Retail & Consumer Products Law Observer

Retail & Consumer Products Law Observer

Legal Insight for the Retail and Consumer Products Industry

Daniel W. Wolff

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OSHA Revises Exemption for “Retail Facilities” from Its Process Safety Management Standard

Posted in Environment & Natural Resources
In a memo dated July 22, the Occupational Safety and Health Administration (OSHA) announced that it was revising its interpretation of the “retail facilities” exemption from its Process Safety Management (PSM) standard, as codified at 29 C.F.R. § 1910.119(a)(2)(1). The PSM standard requires employers to manage hazards associated with processes involving highly hazardous chemicals. The standard exempts… Continue Reading

To Label Or Not To Label? Companies May Have No Choice

Posted in Advertising & Product Risk Management, Environment & Natural Resources
Most everyone knows that the First Amendment restricts the government’s ability to limit commercial speech. Similarly, most everyone would probably think the First Amendment also restricts the government’s ability to compel commercial speech. But are there times when the government may compel commercial speech? Indeed it can in some circumstances, and the D.C. Circuit recently… Continue Reading