The U. S. Department of Labor’s Occupational Safety and Health Administration (“OSHA”) sets and enforces workplace safety standards. Recently, OSHA has increased its enforcement focus on the retail industry, as described in the Gibson Dunn client alert found here. Retail establishments are becoming a frequent target of OSHA citations, with significant proposed penalties. Accordingly, retailers should be particularly careful to review their company-wide workplace safety policies and to vigorously defend against arbitrary OSHA enforcement actions.