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Court Holds OSHA Violated Notice-and-Comment Procedure with 2015 Retail Exemption Memorandum

Prepared for the Katten Safety Advisory Group
Advisory | September 27, 2016

Recently, the D.C. Circuit Court of Appeals ruled the Occupational Safety and Health Administration ("OSHA") violated the Occupational Safety and Health Act ("OSH Act") when it issued a "guidance" memorandum in 2015 titled "Memorandum on Process Safety Management of Highly Hazardous Chemicals and Application of the Retail Exemption" that narrowed the retail facility exemption in the Process Safety Management ("PSM") Standard. The new definition would, for the first time, have subjected up to 4,800 facilities to the requirements of the PSM Standard....

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