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Jackson Lewis' Hammock Testifies Before House Subcommittee

WASHINGTON, D.C. (December 10, 2015) Bradford T. Hammock, Principal in Jackson Lewis’ Washington, D.C. Region office and Leader of its Workplace Safety and Health Practice Group, testified yesterday before the Subcommittee on Workforce Protections at a hearing entitled “How the Administration’s Regulatory Onslaught is Affecting Workers and Job Creators.”

Offering his perspective on regulatory burdens on employers based on his previous experience working for OSHA as well as his years representing employers across the county, Mr. Hammock expressed his concern that employers are feeling the full weight of OSHA and fear several new regulatory initiatives set to become final rules in 2016.

“The combination of new regulatory requirements and aggressive enforcement places significant pressure on employers,” said Hammock. “It is critical that agencies be mindful of the cumulative impact of regulations on employers and be judicious with promulgating new regulations.”

Among other concerns, Mr. Hammock raised issues specifically concerning the silica rule and its reporting requirements, calling the proposed rule “highly burdensome.”

“Not only is OSHA proposing to significantly reduce the permissible exposure limit for silica in construction, it is proposing other extensive requirements, including prohibitions on work practices such as the use of compressed air, dry sweeping, and dry brushing,” said Hammock. “Some stakeholders have estimated that the cost of the rule for construction will be approximately $4.9 billion a year.”

Mr. Hammock also stated his concern regarding OSHA enforcement initiatives in areas where the Agency has provided little compliance clarity, namely in ergonomics, leading to additional challenges for employers.

“OSHA has issued some guidance documents related to ergonomics, but in my experience, often it views its own guidance as outdated,” stated Hammock.  “Employers that are following OSHA’s own ergonomics guidelines for a particular industry may be cited because OSHA believes that they need to be doing something “more” in the worksite, even though there is no clear guidance as to what that “more” should be,” Hammock continued.

“In conclusion, while OSHA compliance is important to employers, so is the day-to-day job of working to prevent injuries.  When OSHA proposes a rule or embarks on an enforcement initiative, it must truly analyze how necessary the rule is, the benefits of the rule, and the adverse consequences of it.”

Mr. Hammock’s full testimony can be found here.


About Jackson Lewis

Founded in 1958, Jackson Lewis is dedicated to representing management exclusively in workplace law. With 800 attorneys practicing in major locations throughout the U.S. and Puerto Rico, Jackson Lewis is included in the AmLaw 100 and Global 100 rankings of law firms. The firm’s wide range of specialized areas of practice provides the resources to address every aspect of the employer/employee relationship. Jackson Lewis is a leader in educating employers about the laws of equal opportunity and, as a firm, understands the importance of having a workforce that reflects the various communities it serves.

Jackson Lewis is a founding member of L&E Global Employers’ Counsel Worldwide, an alliance of premier employment law firms and practices in Europe, North America and the Asia Pacific Region.

Additional information about the firm can be found at


For more information about Jackson Lewis, please contact:

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