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No COVID-19 ETS Yet, But A National Emphasis Program And updated Enforcement Guidance | Constangy, Brooks, Smith & Prophete, LLP

336 Transportation Equipment Manufacturing Master List 2 is a list of all establishments listed in Appendix A and B  and having an elevated illness rate based on the 2020 OSHA 300A data. OSHA Area Offices are directed to use “either list or a combination of the two lists” to meet their targeted inspection goals. The Compliance Directive instructs that targeted inspections may begin at least two weeks after the effective date of the Directive, which was March 12. These inspections are to be conducted consistent with the “Updated Interim Enforcement Response Plan for COVID-19,” which was also issued on March 12. Under this Plan, inspections are to be conducted on site, “where practical,” but “phone and video conferencing in lieu of face-to-face employee interviews” will also continue to be used.

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