Lawrence P. Halprin: Lawyer with Keller and Heckman LLP

Lawrence P. Halprin

Partner
Washington,  DC  U.S.A.
Phone202.434.4177

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Experience & Credentials
 

Practice Areas

  • Chemical Control
  • Employment and Labor
  • Environmental
  • Workplace Safety and Health
  • Health and Safety Compliance Audit
  • Trade and Professional Associations
  • Transportation
 
University University of Pennsylvania, B.S.Ch.E., with honors, 1974; George Washington University, M.B.A., Finance/Investments, 1984 Beta Gamma Sigma
 
Law SchoolDuquesne University School of Law, J.D., 1977 Duquesne Law Review
 
Admitted1977, Pennsylvania; 1978, District of Columbia; U.S. Court of Appeals for the Third Circuit; U.S. Court of Appeals for the D.C. Circuit; U.S. District Court for the District of Columbia; U.S. Court of Appeals for the Fifth Circuit; U.S. Court of Federal Claims; U.S. Tax Court; U.S. Court of Appeals for the Eleventh Circuit
 
Biography

Lawrence Halprin joined Keller and Heckman in 1978.

Lawrence Halprin is nationally recognized for his work in the areas of occupational safety and health, and chemical regulation, at the federal and state levels. His occupational safety and health practice covers all aspects of legal advocacy, including: legislative reform and oversight; participation in OSHA, NIOSH and MSHA rulemakings and stakeholders processes; participation in the development of national consensus standards under the ANSI process, and TLVs under the ACGIH process; bringing and intervening in pre-enforcement challenges to final OSHA rules; providing compliance counseling and training; conducting incident investigations, compliance audits and program reviews; representing clients in OSHA investigations; and defending clients in OSHA and MSHA enforcement actions.

Mr. Halprin's engineering background and historical knowledge of OSHA rulemakings have greatly enhanced his ability to provide compliance counseling and represent clients in OSHA and MSHA enforcement actions. He has extensive experience with federal and state OSHA investigations and enforcement actions involving: chemical emergency response, chemical process safety management, chemical hazard communication, combustible dust, confined spaces, electrical safety, the General Duty Clause, (Cal-OSHA) injury and illness prevention programs, injury and illness recordkeeping, lockout/tagout, machine guarding, noise, powered industrial trucks, respiratory protection, and alleged employer retaliation claims.

Mr. Halprin's engineering background and financial background have been particularly useful in evaluating and critiquing OSHA and MSHA rulemaking proposals and suggesting alternative approaches. On behalf of one or more clients, Mr. Halprin has participated in almost every major OSHA rulemaking initiative over the past 25 years and numerous Cal-OSHA rulemakings.

Mr. Halprin has a hands-on familiarity with the manufacturing environment and has represented clients in the aerospace, chemical, construction, electronics, food, machinery, paper and forest products, petroleum, pharmaceuticals, plastics, steel, telecommunications and transportation industries. He is a member of the following ANSI and ASTM technical committees: ANSI B11.19 Subcommittee on Performance Standards for Safeguarding, the ANSI/PMMI B155.1 Committee on Safety Requirements for Packaging Machinery and Packaging-Related Converting Machinery; ASTM Committee E34 on Occupational Health and Safety; and ASTM Committee E56 on Nanotechnology. He regularly follows and participates in the development of combustible dust standards by NFPA.

In addition to his work in the area of occupational safety and health, Mr. Halprin also counsels individual companies and trade associations regarding a broad range of chemical management activities and requirements under the jurisdiction of the U.S. Tax and Trade Bureau (formerly BATF, covering the permitting, registration and operation of facilities that manufacture, process, store and distribute ethanol), the Environmental Protection Agency (asbestos rules and Risk Management Program rule), the Department of Transportation, the Chemical Safety Board, and their state counterparts. He also works with clients in developing, implementing and auditing environmental, health and safety, and product stewardship management programs. Mr. Halprin has been a strong advocate of measures to enhance the effectiveness of regulatory agencies. He has testified before Congress and participated in numerous government rulemakings in an effort to ensure that the scope and requirements of agency rules reflect what is necessary, practical and justified by appropriate risk assessment and cost-benefit analyses. Mr. Halprin is a frequent writer and speaker on a broad range of environmental, health and safety management issues.

In his transactional practice, Mr. Halprin has provided counsel and negotiated: waste management agreements; purchase, leasing and financing agreements for commercial properties, drilling equipment and computer systems; and telecommunications system design, construction and operating agreements. Before joining Keller and Heckman, Mr. Halprin clerked for the Honorable Charles R. Johnston of the U.S. Tax Court.

Enforcement Actions with Widespread Impact, Agency Rulemakings and Pre-Enforcement Court Challenges

Mr. Halprin has represented clients in a significant number of OSHA enforcement actions having widespread application across an entire industry and, in some cases, the entire manufacturing sector or the entire industrial sector (outside of mining). He has participated in almost every major OSHA rulemaking initiative over the past 25 years and numerous Cal-OSHA rulemakings. He also participated in numerous court challenges to final OSHA rules - on behalf of petitioners challenging rules that our clients concluded were not reasonably necessary or appropriate to workplace safety and health, and on behalf of intervenors to protect final rules against efforts to make them more burdensome. Some of these representations are summarized below.

•Co-counsel and primary author of the comments for the primary industry coalition (led by the National Association of Manufacturers) challenging OSHA's proposed October 19, 2010 re-interpretation of the OSHA Noise Standard.

•Co-counsel and primary author of the comments for the primary industry coalition (led by the US Chamber of Commerce) challenging OSHA's proposed January 29, 2010 addition of a musculoskeletal disorders (MSD) column to the OSHA Injury And Illness Recordkeeping Rule.

•Primary author of the comments submitted on behalf of the Grocery Manufacturers Association in the Cal-OSHA Diacetyl Rulemaking to preserve the exemption for flavors containing less than 1% diacetyl

•Lead counsel for the successful intervention on behalf of the Aerospace Industries Association to preserve the Separate Engineering Control Airborne Limits (SECAL), permissible exposure limit (PEL) and action level (AL) of OSHA's Hexavalent Chromium Standard against the challenge brought by Public Citizen. Public Citizen Health Research Group v. Dept. of Labor, 557 F.3d 165 (3d Cir. 2009).

•Author of the comments submitted to the Chemical Safety Board (CSB) that apparently persuaded the CSB to conclude that it did not have the legal authority under the Clean Air Act to adopt the proposed Accident Investigation Initiation Notice and Order to Preserve Evidence [Rule], which was published in the Federal Register on January 4, 2006 (71 FR 309).

•As lead counsel, on behalf of the American Forest & Paper Association, negotiated an unprecedented compliance instruction (effectively a generic variance) from OSHA in connection with the design, operation and maintenance of chemical batch digesters -- a type of pressure vessel in wide use within the paper industry to convert wood chips into pulp. See OSHA Directive CPL 02-01-041, EFFECTIVE DATE: 9-16-04, SUBJECT: Alternative Abatement Method for 29 CFR 1910.261(g)(17) - Over-pressure Protection for Batch Digesters Used in the Pulp Processing Industry. OSHA vacated citations against four mills that were determined to be in compliance with the alternative abatement method established by this directive.

•Primary author of the 2003 comments submitted on behalf of the primary construction coalition in the Small Business Review of OSHA's draft comprehensive standard for occupational exposure to crystalline silica under SBREFA. SBREFA Final Report issued December 19, 2003, extensively quoted coalition comments.

•Co-counsel for the leading industry coalition (led by the National Association of Manufacturers and the US Chamber of Commerce), several major trade associations, and several major corporations in the OSHA Ergonomics Program Standard Rulemaking and the successful effort before Congress to rescind OSHA's ill-advised Ergonomics Program Standard in 2001.

•Lead counsel in a case resulting in a 1995 OSHA Letter of Interpretation and settlement acknowledging that employers may inspect representative authorized employees (and are not required to inspect every authorized employee) applying lockout/tagout on an annual basis, and may inspect representative applications of lockout/tagout (and are not required to inspect the application of lockout/tagout to every piece of annually serviced equipment) on an annual basis.

•Lead counsel for the successful challenge to the 1994 amendments to the OSHA Personal Protective Equipment (PPE) Standards brought on behalf of the American Forest & Paper Association and the American Iron and Steel Institute, resulting in a settlement that limited the scope of the employers' obligations under that rule to what OSHA had demonstrated to be reasonably necessary and appropriate.

•Co-counsel in the successful intervention on behalf of Chocolate Manufacturers Association and National Confectioners Association to preserve the minor servicing provisions of the OSHA Lock-Out/Tag-Out Standard against union challenges International union, United Automobile, Aerospace and Agricultural Implement Workers of America, UAW v. OSHA, 938 F.2d 1310 (D.C. Cir. 1991).

News

Jul 09, 2008 Are You Ready For REACH?
Aug 04, 2008 Post Hearing Comments Due on OSHA Proposed Rule for Confined Spaces in Construction
May 05, 2009 Partner Lawrence Halprin Quoted on Workplace Safety and OSHA Regulations
Apr 28, 2009 Partner Lawrence Halprin testifies before House Education and Labor Committee on Adequacy of OSHA Penalty Structure
Jan 10, 2012 Keller and Heckman Comments on NIOSH's Review of its RELs/PELs and Cancer Policies
Mar 08, 2012 Partner Larry Halprin to Present at the American Forest & Paper Association 2012 Employee Relations Conference
Jul 16, 2012 Partner Lawrence Halprin to Join OSHA SBREFA Panel at SPI's Vinyl Products 23rd Annual Compounders Conference
Oct 10, 2012 Lawrence Halprin to Present at the American Petroleum Institute's workshop on OSHA's New Hazard Communication Standard 2012
Mar 21, 2013 Lawrence Halprin Quoted in Recent Bloomberg BNA Article
Apr 22, 2013 Lawrence Halprin to Present at ANTEC 2013 Conference
Jun 12, 2013 Lawrence Halprin to Present at the Pulp and Paper Safety Association Conference
Sep 25, 2013 Keller and Heckman Attorneys to Present a Course for the Society for Chemical Hazard Communication
Mar 06, 2014 Keller and Heckman Partner Larry Halprin's Role in the American Petroleum Insitute Settlement with the Occupational Safety and Health Administration
Apr 29, 2009 New OSHA Legislation Would Dramatically Increase Civil and Criminal Penalties for Workplace Safety Violations

Events

Feb 08, 2007 Regulations for Nanotechnology in Consumer Products
Sep 23, 2008 Advanced Chemical Control Course: Managing a Shifting Regulatory Climate - Washington, D.C.
Oct 24, 2011 Register Today! - Chemical Control Law Seminar - October 24-26, 2011
Mar 27, 2012 A Webinar: How will OSHA's adoption of GHS impact your operations?
Dec 18, 2013 OSHA 30/30 - Updates with Manesh Rath
Oct 10, 2013 Registration is Closed - A Webinar on OSHA's Silica Proposal Up Close: The Good, The Bad and The Ugly
Aug 26, 2014 Lawrence Halprin Selected to Present at the VPPPA 30th Annual National Conference
Apr 30, 2014 OSHA Citation for Contractor's Alleged Failure to Exchange Lockout/Tagout Information with Host Employer Heard by U.S. Court of Appeals
Aug 20, 2014 OSHA 30/30 - August 20, 2014

Publications

Aug 15, 2014 Will OSHA's Misguided Ideology on Injury and Illness Recordkeeping Lead to More Video Cameras in the Workplace?
Jul 29, 2014 EPA is Considering Amendments to its Chemical Risk Management Program (RMP) Rule that Would Impose Burdensome Additional Requirements on both Covered Facilities and Facilities Not Currently Covered by the RMP Rule
Nov 22, 2013 Understanding the OSHA Temporary Worker Initiative
Oct 24, 2013 Deadline for Training Employees on the OSHA Hazard Communication Standard's New Label and SDS Formats is Dec. 1
Oct 10, 2013 OSHA's Silica Proposal Up Close: The Good, The Bad and The Ugly Slides
Oct 08, 2013 OSHA's Proposed Silica Health Standard: A Summary of Key Elements
Oct 04, 2013 What is California Up To? - The Initial List of Candidate Chemicals is Published
Sep 25, 2013 OSHA 30/30 Crystalline Silica Slides
Aug 05, 2013 Senate Committee on Environment and Public Works Holds Hearing on TSCA Reform
May 22, 2013 Summary - Chemical Safety Improvement Act of 2013
Mar 08, 2013 The GHS May Arrive Much Sooner Than You Expected
Sep 06, 2012 Review Commission Decision Invites OSHA to Implement I2P2 through an Expansive New Interpretation of Existing Construction Accident Prevention Program Standard
Aug 15, 2012 Summary of the Committee Mark-up of the Safe Chemicals Act of 2011 (S. 847)
Feb 14, 2012 KH Workplace Update
Jan 05, 2012 SEC Unveils New Dodd-Frank Mine Safety Disclosure Requirements
Dec 14, 2011 KH Workplace Update
Dec 07, 2011 KH Workplace Update
Mar 11, 2011 The Constantly Pending PMN: Low Volume Exemption Applications Are Living Documents
Sep 20, 2010 Environmental Business Alert: End-of-Year Deadline to Nominate Existing Chemicals for Taiwan Inventory Nears
May 03, 2010 OSHA's Proposed Severe Violator Enforcement Program
Nov 12, 2009 Combustible Dust Update: OSHA's Preliminary Rulemaking on Dust is Underway
Oct 08, 2009 EEOC ADAAA NPRM Guarantees Spike In Disability Discrimination Claims and Creates a Backdoor Ergonomics Rule
Mar 10, 2009 Legal Impacts and Opportunities of GHS Implementations in the United States and Around the Globe
Mar 10, 2009 Equal Employment Opportunity Commission Releases Proposed Regulations to Prohibit Genetic Discrimination or Misuse of Genetic Information
Aug 01, 2008 Department of Labor Submits Draft Proposed Rule on Occupational Risk Assessment to OMB for Review
Jun 06, 2007 REACH Is Here: Are You Ready?
Mar 19, 2007 Workplace Alert: OSHA Announces Site-Specific Targeting Plan for FY 2007
Jan 11, 2007 Workplace Alert: Is There a Hidden Agenda in Phase III of OSHA's Standards Improvement Project and OSHA Recordkeeping Reminder
Feb 28, 2006 Workplace Alert February 2006 Gearing Up for OSHA's New Hexavalent Chromium Standards
Feb 17, 2006 Proposed New Rules: N.J.A.C. 12:122, Cutting and Grinding of Masonry
Jan 17, 2006 Workplace Alert January 2006 Recent Proposed Rule by the U.S. Chemical Safety and Hazard Investigation Board Requires Companies to Preserve Evidence Related to Chemical Accidents
Dec 22, 2005 The Potential of PELS Based on Particle Size
Aug 17, 2005 OSHA Alert August 2005 OSHA Announces Site-Specific Targeting Plan for FY 2006
Jul 25, 2005 Workplace Alert July 2005 OSHA's Proposed Electrical Safety Standards
Jul 14, 2005 OSHA Alert- House Passes Four OSHA Reform Bills
May 05, 2005 OSHA Alert - OSHA Soliciting Ionizing Radiation Information and Comments
Mar 29, 2005 Workplace Alert March 2005 Comments on Revised ADA Standards Due May 31, 2005
Mar 21, 2005 Electric Power Generation, Transmission, and Distribution
Feb 08, 2005 DRAFT Asbestos Bill Includes Huge EPA/OSHA-Based Enforcement Hammers
Dec 07, 2004 Employment Law Alert December 7, 2004 Employer Consent Required Before Combining Regular Employees With Joint Employees Into Single Bargaining Unit
Oct 02, 2004 OSHA ALERT - OSHA's Proposed Rule on Hexavalent Chromium
Jul 30, 2004 OSHA REFORM - The SAFE ACT -- S. 2719
Jun 22, 2004 Current Federal Regulatory Developments and Rulemakings
Feb 09, 2004 OSHA Recordkeeping Has No Normal Body Function Exemption
Aug 13, 2003 OSHA Reform Legislation
Jul 01, 2003 OSHA Drops MSD Column, Definition of MSD and MSD Privacy Case Exclusion
Jun 01, 2003 Environmental Reporting and Recordkeeping: Sound Strategies and Legal Insights
May 13, 2003 Workplace Advisory May 2003, Issue No. 15
May 12, 2003 Workplace Alert May 12, 2003 OSHA Announces Draft Ergonomics Guidelines for Retail Grocery Stores
Apr 24, 2003 Is OSHA Enforcing an Invalidly Adopted and Subsequently Lapsed Amendment to its Lockout/Tagout Standard?
Feb 12, 2003 Employment Law Alert February 12, 2003 Michigan Executive Order May Bar Contractors for Employment and OSHA Violations
Jan 24, 2003 Employers May No Longer Rely On Compliance With Their Local Building Code As Establishing Compliance With OSHA Fire Safety Requirements
Oct 12, 2002 Amendment to the Final Injury and Illness Recording Rule Signed and Filed
May 31, 2002 How to Handle an OSHA Inspection - General Do's and Don'ts
Apr 12, 2002 OSHA's Comprehensive Plan for Addressing Workplace Ergonomics Hazards
Mar 29, 2002 Ripe for a Challenge--Does OSHA's Lockout/Tagout Standard Really Require Equipment-Specific Energy Control Procedures
Jan 25, 2002 Posting Date for OSHA Form 200 is February 1
Jan 25, 2002 OSHA Inspection Targeting Program Revised, Expiration Date Extended
Aug 15, 2001 OSHA Launches National Emphasis Program for Lead Exposure
Jul 12, 2001 OSHA Announces that Final Rule for Recording and Reporting Occupational Injuries and Illnesses Will Go Into Effect on January 1, 2002, and Proposes to Stay The Provisions on MSDs and Hearing Loss
Mar 08, 2001 Both Houses Pass Historic Rejection of OSHA's Ergonomic Program Standard
Jan 19, 2001 OSHA Publishes Final Rule for Recording and Reporting Occupational Injuries and Illnesses, and Makes Major Changes in Employer Obligations
Jan 01, 2001 2001 Occupational Safety and Health Law Handbook
Oct 17, 2000 OSHA Confirms Acceptability of Air Purifying Respirators to Protect Workers from Diisocyanate Exposures
Jan 10, 2000 OSHA Standards Interpretation and Compliance Letters
Sep 15, 1999 OSHA Says 30 Year Record Retention Requirement for Employee Exposure Record Applies to Non-Detectable Levels
Nov 23, 1998 Comments on OSHA's Draft Proposed Safety and Health Program Rule
Nov 10, 1998 Primary Concerns Raised by OSHA's Safety and Health Program Rule Initiative
Jul 23, 1998 Comments on OSHA's Request to Extend OMB Approval of Paperwork Requirements
Jun 01, 1998 Workplace Advisory June 1998, Issue No. 14
May 08, 1998 Scientific Basis of Z-365 Standard for Cumulative Traumas Questioned
Apr 22, 1998 Comprehensive Critique of Draft Safety and Health Program Standard Submitted to OSHA
Jan 01, 1998 Workplace Advisory January 1998, Issue No. 13
Feb 01, 1997 Workplace Advisory Winter/Spring 1997
Oct 01, 1996 Employee Conduct and the OSH Act: New York State Electric & Gas Corp. vs. Secretary of Labor, U.S. Court of Appeals for the Second Circuit, July 3, 1996
Apr 26, 1995 Interpretation of Lockout/Tagout: General Motors Corporation, Delco Chassis Division, OSHRC Docket Nos. 91-2973, 91-3116 & 91-3117 (Consolidated), Occupational Safety and Health Review Commission, April 26, 1995
OSHA 30/30 - Training Requirements Under The Revised Hazard Communication Standard

 
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Will OSHA's Misguided Ideology on Injury and Illness Recordkeeping Lead to More Video Cameras in the Workplace?
Lawrence P. Halprin,Manesh K. Rath,David G. Sarvadi, August 20, 2014
At every opportunity during the Obama Administration, OSHA has alleged that there is widespread and substantial under-reporting of work-related injuries and illnesses that OSHA must address through additional regulatory and enforcement measures. OSHA has taken this position despite the overwhelming...

EPA is Considering Amendments to its Chemical Risk Management Program (RMP) Rule that Would Impose Burdensome Additional Requirements on both Covered Facilities and Facilities Not Currently Covered by the RMP Rule
Trent M. Doyle,Lawrence P. Halprin, doyle, July 30, 2014
On August 1, 2013, reacting to a number of high-profile incidents and the constant drumbeat from the Chemical Safety Board, President Obama signed Executive Order 13650, entitled Improving Chemical Facility Safety and Security. Among other things, EO 13650 directs EPA and OSHA to consider possible...

OSHA Proposes Revisions to Crystalline Silica Standard
Lawrence P. Halprin,Manesh K. Rath,David G. Sarvadi, November 5, 2013
On September 12, 2013, the Occupational Safety and Health Administration (OSHA) issued a proposed rule to establish comprehensive, substance-specific health standards for occupational exposure to respirable crystalline silica (RCS) for General Industry, Maritime, and Construction activities.

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Lawrence P. Halprin

Suite 500 West, 1001 G Street, N.W.
WashingtonDC 20001




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