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November-December 2015

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palletcentral.com PalletCentral • November-December 2015 25 speculation that, by refocusing on these types of inspections, more General Duty Clause citations will be issued. OSHA also recently sought comment on a fast track rule aimed at reversing a recent court decision that limited OSHA injury/illness recordkeeping citations to the six-month statutory limitations period. OSHA seeks to be able to go back five years to cite employers for inaccurate or incomplete OSHA 300 log entries. Finally, OSHA will place greater emphasis on occupational health hazards, which could include a focus on wood dust. In October 2015, OSHA closed its comment period concerning how the agency can better update its permissible exposure limits (PELs) or otherwise require employers to protect workers against respirable air contaminants in the absence of sufficiently protective PELs. Indications are that this may lead to a controlled banding approach to health management, and enforcement, in the future. PC Adele L. Abrams is an attorney and safety professional who represents companies in litigation with OSHA and also pro- vides safety training and consultation. The Law Office of Adele L. Abrams PC has three offices: Beltsville, MD; Denver, CO; and Charleston, WV. Adele can be reached at 301-595- 3520 or www.safety-law.com.

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