Vt. Stat. Ann. » Title 21 Chapter 3
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 21, § 223 (2026)

Duties

✓ current as of May 2026
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Subchapter 005 : OCCUPATIONAL SAFETY AND HEALTH

(Cite as: 21 V.S.A. § 223)
Notes of Decisions
Cited in 13 cases (1 in the last 5 years), 1978–2025 · leading case: Joseph L. LeClair v. Hector LeClair, 169 A.3d 743 (Vt. 2017).
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Joseph L. LeClair v. Hector LeClair, 169 A.3d 743 (Vt. 2017). · cites it 2× “A similar duty is now codified in 21 V.S.A. § 223(a), although no private right of action is created to enforce it.”
Green Mountain Power Corp. v. Comm'r of Labor & Indus., 383 A.2d 1046 (Vt. 1978). · cites it 3× “21 V.S.A. § 223 (a). In addition, a $600.”
Chayer v. Ethan Allen, Inc., 2008 VT 45 (Vt. 2008). · cites it 2× “Finally, 21 V.S.A. § 223(a) mandates that employers shall provide “a place of employment .”
Vella v. Hartford Vermont Acquisitions, Inc., 2003 VT 108 (Vt. 2003). “On the other hand, defendant’s duty to maintain the premises is narrower in the sense that Premier’s duty to provide a safe workplace includes every aspect of the workplace.”
Andrew v. State, 682 A.2d 1387 (Vt. 1996). “Under the statute, the Commissioner of Labor and Industry, the Director of Occupational Health, or their agents “may” enter private business premises at reasonable times without warning and conduct reasonable inspections to determine whether there has been compliance with the…”
Gerrish v. Savard, 739 A.2d 1195 (Vt. 1999). “2d 179, 180 (1941); 21 V.S.A. § 223(a). Here, as in Gerger , defendant allegedly made a decision that a piece of machinery could operate without a certain safety feature.”
Garrity v. Manning, 671 A.2d 808 (Vt. 1996). “” 21 V.S.A. § 223(a). *513 We adopt the Wisconsin rule as consistent with the result' in Steele , but with a rationale that is more workable for future cases.”
Ira Martel v. Connor Contracting, Inc., Jason Clark, & Stephen Connor, 200 A.3d 160 (Vt. 2018). “Employers have a duty to "furnish to each of [their] employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or significant physical harm to [their] employees" and to "comply with safety and health…”
Knisely v. Cent. Vermont Hosp., 769 A.2d 5 (Vt. 2000). “It has greater difficulty, however, in contravening the trial court’s conclusion that as between the Hospital and TSP there is no material dispute that it was the Hospital’s duty to make the operating rooms safe for the employees who worked there.”
Dunham v. Chase, 674 A.2d 1279 (Vt. 1996). “2d at 810 see also 21 V.S.A. § 223 (employers have duty under occupational safety law to furnish workplace free from recognized, hazards that could cause serious physical harm).”
Palmeri v. Brattleboro Mem'l Hosp., Inc. (Vt. Super. Ct. 2004). · cites it 2× “Count IV states a claim for violation of 21 V.S.A. § 223. This statute sets out an employer’s statutory obligation to furnish a place of employment free from recognized hazards and its obligation to comply with VOSHA safety and health standards but does not include any private…”
Streeter v. Chittenden Solid Waste Dist. (Vt. Super. Ct. 2019). “21 V.S.A. § 223(a). “Neglect of safety precautions .”
Show all 13 citing cases →
— Vt. Stat. Ann. tit. 21, § 223(a) — 10 cases
Joseph L. LeClair v. Hector LeClair, 169 A.3d 743 (Vt. 2017). “A similar duty is now codified in 21 V.S.A. § 223(a), although no private right of action is created to enforce it.”
Chayer v. Ethan Allen, Inc., 2008 VT 45 (Vt. 2008). “Finally, 21 V.S.A. § 223(a) mandates that employers shall provide “a place of employment .”
Vella v. Hartford Vermont Acquisitions, Inc., 2003 VT 108 (Vt. 2003). “On the other hand, defendant’s duty to maintain the premises is narrower in the sense that Premier’s duty to provide a safe workplace includes every aspect of the workplace.”
Gerrish v. Savard, 739 A.2d 1195 (Vt. 1999). “2d 179, 180 (1941); 21 V.S.A. § 223(a). Here, as in Gerger , defendant allegedly made a decision that a piece of machinery could operate without a certain safety feature.”
Green Mountain Power Corp. v. Comm'r of Labor & Indus., 383 A.2d 1046 (Vt. 1978). “21 V.S.A. § 223 (a). In addition, a $600.”
— Vt. Stat. Ann. tit. 21, § 223(b) — 1 case
Green Mountain Power Corp. v. Comm'r of Labor & Indus., 383 A.2d 1046 (Vt. 1978). “21 V.S.A. § 223 (a). In addition, a $600.”
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