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OSHA Policy Changes Expanded Enforcement

February 21 @ 10:00 am - 11:30 am


On Thursday, January 26, 2023, the Occupational Safety and Health Administration (OSHA) issued new enforcement guidance making it easier for Area Offices in Illinois to issue significantly larger penalties when citing employers that it contends have failed to comply with certain workplace safety and health requirements. This important development follows close on the heels of the changes OSHA announced last September to the agency’s Severe Violator Enforcement Program (SVEP), which enable the agency to place more employers into this dreaded program. Taken together, these two developments significantly increase the likelihood that even well-meaning employers will be subject to six (or even seven) figure citations and shaming press releases. Are you prepared?

Join us for a deep dive into what these changes mean for Illinois manufacturers and action steps you can implement to keep your employees safe and avoid messy entanglements with OSHA.


• “Instance-by-Instance” for cases where the agency identifies “high-gravity” serious violations, including lockout/tagout, machine guarding, permit-required confined space, respiratory protection, falls, trenching)
• Increased authority to inspectors to “Not Group” violations and instead cite them separately
• Changes to OSHA’s SVEP and how you might be at risk for referral into this program
• 2022 OSHA enforcement data and important case decisions
• The future of OSHA enforcement during the Biden Administration
• Rulemaking initiatives and predictions
• Significant OSHA policy issues to consider this year


Aaron R. Gelb | Partner, Conn Maciel Carey

Aaron R. Gelb is a partner in Conn Maciel Carey’s Chicago office where he regularly advises and represents clients in relation to inspections, investigations, and enforcement actions involving federal OSHA and state OSH programs, while managing a full range of litigation against OSHA. Mr. Gelb also litigates EEO matters in federal and state courts (having tried several cases to verdict) and defends employers before the EEOC and fair employment agencies across the country.


Contact Name: Terri Graham

Contact Email: tgraham@ima-net.org


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