After Hours: OSHA Can and Will Use Employers' Own Internal Safety Audit Reports as a Roadmap to Cite Them: Tips for How Employers Can Respond

According to a long-standing published policy, OSHA will not use an employer’s own, voluntary safety and health audit as a roadmap to identify potential OSHA violations. A recent Review Commission decision, however, blessed OSHA’s use of an employer’s draft internal audit report as a guide to potential violations, blatantly ignoring OSHA’s Policy. This podcast will provide guidance for employers in responding to OSHA’s requests for internal audit reports and strategies for protecting reports from disclosure.

After Hours is Arent Fox’s online resource for general employment law and labor-management issues. It offers new video features addressing topics and issues of interest to in-house counsel and human resources professionals.

About the Labor & Employment and OSHA Practices

Arent Fox’s Labor & Employment and OSHA practices are nationally recognized as leaders in their field. Chambers USA, the leading attorney ranking publication, has described Arent Fox labor attorneys as “thoughtful, responsive, creative, and diligent.” Arent Fox is proud to have one of the only groups in the country with attorneys that focus solely on OSHA matters.


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