/17

What happens now?

OSHA is not permitted to promulgate a “substantially similar”

regulation

The Good: OSHA cannot enforce beyond 6 months

The Bad: Much less incentive to record properly; “bad

apples” are rewarded





Rulemaking Updates: Silica, Cranes,

PSM and Walking/Working Surfaces





Silica – Multiple Challenges

Labor argues the rule doesn’t go far enough…

North America’s Building Trades Unions v. OSHA (D.C. Cir.): medical

testing provisions must be improved

United Auto Workers (UAW) (3RD Cir.): new PEL of 50 of µg/m3 is too

low – should be 25 µg/m3 or lower

Industry argues rule goes too far…not technologically and

economically feasible

National Stone, Sand & Gravel Association (NSSGA) (11TH Cir.).

Challenges also filed in 5th, 8th and 10th Circuits.

Cases consolidated under D.C. Cir. North America’s

Building Trades Union





Silica

Final briefs filed 3/23/17

OSHA’s position:

“It is undisputed that silica causes serious, even fatal, health

effects in exposed workers”

PEL and other provisions are appropriate

Secretary of Labor nominee Alexander Acosta

declined to commit to defending the silica rule during

congressional testimony

What’s next? Would new regime at DOL/OSHA decline

to defend the rule in court?





Silica – Legal Update

4/6/17: OSHA announces enforcement delay of silica

standard for construction

Original date: 6/23/17

Now: 9/23/17

Delay so that OSHA can “conduct additional outreach and

provide educational materials and guidance for employers”

“The agency has determined that additional guidance is necessary

due to the unique nature of the requirements in the construction

standard”

Rumor mill: compliance documents are far from being completed;

input of new Administration needed





Crane Amendments – Will They Happen?

Two planned amendments in 2016, but will they ever

get done?

1) General amendments to crane standard; e.g.,

clarifying and correcting standard terms, clarifying the

use of demarcated boundaries for work near power

lines.

Last update: NRPM expected by Oct. 2016

Nothing issued






2) Revising Operator Certification Requirement: OSHA

expected to issue a proposal stating that ongoing

evaluations of operator competency are required; 3rd

party certification no longer sufficient

Operator certification deadline extended to Nov. 2017

Dec. 2016: Report that OSHA was close to sending proposal

to OMB for review

No indication that ever happened

Will compliance deadline be delayed?






Underground issue

Range of material handling equipment used in underground

construction, beyond digger derricks

No exemption for underground construction equipment other

than digger derricks (e.g. knuckle booms)

Hazards are arguably less significant than those presented

during overhead construction

Underground environments typically do not have exposed

energized parts

Materials moved close to ground level

Is OSHA willing to expand the digger derrick exemption to

cover equipment used in this work?





PSM/RMP Updates





Revised RMP Rule – Two Categories

Accident Prevention Program Revisions

Emergency Response Enhancements





Revised RMP Rule

Third Party Audits – Facility must use an independent

third party to conduct its next scheduled audit if it has

had a RMP reportable accident or a recent finding of

non-compliance

The auditor would have to meet the criteria for auditor

competence and independence

Incident Investigations and Root Cause Analysis –

Incident investigation after any incident that resulted in

or could have resulted in a catastrophic release

Report completed within 12 months





Revised RMP Rule

Local Coordination – Increased communication with

Local Emergency Planning Committees (LEPCs) by

requiring annual coordination by facilities with LEPCs

to clarify response needs, emergency plans, roles, and

responsibilities

Emergency Response Exercises – Annual emergency

notification response exercises

Periodic tabletop and field exercises would also be required





Revised RMP Rule – On Hold

Currently stayed through at least June 19, 2017

EPA has proposed extending the stay until February 19,

2019

Public hearing was held on Wednesday, April 19th.

Written comments due May 19th.

No obligation to implement new requirements while stay is place.

While CRA is unlikely, Rule may be modified

EPA Administrator Pruitt authored a letter opposing the RMP

Revisions while he was AG for the State of Oklahoma

ACC and others challenged Rule; unions and public

interest groups intervened





Revised RMP Rule – On Hold

Practical impact

EPA’s interprets its General Duty Clause as broader than

OSHA’s

[And does not seem shy about using it]

Will EPA career staff look to “enforce” proposed provisions

through the General Duty Clause?





2017 PSM Covered Chemical Facilities NEP

Replaces the 2011 Chemical NEP

Potential Inspection Targets

1) Employers whose principal highly hazardous chemical is

anhydrous ammonia

(2) Refiners

(3) Chemical manufacturers; and

(4) all others (TQ of chlorine at electric utility)

41






Selecting the Inspection Sites

Each year, OSHA’s national office intends to create a target

list of facilities to be inspected within each OSHA Region.

Within each region, the breakdown for non-refinery,

programmed inspections will be as follows:

Group 1 facilities will comprise roughly 25 percent;

Group 3 facilities will comprise 45 percent;

Group 4 facilities will comprise the remaining 30 percent.

Group 2 refineries – will like all be inspected at some point

42






Before the Inspection

OSHA will review the facility’s RMP submission

Emphasis on RMP reportable accidents

Offsite consequence analysis

During the Inspection

OSHA will use a dynamic list of questions

The inspection will include a concurrent inspection of onsite

contractors

After the Inspection

“Violations of the PSM standard should not normally be classified

as ‘other-than-serious’”

Notification to EPA of findings are encouraged

43






PSM NEP inspections are a unique animal

Lengthy and burdensome

Strategic questions about how much information to prepare

in advance

Significant cooperation with EPA seems to be a reality this

time

SVEP implications

Will OSHA have the resources?

44





Important PSM Case

Delek Refining, LTD

v.

Sec. of Labor

December 29, 2016

(U.S. Court of Appeals for the 5th Circuit)





Delek

The Good

The OSH Act Statute of Limitations applies to PSM Citations

Applicability breadth? Unknown

“We, like the Volks court, do not decide whether OSHA may be

able to use the continuing violations theory to toll Section

658(c)’s statute of limitations in cases involving continuing,

unlawful risks to employee health and safety”

Applies at least to:

1910.119(e)(5) citations – failure to address PHA

Recommendations

1910.119(o)(4) citations – failure to respond to audit findings





Delek

The Bad

Scope of process equipment and the related mechanical

integrity inspection requirements broadened considerably

Safety equipment likely considered “process equipment” under

the PSM Standard as it “mitigates” the consequences of a

catastrophic release

E.g. a control room positive pressurization unit (PPU) is

considered process equipment subject to the mechanical

integrity inspection requirements

Possible expansion?

Safety showers? Eye wash stations?

Fireproofing on structures?





Delek

The Ugly

Broad application of the OSH Act’s Statute of Limitations may

shift process safety enforcement away from OSHA and

towards the EPA

EPA's enforcement of the RMP rule is more protracted, less

transparent and much higher penalties





Revised Walking/Working Surfaces

and Fall Protection Standard





Final Rule





Final Rule – Dates

Final rule: November 18, 2016

Effective date: January 17, 2017

Training required by May 17, 2017

Some equipment grandfathered – changes not

required until equipment replaced





Fall Protection Methods

OSHA’s goals

Consistency with construction standards

Flexibility in type of method used

Engineering control – guardrail, safety net system

PPE – personal fall arrest system, travel restraint, positioning

systems

Designated areas if certain conditions met





Final Rule

1910.28 – Fall protection options when work is performed

at heights over 4 feet:

Guardrail system

Designated areas (infrequent, temporary work more than 15

feet from the edge)

Safety net system

Travel restraint system

Personal fall arrest system

Alternate systems for residential roofs where traditional fall

protection is not feasible






Section 1910.28: Duty to protect from fall hazards

Exemptions

Portable ladders

When inspecting or assessing work conditions prior to start of

work or after work is completed; if system is present, must be used

All work covered by Section 1910.269(g)(2)(i)

Specifications for fall protection equipment

Fall protection from aerial lifts

Pole/tower climbing

Result: Little impact on T&D work; some impact on

generation






Work on low-slope roofs

Less than 6 feet from edge – guardrail, net system, travel

restraint or personal fall arrest

More than 6 feet, but less than 15 feet – designated area if

work is infrequent and temporary

15 feet or more – no protection if infrequent and temporary






If infeasible or greater hazard on residential roof, fall

protection plan that meets 1926.502(k)

Controlled access zone

Presumption that fall protection is feasible

Training requirements

*** Burden on employer to prove infeasibility or greater

hazard






Fixed ladders more than 24 feet above lower level

Ladder safety or personal fall arrest system must be installed

New ladders installed after 11/19/18

Repaired or replaced on or after 1/17/17

By 11/18/36 – all ladders must be compliant

“Gradual phasing out of cages and wells means that

employers may continue to use existing fixed ladders during

the 20-year phase out period”





Equipment Changes

Ladderway openings – 1910.28(b)(3)(iv)

“Self-closing gate” must be used

Purpose: “Provide a means of access to ladderway floor

holes and, when closed, to provide guardrail protection”

Use of chains explicitly rejected





Equipment Changes

Ladders – 1910.23

Specifications on rungs and steps are consistent with ANSI

standards and flexible, e.g. ladder rungs – between 10 and

14 inches wide; vertical spacing for step stools between 8

and 12 inches

Exception for manhole ladders – 9 inches wide

Ladder safety rules, e.g. three-point contact

7 inches minimum clearance from permanent objects in back

of the ladder – no grandfather provision

Non-caged ladders – general rule is 30 inches of space

between centerline and nearest object on climbing side (no

grandfather)





Equipment Changes

Step Bolts

Corrosion resistant (GF)

Uniform spacing (12 – 18 inches), width of 4.5 inches, 7

inches clearance in back (4.5 inches if obstruction (no GF))

Existing step bolts – support maximum intended load

Installed after 1/1/17 – support four times maximum intended

load





Equipment Changes

Step Bolts/Manhole Steps – 1910.24

“Construction” v. “Maintenance” distinction is important

OSHA’s goal is to harmonize requirements

Reason for climbing with step bolts or using manhole steps will

dictate which standards apply

Grandfather provisions – most provisions apply only to steps

installed after effective date (1/1/17)

New construction

Regular inspection reveals that equipment must be replaced





Equipment Changes

Manhole steps installed after 1/1/17

Slip-resistant

Corrosion resistant if dictated by environment

Minimum step width of 10 inches, uniform step spacing 4.5

inches clearance from the back

Properly designed, constructed, maintained





Fall Protection Training

Training must include

Fall hazards in the area and how to recognize them

Required procedures

How to maintain systems used

Correct use of PPE

Retraining when changes, evidence that employee does not

understand

Training completed by May 17, 2017





General Provisions

Section 1910.22(a)(3): Ensure walking-working

surfaces are free from hazards like “loose boards,

corrosion, leaks, spills, snow, ice and sharp or

protruding objects”

Ensure “all walking-working surfaces are maintained

free of recognized hazards”

Includes “working place” and “passageway”

Scope broader than “slips, trips and falls”

Example: Nail protruding from a wall could pose a hazard if

an employee bumps into it





Motor Vehicles

Fall protection while working on motor vehicles, such as

headache racks of trucks

No specific requirements for fall protection on motor

vehicles

Final Rule: “this Final Rule does not include any specific

requirements for fall protection on rolling stock and motor vehicles

and OSHA's current existing enforcement policies on rolling stock

and motor vehicles will remain in effect.” 81 Fed. Reg. 82494,

82505 (Nov. 18, 2016)

“Since the Agency did not propose any specific fall protection

requirements for rolling stock or motor vehicles, OSHA has not

included any in this final rule.” 81 Fed. Reg. at 82509





Motor Vehicles

10/18/96 OSHA LOI: it is not appropriate to cite

employers for fall hazards on rolling stock under the

walking-working surfaces standards

Same is true for GDC unless feasible means of abatement

exists

Erickson Air – no notice of duty to provide fall

protection

OSHA states that the “walking-working” surface

definition includes motor vehicles





Motor Vehicles

OSHA believes it is technologically feasible to provide

fall protection on motor vehicles “in many cases.”

Final Rule: OSHA “believes the evidence employers and

industry associations submitted shows it is technologically

feasible in many cases for employers to provide fall

protection for rolling stock and motor vehicles regardless of

their location”

OSHA will “continue to consider the comments it has

received” and “may determine whether it is appropriate

to pursue any action on this issue”

GDC citation?





OSHA Enforcement Update





Our Next Sec. of Labor?

Alexander Acosta





Possible Next Sec. of Labor: Alex Acosta

History of public service

2002: Member of National Labor Relations Board

2003: Assistant Attorney General for the Civil Rights Division of the

United States Department of Justice

2005: U.S. Attorney for Southern District of Florida

Most recent position: Dean of Florida International

University College of Law (2009 – present)

2/16/17: Trump announces Acosta as Sec. of Labor pick

Hearings completed and voted out of Senate HELP

Committee

Confirmation vote expected week of 4/24 or 5/1





Alex Acosta: The Future of OSHA

Regulation

Good for regulation and labor?

Acosta endorsed by unions (Firefighters, Operating Engineers,

LIUNA)

Mainstream reputation with public service experience

Or not…

At Senate confirmation hearings, Acosta declined to confirm

whether he would enforce new silica rule

Acosta: “The president has directed each cabinet officer to review all

rules. I cannot make a commitment because the Labor Department

has an order to review all rules”

Senator Elizabeth Warren (D-Mass.): Acosta is “hiding behind

[Trump’s] executive order”





Our Next Asst. Sec. of Labor?

Scott Mugno

VP of Safety, Sustainability and Vehicle Maintenance

at FedEx Ground





Our Next Asst. Sec. of Labor: Scott Mugno

Started with FedEx in 1994

In-house Counsel

2000 – 2011: Managing Director, Corp. Safety, Health and Fire

Prevention

2011 – Present: VP of Safety, Sustainability and Vehicle

Maintenance

Critical of FMSCA’s Compliance, Safety, Accountability

(CSA) program, which identifies operators with the highest

crash risk – measures all crashes, regardless of fault.

“[We’re] frustrated by the delays in resolving this fundamental flaw

in the system [as it] now appears that FMCSA may not be poised to

even propose a solution, let alone implement one, until three years

after the agency first began studying the issue.”





Our Next Asst. Sec. of Labor: Scott Mugno

Sunset Provisions

In 2006, Mugno suggests some OSHA standards should be

terminated at the end of a fixed period, unless renewed.

“We've got to free OSHA from its own statutory and regulatory

handcuffs.”

Increased employee responsibilities

In 2006, Mugno suggests employees need to get more involved in

safety matters

“We’ve got to look harder at the employee”

Part of greater discussion that OSH Act does not address employee

responsibilities





Enforcement Update

Is Dr. Michaels’ public shaming campaign over?

Only two enforcement press releases since Trump took office

Effect: will make settlement more tenable.

Future of SVEP?

Will political appointees be able to “turn the ship?”

Eliminating press releases is fairly easy, but how do you

prevent an Area Office from issuing unwarranted “willful”

violations?

Can/will the Solicitor’s Office serve as a moderating force?





The “New” OSHA and EPA

Budget impact on process safety enforcement

What impact will budgeting play?

21% cut in Dept. of Labor Budget ($2.5 Billion)

Increased focus on compliance assistance?

Proposed elimination of OSHA’s Susan Harwood Training

Grant Program ($11Million)

25-30% cut in EPA Budget ($2.6 Billion)

Staff reduction of 25%

Proposed elimination of voluntary activities

Elimination of the Chemical Safety Board





Questions?





Thank You

78

Melissa A. Bailey Ogletree Deakins, Nash,

Smoak & Stewart, P.C.

1909 K Street, N.W.

Suite 1000

Washington, DC 20006

Phone: 202-887-0855

[email protected]

.

ogletreedeakins.com

EEI - OSHA UPDATE April 25, 2017

Presented by: Melissa A. Bailey (Washington, D.C.)

[email protected]

202 887-0855

.

© 2016, Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

eei - osha updateesafetyline.com/eei/conference s/2017spring... · ogletreedeakins.com eei - osha...

Documents