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On Sept. 28, 2021, California Gov. Gavin Newsom signed into law Senate Bill 606 (SB 606), which, among other things, creates two new categories of California Division of Occupational Safety and Health (Cal/OSHA) violations: “egregious” and “enterprise-wide.”

The new categories of violations carry significant monetary penalties against employers. Employers face up to $134,334 per egregious and enterprise-wide violation. But employers who commit egregious violations could face significantly higher monetary penalties, because each exposed employee will be considered a separate violation, i.e., $134,334 multiplied by the number of impacted employees. The new law takes effect Jan. 1, 2022.

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Photo of Michael Taylor ‡ Michael Taylor ‡

Michael Taylor is Chair of the Greenberg Traurig OSHA Practice group. Michael focuses his nationwide practice exclusively on representing employers regarding workplace safety and health matters. Over the last two decades, Michael has represented hundreds of employers during federal and state workplace safety…

Michael Taylor is Chair of the Greenberg Traurig OSHA Practice group. Michael focuses his nationwide practice exclusively on representing employers regarding workplace safety and health matters. Over the last two decades, Michael has represented hundreds of employers during federal and state workplace safety and health litigation, many of which involved a significant injury, fatality, fire, explosion, or catastrophic release of a highly hazardous substance in the workplace. Michael also provides federal and state workplace safety and health compliance counseling, inspection counseling, whistleblower representation, and due diligence reviews for clients. Michael also represents employers regarding Chemical Safety Board investigations in response to a significant fire, explosion, or catastrophic release of a highly hazardous substance in the workplace. Michael has significant experience in the oil, gas, electric utility, grain, construction, and chemical manufacturing industries.

Michael previously served as General Counsel to the federal Occupational Safety and Health Review Commission, the agency in charge of adjudicating workplace safety and health disputes between federal OSHA and the regulated community.

Michael is the Founder and Host of the Greenberg Traurig Workplace Safety Review Podcast, where he interviews influential environmental, health, and safety professionals across the country regarding timely and important topics in the environmental, health and safety world. Recent guests have included Douglas Parker, Assistant Secretary of Labor for Occupational Safety and Health in the Biden Administration; Deborah Harris, Chief of the U.S. Department of Justice Environmental Crimes Section; John Howard, Director of NIOSH and Administrator of the World Trade Center Health Program in the U.S. Department of Health and Human Service; Nadine Mancini, General Counsel of the federal Occupational Safety and Health Review Commission; and Richard Fairfax, former Deputy Assistant Secretary of Labor for federal OSHA.

In 2020, Michael was recognized as a “Labor & Employment Star” in the Benchmark Litigation Labor & Employment rankings, and, in 2013, EHS Today named Michael as one of the Top 50 People Who Most Influenced Environmental, Health, and Safety.

 Admitted in the District of Columbia. Not admitted in Virginia. Practice in Virginia limited to federal OSHA and proceedings before federal agencies.

Photo of Adam Roseman Adam Roseman

Adam Roseman focuses his practice on federal and state labor and employment investigations, counseling and litigation arising under Title VII, the Fair Labor Standards Act, whistleblower retaliation under Sarbanes-Oxley and Dodd-Frank, the Occupational Safety and Health Act, and restrictive covenants. Adam also has

Adam Roseman focuses his practice on federal and state labor and employment investigations, counseling and litigation arising under Title VII, the Fair Labor Standards Act, whistleblower retaliation under Sarbanes-Oxley and Dodd-Frank, the Occupational Safety and Health Act, and restrictive covenants. Adam also has experience on white collar matters, representing clients during internal investigations and in civil and criminal government enforcement actions including the defense of qui tam/False Claims Act complaints.

Photo of Tim Swickard Tim Swickard

Tim Swickard focuses his practice on federal and state environmental regulatory compliance and litigation, real estate development, land use entitlement, environmental compliance, hazardous waste, and water law. He represents recycling, environmental cleanup, transportation industry businesses, commercial and residential developers, Indian Nations, public agencies,

Tim Swickard focuses his practice on federal and state environmental regulatory compliance and litigation, real estate development, land use entitlement, environmental compliance, hazardous waste, and water law. He represents recycling, environmental cleanup, transportation industry businesses, commercial and residential developers, Indian Nations, public agencies, and landowners. Tim previously served as the director and chief counsel for Cal/EPA Department of Toxic Substances Control under Governor Arnold Schwarzenegger.

Tim counsels clients on a wide array of topics related to environmental and regulatory law, including USEPA, USCOE, Cal/EPA, USFSW, CDFW, FDA, USDA, and CDFA. He also represents clients in OSHA Workplace Health and Safety facility regulatory compliance and enforcement defense, permitting and licensing, transportation, and storage.

Tim represents clients in brownfields development and other fields where energy law, real estate law, and governmental regulation overlap, such as CEQA, NEPA, wetlands, endangered species, transportation law, natural resource damages, air quality, greenhouse gas emissions, contaminated site cleanup cost allocation, mining, timber harvesting, agricultural law, and legislative and regulatory advocacy.