This past week I worked with a client who's safety contact is the HR manager and we had several discussions about OSHA's revised recordkeeping requirements and all the recent reporting changes.  One thing I noticed is that ALL MANUFACTURING facilities are considered "high risk" and are on the list of NAICS's number that must report.  So the "list" of high-risk industries is not very specific!  But one thing that is stirring a lot of discussion is OSHA's official position on "post-accident" drug testing.  OSHA stated in the preamble...

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