William J. Downey, JD, LLM, MS

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Your Need to Know
 

Your Need to Know 

Legal, Regulatory and Government    

William J. Downey, JD, CEO, W J Downey & Associates

 Email, Technology & Social Networking: Policy Considerations

 

Email & Web Rule #1: Litigation and Regulations,

Productivity and Security Create the Need for Strategic Email and Web Management

 

> Email & Web Rule #2: Apply Policy, Training and Technology

to Help Manage Email and Web Risks

> Email & Web Rule #3: The Easiest Way to Control Email

Risk Is to Control Written Content

> Email & Web Rule #4: Combine Policy with URL Blocks

to Protect Resources, Preserve Productivity and Prevent

Lawsuits

> Email & Web Rule #5: Personal Use Heightens

Organizational Risk

> Email & Web Rule #6: Exercise Your Legal Right to

Monitor — and Discipline — Employees

> Email & Web Rule #7: Employees Have Absolutely No

Reasonable Expectation of Privacy

Email & Web Rule #8: Lock Out Malicious Intruders to

Keep Your Secrets Safe and System Secure

> Email & Web Rule #9: Conduct an Annual — Legal –

Review of Email and Web Policies

 

 

More than 70 percent of congressional offices violate OSHA safety standards

By Jordy Yager - 02/24/10 06:00 AM ET

But this year’s inspection data from the Office of Compliance inspections is an improvement over last year’s.

More than 70 percent of congressional offices have violated worker safety standards over the past year.

While the majority of all lawmaker offices on Capitol Hill have at least one health or safety hazard violation, this year’s inspection data from the Office of Compliance inspections is an improvement over last year’s.  http://thehill.com/homenews/house/83311-over-70-percent-of-offices-violate-osha-standards?utm_source=Newsletter&utm_medium=Email&utm_campaign=Morning%2BBell

 

In December, the Senate confirmed David Michaels, a research professor at George Washington University, to head the agency. Michaels, who is a believer in metrics measurement and the creation of an enforceable ergonomics standard, is expected to strongly push for the prevention of musculoskeletal disorders in all workplaces. With a 10 percent increase in OSHA's budget for the coming year, including the addition of 210 personnel, inspecting injury logs and penalizing health and safety violators will be easier for the administration to accomplish.

In addition to Michaels' confirmation, OSHA officials released the agency's upcoming regulatory agenda. Jordan Barab, acting assistant secretary for OSHA, said the agency will issue a proposed rule in January to revise its regulation on recordkeeping to restore a column on the OSHA 300 Injury and Illness Log that would require employers to separately list work-related MSDs from other conditions. The MSD column was removed from the log in 2003.

http://www.riskandinsurance.com/story.jsp?storyId=325340948

 

Security officer's disciplinary file supports denial of benefits

In Ohio, failure to submit the formal employee handbook to the court is not automatically fatal to an employer's voluntary abandonment claim.


Case name: State ex rel. Galligan v. Industrial Commission of Ohio; Tenable Protective Services, Inc., No. 2009-0141 (Ohio 01/06/10).

Ruling: The Ohio Supreme Court reversed the Court of Appeals, holding the employee's termination for violating the employer's rules was a voluntary abandonment of her job for purposes of denying temporary total disability benefits.

Related Coverage

·         California: WC premiums fall in 2008, but cost per claim increases (01/22/09)

·         Failure to address football player's wage loss warrants remand (05/21/09)

·         School custodian's early departure for vacation undermines injury claim (01/19/09)

·         State more aggressive in attempts to deny comp claims, consultant says (11/04/08)

·         Report shows decline in average comp rates, claims first half of '08 (11/04/08)

What it means: In Ohio, to be considered voluntary abandonment, a termination must arise from an employee's violation of a written work rule or policy that: 1) clearly defined the prohibited conduct; 2) had been previously identified by the employer as a dischargeable offense; and 3) was known or should have been known to the employee. The failure to submit the formal employee handbook to the court is not automatically fatal to an employer's voluntary abandonment claim.

Summary: A security officer filed a claim for benefits after she was terminated for misconduct. The employer denied the claim, arguing that the officer had voluntarily abandoned her job based on her discharge. The Ohio Supreme Court rejected the officer's position that the employer's failure to submit the company handbook prevented meaningful review of the written work rules that clearly defined the prohibited conduct. In lieu of the company handbook, the employer submitted the officer's disciplinary file. The court determined the officer's file satisfied the requirements that the prohibited conduct was previously identified, clearly defined, and known to the employee prior to her termination. The court held that a per se rule automatically precluding voluntary abandonment as a defense when the employee handbook was not submitted would deprive the Ohio Industrial Commission of the ability to consider other relevant credible evidence. It upheld the denial of temporary total disability benefits based on voluntary abandonment.

The court noted the employee had been disciplined with multiple official written warnings but continued to engage in the same conduct for which she was terminated -- sleeping at her post. She had accumulated two dozen oral and written citations for violating work rules, including inappropriate sexual remarks, breach of confidentiality protocol, timesheet irregularities, failure to remain at her post, and multiple incident

 

Worker’s Compensation – Retaliation Case

 

Possibility of failure does not remove retaliation claim from court's jurisdiction

In Texas, a case "arises" under workers' compensation law from the instant it becomes clear that the worker will have to invoke, explain and apply workers' compensation law. An anti-retaliation suit arises under state workers' compensation law and must be brought in state court.

Case name:
Meeks v. Swift Transportation Inc., et al., No. EP-09-CV-298-KC (W.D. Tex. 12/11/09).

Ruling: The U.S. District Court, Western District of Texas remanded a worker's retaliation claim to state court, finding it arose under the state workers' compensation law.

What it means: In Texas, a case "arises" under workers' compensation law from the instant it becomes clear that the worker will have to invoke, explain and apply workers' compensation law. An anti-retaliation suit arises under state workers' compensation law and must be brought in state court.

 

 

Related Coverage

·         Special employment relationship grounds flight attendant's personal injury suit (01/26/09)

·         Failure to prove employer knowledge of injury dooms clerk's claim (07/16/09)

·         Evidence on inability to perform range of jobs missing in mechanic's case (08/21/09)

·         Well owner can't show oil worker was a borrowed servant for WC exclusivity (09/28/09)

·         History of depression hinders teacher's mental injury claim (03/05/09)

 

http://www.riskandinsurance.com/story.jsp?storyId=327407953

 

Why it matters: For employers and counsel the ruling indicates that actions related to workers’ compensation belong in state rather than federal courts; federal courts lack the jurisdiction to intervene in such cases.

 

 

FINRA

Blogs and Social Media Guidance http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p120779.pdf

Social media has become a major tool in both social and business communication, with firms establishing social media sites, and employees developing professional and social networks.  In regulated industries this poses an additional risk of unintentional disclosure of confidential information.  Just as many firms have developed Authorized Use Policies (AUP) for computer users, regulated firms are now required to develop, implement and monitor social media.  These policies should apply not only to lap tops and desk tops but also to “Smart Phones”, Blackberries and other electronic media provided by the company.

 

Export Compliance Management

 

 

United States Department of Commerce, Bureau of Industrial Security

 

3/3/2010 - The following was added to the Denied Persons List:

Robert Kraaipoel
P.O. Box 418
Heerhugowaard, Netherlands 1700AK

 

Robert Kraaipoel
Flemming Straat 36
Heerhugowaard, Netherlands 1700AK

 

Aviation Services International, B.V.
also known as Delta Logistics, B.V.
P.O. Box 418
Heerhugowaard, Netherlands 1700AK

 

Aviation Services International, B.V.
also known as Delta Logistics, B.V.
Flemming Straat 36
Heerhugowaard, Netherlands 1700AK

Please visit http://www.bis.doc.gov/dpl/ for more information.

 

3/2/2010 - This update adds the following respondent to the Denied Persons List:

Mohamad M. Elkateb
29256 Marilyn Dr.
Canyon Country, CA 91387

Please visit http://www.bis.doc.gov/dpl/ for more information.

 

 

United States Treasury Department, Office of Foreign Asset Control

Specially Designated Nations (SDN)

2/23/2010 - Please visit http://www.treas.gov/offices/enforcement/ofac/sdn/index.shtml

UNSC Sanctions Will Fail

February 11, 2010 Analysis

 

Summary

Even though Iran is a destabilizing influence, and there remains a strong probability that the Iranian government's attempts to construct both nuclear weapons and delivery systems two critical players on the United Nations Security Council have repeatedly indicated that they do not support tougher sanctions. 

Analysis

When implementing a sanctions program, the sanctions need to be tough and comprehensive.  However, two members of the Security Council have repeatedly stated opposition to this type of program, and have the power to veto any UNSC Resolution that shuts off international trade with Iran.

Logic would dictate that an examination of the trade interests of the PRC and Russia would be in order.  Both have strong economic ties to Iran.  Both have oil and gas discovery and production projects in Iran.  Russia and the PRC as well as others turn a blind eye to the movement of critical technology into Iran (see Axis of Commerce, by Christopher Stewart, in the September 2008 issue of Conde Nast Portfolio).  Many US and European companies have broken the UN Sanctions and US Trade Embargo, sometimes knowingly and sometimes not.

Another principal problem is that sanctions and embargoes have been used by the government they are aimed at to unify the people against those nations that impose such actions.  While Iran is at the moment undergoing turmoil, this may be attributed to the repressive nature of the regime, and less to overall depravation of the populace.  One may also look at North Korea and Cuba. 

Despite UN sanctions on North Korea that have been in place for many years the regime which is very repressive has successfully continued to develop atomic capabilities and delivery systems, as well as exporting weapons and technology to Iran, Pakistan and terrorist groups with hard currency.

Cuba which is under US Embargo, has successfully used the embargo to unite the people despite the negative effects of the US effort.  Economically the government is presently profiting from increased oil and gas exploration from a variety of countries including the PRC, and European energy firms.

So what may succeed?  Some would argue that unless there is a regime change in Iran, military action would be required.  However such action would require the cooperation and participation of Iran's neighbors and the PRC and Russia, which would probably not be forthcoming.  In addition, such action might have the unintended but devastating result of inflaming the Muslim world against those who participated.

Since Secretary Gates has brushed aside the possibility of such action, that leaves engagement.  Engagement with Iran is liable to be just as difficult as it is with North Korea.  Meaningful engagement means modifying existing policies on both sides as well as a more open and honest response from Iran's government.  Iran would need to allow free travel and communication with the world, impose a more rational foreign policy.

The overall problem remains that without human intelligence (HUM INT) which can be gained through engagement,  it is impossible to tell what actions the present regime in either Iran or North Korea will take.