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Eric Conn Quoted in Article, "New OSHA Enforcement Memo Targets Safety Incentive Programs, Retaliation"

Bloomberg BNA, 3/12/2012

Eric Conn, a Member of the Firm in the Labor and Employment practice, in the Washington, DC, office, was quoted in an article titled "New OSHA Enforcement Memo Targets Safety Incentive Programs, Retaliation," written by Bruce Rolfsen.

Following is an excerpt:

A new guidance memo from the deputy director of the Occupational Safety and Health Administration calls for increased attention by agency compliance officers and investigators to whether disciplinary and safety incentive programs violate safety regulations.

Conn sees the memo as a continuation of OSHA's emphasis on enforcing recordkeeping rules.

He told Bloomberg BNA March 20 that if an inspector concludes an employer should have been aware that an incentive program would dissuade workers from reporting injuries, the employer might face a costly citation for a willful violation.

Conn said he is advising clients with incentive programs to send a "clear message" to employees to report all injuries.

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