In what amounts to a significant explansion of the existing regulations and OSHA's own internal Field Operations Manual into the arena of labor and management relations, a recently-released OSHA Interpretation letter states that anyone may be designated by workers at a non-union facility as their "representative" during an OSHA inspection.
Our latest Labor & Employment Alert takes a closer look at OSHA's Interpretation letter and what employers can expect going forward. As the Alert suggests, employers are well advised to consult with qualified counsel to discuss how to hande this situation in advance of the actual inspection request. A link to the full Alert appears below. Barnes & Thornburg LLP - " OSHA Interpretation Letter Allows Non-Union Employees to Designate Union Personnel as “Representative” During OSHA Inspection."
OSHA: Non-Union Employees May Designate Union Reps as "Representative" During Inspection
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