By Eric J. Conn, Head of the OSHA Practice Group
Back in September, we posted an article critiquing OSHA’s Severe Violator Enforcement Program (“SVEP”) in general, and the newly announced “exit criteria” in particular. Since that time, in the beginning of October, OSHA updated its embarrassing SVEP Log that it maintains for public consumption on the OSHA website. With the new data included on the SVEP Log, we thought this would be a good time to provide an update about the SVEP, including: