Thank you to my colleague Bob Melvin for his contributions to the post below. Bob is a partner in the Environmental & Utilities Practice Group whose practice focuses on representing manufacturers with enforcement, compliance, and permitting issues.

On March 25, 2016, the Occupational Safety and Health Administration (“OSHA”) issued its final rule cutting in

Everyone knows that the permissible exposure limits or PELs set forth in various OSHA standards are pretty old (most have not been updated since 1971), and that we’ve learned a lot about chemical exposure and human health in the years since those PELs were originally published.  OSHA knows it, too.  Furthermore, of the thousands of

In a press release dated Thursday, Oct. 24,  OSHA let industry know that it was issuing guidance for employers in the form of “Annotated Permissible Exposure Limits.”  Recognizing that its published Permissible Exposure Limits or PELs (i.e., the concentrations of chemicals to which an employee can be safely exposed during a work shift) are