Partner Wayne D’Angelo co-authored the Safety Outlook article “Countdown to Quitting Time: The Administration’s Final Push to Lock in a Health & Safety Legacy.” The article focuses on the types of regulatory and non-regulatory rulemaking to expect from the Occupational Safety & Health Administration (“OSHA”) in 2016. First, they discuss “traditional rules,” which can be predicted pretty accurately because they have already been proposed and scrutinized extensively. They go on to discuss guidance and policy statements that will not go through notice-and-comment rulemaking but which may have the same practical impact on the regulated community, referred to as “sleepers”. Finally, they discuss OSHA’s expected actions pursuant to an interagency effort to prevent catastrophic chemical releases at industrial facilities. These “interagency actions” consist of a mixture of “traditional rules” and non-regulatory “sleepers.”
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