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According to an OSHA Letter of Interpretation (the "Sallman Letter"), employees at a workplace without a collective bargaining agreement may designate a person affiliated with a union to act as their "personal representative" for OSH Act purposes.
According to a recently published OSHA Letter of Interpretation
(the "Sallman Letter"), employees at a workplace without
a collective bargaining agreement may designate a person affiliated
with a union to act as their "personal representative"
for OSH Act purposes. This novel interpretation creates new threats
to the protection of proprietary information, the risk of tort
liability and opens the door to union organizing campaigns.
Partner Mark S. Dreux discusses the potential ramifications of
the Sallman Letter in this edition of After Hours.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
