The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013 ). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Applying PSM / RMP to Oil and Gas
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Mandatory Updating of Defining RAGAGEP
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Defining Recognized and Generally Acceptable Good Engineering Practices
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Atmospheric Storage Tanks
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating
OIG Issues Advisory Opinion on Preferred Hospital Network Proposal
The OIG issued Advisory Opinion 15-3 to address an arrangement proposed by a licensed offeror of Medicare Supplemental Health Insurance (“Medigap”) policies (the “Requestor”), in which the Requestor would indirectly contract with a preferred hospital organization (“PPO”) having contracts with a national network of hospitals (the “Network Hospitals”) for discounts on otherwise-applicable Medicare inpatient deductibles
Spoliation of Evidence in Louisiana
Spoliation of evidence is the evidentiary doctrine that refers to destruction or significant alteration of evidence, or the failure to preserve evidence, for another’s use as evidence in pending or future litigation. While there can be a statutory duty, a contract, a special relationship between the parties, or an affirmative agreement or undertaking to preserve
LDEQ Now Limits Term for Minor Source Air Permits and Requires Update for Such Existing Permits
In the past, Minor Source Air Permits issued by LDEQ typically did not have an expiration date. That has changed. Per Louisiana Revised Statute 30:2023(A), all environmental permits issued by the Louisiana Department of Environmental Quality (“LDEQ”) “shall have, as a matter of law, a term of not more than ten years.” Louisiana’s air quality
OIG Would Not Sanction Arrangement Involving Payment to Excluded Provider for Pre-Exclusion Services
The latest OIG Advisory Opinion, issued February 9, 2015, addresses the issue of sharing federal health care program payments with an excluded practitioner. While federal statutes prohibit payment by any federal health care program, including Medicare or Medicaid, for items or services furnished by an excluded person or furnished at the medical direction or on
Mardi Gras Season; Travel Season: Why Louisiana Employers Must Also Consider the Legalization of Marijuana
For many Louisianans, the Mardi Gras and President’s Day office and school closures equate with travel time. For some, it will mean a time to flock west to hit the slopes – including in Colorado, a state that has legalized marijuana for recreational use.
Employers in many states have grappled with the legal and practical