Meeting Archive:
Everything You Never Wanted to Know about OSHA Repeat, Willful and Egregious Violations

Meeting Description:

Everything You Never Wanted to Know about OSHA Repeat, Willful and Egregious Violations

Tuesday, October 16, 2018 at 1 PM ET

Presented by Eric J. Conn and Amanda R. Strainis-Walker

During the Obama Era, OSHA sharpened its enforcement teeth considerably by rewriting policies to characterize more violations as repeat and willful and by increasing its penalty authority by 80%. Now, OSHA violations characterized as Repeat or Willful carry penalties up to $126,000 each. But what are Repeat and Willful violations? And what are these “Egregious” (or per-instance) citations OSHA has been issuing more and more to generate multi-million dollar enforcement actions?
This webinar will explain the legal standard for Repeat, Willful and Egregious violations, the circumstances most often associated with them, the consequences for receiving them, and how OSHA’s enforcement policies have resulted in significant increases in the frequency with which we see them.


Participants in this webinar will learn:
  • The legal standards OSHA must meet to establish Repeat and Willful violations
  • Background and details about OSHA’s Egregious / Per-Instance Enforcement Policy
  • Policy changes that have resulted in more Repeat and Egregious violations
  • Impacts of these aggravated characterizations, including qualifying into the Severe Violator Enforcement Program, facing criminal charges, etc.
  • What employers should do to avoid Repeat and Willful citations

Date: Tue, Oct 16, 2018
Time: 01:00 PM EDT
Duration: 1 hour 15 minutes
Host(s): Eric J. Conn and Amanda R. Strainis-Walker
 Presenter Information
Eric J. Conn
Speaker Photo

Eric J. Conn is a founding partner and Chair of the national OSHA • Workplace Safety Practice Group at the law firm Conn Maciel Carey LLP, where he focuses his practice on all aspects of occupational safety & health law.  Mr. Conn represents employers in inspections, investigations and enforcement actions involving OSHA, the CSB, MSHA, EPA and state and local safety related agencies.  He also handles all aspects of OSHA litigation, from criminal prosecutions to appeals of citations. 

Mr. Conn also conducts and directs attorney-client privileged workplace safety audits, delivers safety training, and helps employers develop and implement compliant safety and health programs.  He writes and speaks extensively on safety & health law issues, including authoring chapters in multiple OSHA Treatises.

Amanda R. Strainis-Walker
Speaker Photo

Amanda R. Strainis-Walker is a partner with Conn Maciel Carey LLP. She focuses on occupational safety and health (OSHA) law. Prior to private practice, she was a Presidential Appointee at the U.S. Department of Labor as a Special Assistant to the Assistant Secretary of Labor for OSHA, and then as an attorney in the Office of the U.S. Solicitor of Labor, where she advised her clients, OSHA and MSHA, on a diverse range of legal and regulatory issues.



For more information about our OSHA Practice Group, visit the OSHA Practice page on our website.  Also, check out our OSHA Defense Report blog.