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2021 OSHA Policies and Audits: Mitigating Risks, Increased Enforcement, General Duty Clause Citations

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, June 23, 2021

Recorded event now available

or call 1-800-926-7926

This CLE course will advise employment counsel on the Occupational Safety and Health Administration's (OSHA) current focus and the enforcement actions and increased audits under the Biden administration. The panel will discuss the National Emphasis Program (NEP) programs to protect employees in high COVID-hazard industries from highly contagious diseases and from retaliation for raising safety health concerns with employers.


In March 2021, OSHA established an NEP related to COVID-19, to ensure that "employees in high-hazard industries are protected from the hazard of contracting SARS-CoV-2." Under the NEP, OSHA will target investigations and enforcement activities toward identified industries and worksites that have workers with increased potential exposure to this hazard.

Employment counsel should review the NEP and future OSHA publications updating targeted industries and provide their clients with counsel on: (1) whether their industry is "high-hazard" and a potential OSHA target for an on-site COVID-19-related inspection; (2) how their COVID-19 safety and health procedures can be updated to enhance worksite compliance and preparedness for COVID-19-related inspections.

Employers can expect to be subject to more COVID-19-related onsite inspections and the potential for general duty clause citations. With the March NEP underway, this is a critical time to review OSHA guidance on the pandemic and incorporate relevant measures into their safety planning and standard operating procedures.

Listen as our expert panel discusses the COVID-19 temporary standards established by OSHA and what the NEP has determined regarding all safety and health procedures for worksites. The panel will address the increased OSHA onsite inspections and best practices to respond to a general duty clause citation.



  1. NEP
    1. Types of workplaces covered
    2. Standards established by OSHA
    3. All COVID-19 safety and health procedures
  2. Consequences of increased onsite inspections
  3. General duty clause citations


The panel will review these and other relevant topics:

  • What types of employers are targeted by the NEP, and what should these employers expect?
  • How can employers ensure worksites are complying with all of OSHA's COVID-19 safety and health procedures?
  • As OSHA increases onsite inspections, what should employers expect?
  • How should employers respond to general duty clause citations?


Dubberly, David
David E. Dubberly

Nexsen Pruet

Mr. Dubberly chairs the firm’s Employment and Labor Law Group. In a career of over three decades, he has built a...  |  Read More

Hecker, A. Scott
A. Scott Hecker

Senior Counsel
Seyfarth Shaw

Mr. Hecker has advised clients and litigated on their behalf under numerous federal labor laws, including the...  |  Read More

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