By Eric J. Conn, Head of the OSHA Practice Group
On June 18, 2010 OSHA replaced its much-maligned Enhanced Enforcement Program (EEP) with a new and equally problematic initiative called the Severe Violator Enforcement Program (SVEP). The SVEP is intended to focus OSHA’s enforcement resources on those employers whom OSHA believes demonstrate indifference to their OSH Act obligations by committing certain types of violations, including:
- Any violation categorized as “Egregious”;
- One or more Willful, Repeat or Failure-to-Abate violations
associated with a fatality or the overnight hospitalization of three or more employees; - Two or more Willful, Repeat or Failure-to-Abate violations in connection with a high emphasis hazard (generally speaking, the subjects of OSHA’s special emphasis programs, including falls, amputations, grain handling, etc.); or
- Three or more Willful, Repeat or Failure-to-Abate violations related to Process Safety Management (prevention of the release of a highly hazardous chemicals).
Arnstein & Lehr’s West Palm Beach office recently received an award from Fidelity Title Company. The firm was recognized for being a Top 10 Agent in Palm Beach County. The award was granted based on the amount of money the office remitted back and the number of policies handled.
One of the initiatives we undertake here at the ILN is marketing partnerships, where we arrange for an in-kind trade of services for various events in the legal industry. When the events are fairly local to me, I’ll go in person to “woman” the table with our materials, answer any questions that might arise, and also sit in on the sessions.
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