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Peter Knight is a partner at the law firm Robinson + Cole's Environmental, Energy + Telecommunications Group, where he focuses on litigation, defense of agency enforcement actions, and regulatory matters. Read more about Peter.
As OSHA practitioners and environmental, health and safety professionals know, avoiding repeat citations is often a central issue when resolving an OSHA enforcement matter. OSHA policy instructs the agency to consider several factors when determining whether to characterize a citation as “repeat.” One of those factors involves a situation in which there has been a change in corporate structure or ownership between the initial and subsequent violations.
Friday, March 13, 2020 is often viewed as the day America began to feel the impact of COVID-19. The following week, businesses throughout the country either transitioned to remote work or had to reckon with how to operate in a different manner while trying to protect workers from exposure to the virus.