According to a recently issued OSHA memorandum, over twenty years’ worth of statistics show that upstream oil and gas production operations are plagued by fatalities at a rate five to eight times greater than the national average. Based on these alarming statistics, OSHA implemented a new policy under its Severe Violator Enforcement Program (“SVEP”) captured by Instruction CPL 02-00-149 Section XI, which endeavors to curb industry fatalities. The memorandum concerning this new SVEP Section was quietly issued to field officials and attorneys at a recent…
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If an OSHA inspector, known as a compliance safety and health officer (CSHO), arrives at your door, presents his or her credentials, and asks for you to consent to an inspection of your workplace, what do you do? If you consent, what should you expect to happen next? And if you refuse to consent, then what? Obviously it would be wishful thinking to conclude that the CSHO would simply leave, bid you good day and never come back. These rather elementary questions are among the…
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