ILTA Joins Working Group on Worker Walkaround Representative Rulemaking
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Jay Cruz
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ILTA Joins Working Group on Worker Walkaround Representative Rulemaking

Again working with Conn Maciel Carey LLP (CMC), ILTA joined a multi-industry working group on OSHA’s Worker Walkaround Representative Rulemaking. The rule would expand the circumstances when non-employees, particularly union representatives at non-union workplaces, can accompany OSHA inspectors during enforcement inspections. For example, union representatives, other labor or community activist groups, and even plaintiffs’ attorneys (or their expert witnesses) could gain direct and early access to non-union workplaces and employees, potentially as a front for organizing campaigns where they otherwise would not have access or to advance personally injury lawsuits. Similarly, the rule could allow competitors, contractors, or others onsite to employers’ detriment.

To aid the group’s efforts, CMC is looking for information that would help support some of the positions the group is intending to advance in its comments and testimony.  Please consider the below requests and reply to Jay Cruz ( by October 11th if you have thoughts, information, or data to share about any of them;

  • Potential issues, problems, concerns from having an unwelcome non-governmental 3rd party at your workplace
  • Issues or problems we foresee arising from third party participation in inspections at multi-employer worksites (i.e., workplaces utilized or accessed by various employees, vendors, contractors, etc. of different employers)
  • Requests for input that OSHA included in the NPRM:
    • “Data or anecdotal examples of individuals who might be selected by employees to serve as their authorized employee representative”
    • “Why employees may wish to be represented by a third-party representative”
    • “Examples of 3rd party representatives who have been or could be reasonably necessary to the conduct of an effective and thorough inspection”

Any other feedback about any aspect of this rulemaking

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