May 26, 2020
In This Issue
SBA PPP Loan Forgiveness Guidance and Application
OSHA Updates
Revised Enforcement Guidance for Recording Cases of Coronavirus Effective May 26, 2020
A word on face masks
New ANSI Lift Standards Delayed Until June1
Recent Events:
Recent Events
Member News
2020 ASM Scholarships Applications Deadline Approaching
Welcome New Members!
ASM Associate Members are your Trusted Partners
Regulatory Update
Proposed UPDATES TO PFML Regulations
Legislative Update
Legislative Update
Thank you to our 2020 Premium Sponsors
Do You Have A Legal Question? Accessing The ASM Hotline
Are You Following ASM On Social Media?
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We hope you had an opportunity to step back and to celebrate Memorial Day Weekend. With the phased reopening of the economy, there is some much information being thrown at all of us and it is difficult to keep with everything you need to know. Here are a few key pieces of information to review.

State Construction Reopening Guidance

Visit the state's main reopening page at: This new site includes the full report of the Governor's Advisory Board, general business guidance, construction specific protocols and requirements, new mandatory posters, and a COVID-19 control plan template.

Here are some points you should know about for Phase 1:

All construction is included in Phase 1 reopening announcement. You should review and become familiar with the detailed Safety Standards and Checklists for Construction. Note that cities and towns are permitted to include additional safety protocols.

Specific to Boston, the City is allowing work on schools, hospitals, and some residential work, and open-air construction until May 25th. After May 25th, the City will permit any construction type that is allowed by the state, with the required COVID-19 Safety Affidavits and Safety Plans for permitted construction work in place.

It is good to see a thoughtful approach to reopening construction that keeps safety first but we acknowledge the challenges presented when cities and towns implement guidelines and protocols that are different from the state. Here are a few to review:




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SBA PPP Loan Forgiveness Guidance and Application

The SBA recently released guidance and an application for PPP Loan Forgiveness but plenty of questions remain and updates keep coming as this Forbes article explains. Massachusetts saw 105,819 PPP loans issued for a total of $14 billion in loans ($511 billion issued in U.S.). Construction companies were a top recipient of the loans.

If you have questions related to PPP Forgiveness, we suggest watching this webinar held recently by ASM Member Withum.

The SBA has a helpful FAQ document on the PPP loan program. For example, one of the frequent questions we received from our members had to do rehiring laid off employees. The SBA included this FAQ on their page:

Question: Will a borrower’s PPP loan forgiveness amount (pursuant to section 1106 of the CARES Act and SBA’s implementing rules and guidance) be reduced if the borrower laid off an employee, offered to rehire the same employee, but the employee declined the offer?

Answer: No. As an exercise of the Administrator’s and the Secretary’s authority under Section 1106(d)(6) of the CARES Act to prescribe regulations granting de minimis exemptions from the Act’s limits on loan forgiveness, SBA and Treasury intend to issue an interim final rule excluding laid-off employees whom the borrower offered to rehire (for the same salary/wages and same number of hours) from the CARES Act’s loan forgiveness reduction calculation. The interim final rule will specify that, to qualify for this exception, the borrower must have made a good faith, written offer of rehire, and the employee’s rejection of that offer must be documented by the borrower. Employees and employers should be aware that employees who reject offers of re-employment may forfeit eligibility for continued unemployment compensation.

The Senate could vote as early as this week on a bill that would double the loan forgiveness period to 16 weeks. The House is expected to vote this week on standalone legislation that would extend the loan forgiveness period to as long as 24 weeks and also eliminate the rule requiring PPP borrowers to spend at least 75% of the funds on payroll costs to qualify for full loan forgiveness. A separate Senate bill would also expand the loan forgiveness period to 24 weeks and eliminate the 75% rule.

Critics of the eight-week loan forgiveness period argue that it isn’t flexible enough for businesses that have dealt, and in many cases continue to deal, with state and locally mandated stay-at-home orders that have kept many types of businesses closed or operating at significantly reduced capacity. Critics of the 75% rule argue that it does not do enough to accommodate businesses whose employees haven’t been able to work because of government-imposed business closures.


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OSHA Updates
Revised Enforcement Guidance for Recording Cases of Coronavirus Effective May 26, 2020

OSHA has issued updated guidance on the requirement for certain employers to record cases of COVID-19 that will become effective on May 26, 2020. All employers who are required to keep OSHA injury and illness logs—not just healthcare employers, corrections facilities and emergency-response providers—must now determine whether employees’ confirmed COVID-19 cases are reportable.

Employers subject to OSHA’s recordkeeping requirements are responsible for recording COVID-19 cases, if: (1) the case is a confirmed case of COVID-19, as defined by the Centers for Disease Control and Prevention (CDC); (2) the case is work-related as defined by 29 CFR § 1904.5; and (3) the case involves one or more of the general recording criteria set forth in 29 CFR § 1904.7. A confirmed case of COVID-19 means an individual with at least one respiratory specimen who has tested positive for SARS-CoV-2.

The new guidance instructs OSHA compliance safety and health officers to consider the factors below in determining whether employers have met their obligation to report confirmed COVID-19 cases.

According to the new guidance, a COVID-19 case is likely work-related, if there are no alternative explanations, under the following circumstances:

  • Several cases develop among workers who work closely together;

  • COVID-19 is contracted shortly after lengthy, close exposure to a particular customer or coworker who has a confirmed case of COVID-19; or

  • The job duties of an employee who contracts COVID-19 include having frequent, close exposure to the general public in a locality with ongoing community transmission.

Alternatively, a COVID-19 case is likely not work-related in the following instances:

  • The employee is the only worker to contract COVID-19 in his or her vicinity, and their job duties do not include having frequent contact with the general public, regardless of the rate of community spread; or

  • Outside the workplace, the employee closely and frequently associates with someone (e.g., a family member, significant other or close friend) who (1) has COVID-19; (2) is not a coworker; and (3) has exposure to the employee during the period in which the individual is likely infectious.

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A word on face masks

In April, OSHA issued guidance on the use of face masks due to the shortage of N95 masks. When social distancing is not possible on a jobsite, extended use of N95 or another NIOSH filtering facemask is permissible under certain circumstances. See the OSHA Guidance for additional information and this helpful article. Also, check with the State’s new PPE Registry for companies selling masks.

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New ANSI Lift Standards Delayed Until June1

Reminder- The New ANSI Lift Standards Delayed AGAIN until June 1, 2020. The changes have already been postponed twice and requires training for occupants and supervisors of aerial equipment. For occupants, detailed training on both categories of MEWP including a classroom and hands-on portion are required. For Supervisors, only the classroom portion is necessary unless they will also be riding in the MEWP. Essentially, the occupant training is enough for both Supervisors and Occupants, but the Supervisor training alone will not cover occupants.

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Recent Events:
Recent Events

We hope you had the chance to join us for one of our recent online programs or webinars. Special thanks to ASM Associate Members and partners for facilitating these sessions. Please continue to visit our resource page on our website for everything related to the Coronavirus included previously recorded webinars. We will continue to update this page with the latest information related to construction.

PPP Intricacies and Federal Tax Updates from Withum

ASM Open Member Forum

ASM Conversation with Mayor Marty Walsh

Cybersecurity in the time of COVID-19

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Member News
2020 ASM Scholarships Applications Deadline Approaching

The ASM Scholarship deadline is being extended to June 1st (previously April 1st). Anyone who is interested in applying should visit the ASM website for additional information and the application. Each year, we proudly award up to five $2,000 scholarships to deserving students who are part of the ASM family. Also, four $500 trade school scholarships are awarded.



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Welcome New Members!

ASM proudly welcomes the following new members to the Association.

AETNA Fire Alarm Service Company, Inc. Boston, MA

At Aetna Fire Alarm Service our mission is simple – to provide the highest level of life safety and fire protection service possible and in doing so, continue to earn the respect and trust of our customers and maintain our reputation as a leader in the fire alarm industry.

Beacon Fire Protection Inc., Weymouth MA
Fire Protection/Sprinklers

(781) 803-3387

Curran Antonelli, Boston MA

Curran Antonelli prides itself on client-driven service, providing trusted counsel to midsize and large multinational organizations throughout the United States and Western Europe. With a well-established foundation of knowledge and understanding of our clients’ business interests, we are able to provide and implement the strategies most effective in restoring your litigation and corporate transactional challenges.

Graziano Redi Mix, Inc., Bridgewater, MA

Graziano Redi Mix, Inc. is a family owned and operated concrete company located in Bridgewater, MA, with more than 50 years of experience in the concrete industry. Our main goal is to provide our customers with the best customer service possible. We want to be your first choice contractor by offering fair and competitive pricing, quality materials, and superior service. Word of mouth is our best advertisement!

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ASM Associate Members are your Trusted Partners

Are you looking for services from a trusted partner? Consider contacting an ASM Associate Member. Our Associate Members include suppliers, law firms, insurance companies, financial advisors and more. Click here for a list of our Associate Member firms.

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Regulatory Update
Proposed UPDATES TO PFML Regulations

Catherine E. Reuben, Hirsch Roberts Weinstein LLP

On May 8 and May 15, the Massachusetts Department of Family and Medical Leave (DFML) announced that it will be updating its regulations, found at 458 CMR 2.00. Included with the announcement was a link to draft regulations, which are redlined to show the proposed changes to the current version. The DFML stated that there will be a public hearing on June 11, 2020 via WebEx. 

Most of the proposed changes are, in our view, helpful and beneficial. There are some that we feel are vague or otherwise problematic. We intend to share that feedback with the DFML, and to offer concrete suggestions to fix it in a manner that achieves the public policy goals of this important new law.

Below is a summary of some of the proposed changes that we view as noteworthy:

Leave Eligibility

There are several changes that have the effect of reducing the number of persons eligible for PFML benefits. These include the following:

  • The term “Active Duty” is defined as full-time duty only, thus potentially restricting the number of persons eligible for qualifying exigency leave.  2.02

  • Substance Abuse Disorders are not considered chronic conditions under the new regulations unless inpatient hospital care is required or unless complications develop.  This restriction does not apply to federal FMLA. 2.02

  • Domestic Partners cannot be less than 18 years of age. 2.02

  • To take leave to care for a Former Member of the Armed Forces, such former member must have been discharged or released under conditions other than dishonorable during the five-year period prior to the completion of an application for benefits to care for such person. 2.02

  • The new regulations confirm the DFML’s position, stated on its website, that contractors are not eligible for PFML benefits if they are properly classified as independent contractors  under the Massachusetts unemployment statute, even if they make up more than 50% of the entity’s workforce. 2.02, 2.03(4)

Leave Taken for Qualifying Reason Counts toward the Annual Total, even if the Employee Does not Apply for Benefits

In several places, the new regulations make clear that any time an employee takes leave that is “associated with a qualifying reason” — regardless of whether they apply for DFML benefits, and regardless of whether that leave is paid or unpaid –- that leave counts toward their annual allotment, provided the leave occurs after January 1, 2021.  The replacement of the word “paid leave” with just “leave” throughout the section on Leave Allotments reinforces that point.  2.08(8), 2.12(6) 

The phrase “associated with a qualifying reason” is not defined and could be subject to differing interpretations.  The provision is potentially beneficial for employers, in that more time off taken by employees can be counted, but on the flip side these “associated leaves” could also trigger the non-retaliation provisions.  2.16(3) 

Exemptions for Private Plans 

There are several changes impacting the drafting and implementation of Private Plans.  The proposed regulations state, consistent with the DFML’s position, that exemptions can be obtained for just family leave, just medical leave, or both; however, an employer cannot get an exemption for only part of its workforce.  2.07(1)(a) 

The proposed regulations state that, “notwithstanding” the Financial Eligibility Test, coverage under a private plan begins for all employees on the first day of the first quarter following approval.  Further, and again “notwithstanding” the financial eligibility test, the benefit amount is based on wages with the employer at the time of the application for benefits. 2.07(1)(c), 2.07(2)  It appears that the DMFL is essentially saying that, for a private plan, there is no need for the plan administrator to consider what the person earned from another employer in the past or is earning currently from other employers.  Instead, the Plan simply provides benefits based on the person’s employment with that employer.  If that is indeed the DFML’s intent, we would offer specific revisions to make that intent clearer, as the current language may be susceptible to multiple interpretations.  We would also seek clarification as to whether the DFML intended that employees who work very few hours (like casual employees), and who work for an entity with an approved private plan, would be eligible paid leave benefits that workers applying through the state would not be.

Private Plans are now required to have an appeal process.  The proposed regulations to not include any specific procedural requirements for such appeals (e.g., whether it can be in writing, etc.)  2.07(2)(c)  

The proposed new regulations provide penalties for failure to maintain an approved private plan, and there are new provisions to provide for a smoother off-ramp for the employees if a private plan is terminated.  2.07(8)

Applying for Benefits and Notice

The section starts by stating that an individual cannot file an application for benefits more than 60 calendar days prior to the anticipated start date of their leave.  It goes on to state that, before filing with the DFML, the employee must give their employer 30 calendar days’ prior notice or notice as soon as practicable if the delay is beyond the employee’s control.  Notice must be provided to the employer before the employee can file an application with the DFML.  2.08(2)  Individuals must consult with their employer about the dates for planned treatment before applying for benefits from the DFML. 2.08(2)    The regulations then state that if, for reasons beyond the individual’s control, the individual cannot provide at least 30 calendar days’ notice to the DFML, the individual must provide notice as soon as practicable.  (This particular provision is subject to interpretation and could be made clearer.)  Read together, the provisions make sense – communication and coordination between employer and employee before the DFML gets involved, and a window of time to get it all done. 

The regulations state that, consistent with the notice requirements, the DFML may allow an employer or its designees to submit applications on behalf of covered individuals; provided that they have approval from the DFML and agree to adhere to all of the requirements with respect to such application, including all the timelines.  The proposed regulations are silent on whether the employer would need the employee’s permission to do so or whether such employer-initiated applications would be handled or paid any differently.  2.08(9) 

The regulations go on to set forth procedures and timetables for the processing of claims: the information and documents that individuals must submit (including proof that they timely notified their employer), the information to be provided in the DFML’s notice to the employer and required timetable to do so (five business days after an application), the various certification requirements, and information to be provided by the employer — now including “whether the covered individual will be receiving any other wage replacement benefits as set forth in section 2.12(6)” (which section deals with reductions that can be made from PFML benefits). 2.12(1)-(9)

Individuals are required to provide the DFML notice of relevant changes in circumstances, and to reimburse the DFML if they were overpaid. 2.09(6)  Verifications are required, and employers may seek medical recertifications for intermittent leave when the initial period expires or every six months, whichever is less.  2.10

Interplay Between PFML Benefits and Employer Benefit Programs / Reductions, Refunds and Substitution of Paid Leave

The proposed regulations define a new term – Accrued Paid Leave. It includes any leave earned or provided pursuant to a benefit plan or policy offered by an employer, and includes but is not limited to sick leave, annual leave, personal leave, compensatory leave or paid time off.  The regulations sometimes use this defined term, but also refer in parts to “Paid Leave”, “accrued paid leave” and “an extended sick leave program.”  2.02, 2.12(6), 2.12(8)   The proposed regulations distinguish between the above types of leave, on the one hand, and a “temporary disability policy or program of the employer” or “a paid family or medical leave policy of the employer”, on the other – even though, for many employers, these benefits are blended.  2.12(8)  

Specifically, with respect to reductions, the proposed new regulations provide:

  •  PFML benefits – both the benefit amount and the leave allotment – are reduced by benefits received from a private plan.  2.16(6)(d)

  •  PFML benefit are also reduced by “any wages received from another employer or covered business entity or through self-employment”.  2.12(6)(d)   This provision may come as a surprise to employees who have more than one job.

  • Unless the total amount the employee receives would exceed their weekly wage, PFML benefits are not reduced by benefits received from employer temporary disability or family and medical leave policies. 2.12(6)

  • PMFL benefits – both the benefit amount and/or leave allotment – are “proportionately reduced” by “any paid or unpaid leave, wages, or wage replacement that a covered individual on family or medical leave receives from the same source for the same qualifying reason in the 12-month period prior to filing an application for benefits (but not including leave taken before 1/1/21).

  • PFML benefits may also be reduced where the covered individual has an outstanding tax or child support obligation.  It is not clear whether the person with such obligation simply gets less money, or if those amounts are garnished.

With respect to substitution of paid leave the proposed regulations provide as follows:

  • An individual may choose to use accrued paid leave provided by their employer “rather than” receive a paid benefit from the DFML.  An individual who chooses to use accrued paid leave provided by their employer or through an extended sick leave program rather than receiving a paid benefit from the DFML “shall not be compensated with paid leave benefits” under the law (presumably either from the DFML or a private plan) for a period of time for which they received compensation from these other sources. 2.12(8) 

           With respect to reimbursements the proposed regulations provide as follows:

  • Employers that make payments to covered individuals during a period of family or medical leave that are equal to or greater than the amount required under the law “shall be reimbursed” out of any benefits due to the person from the Trust Fund.  2.12   The section on reimbursements goes on to state, however, that to qualify for reimbursement, a temporary disability or paid family or medical leave policy or program of an employer must be “separate from and in addition to any sick leave, annual leave, vacation, personal leave, or accrued time off that is made available to the individual.”  2.12

  • If an individual elects to utilize accrued paid leave, whether in lieu of applying for benefits to the DFML or supplementary to a temporary disability or paid family or medical leave policy or program of an employer, the employer is not eligible for reimbursement.  2.12

  • Voluntary programs where individuals donate accrued leave time to fund a bank for a co-worker experiencing a qualifying reason under the PFML may be reimbursable if those payments were consistent with the law and regulations.

  •  An employer will never receive reimbursement where the person received a benefit from the Trust Fund at the same time.

Here is our understanding of how it is supposed to work, though the language could be made clearer in places.  If a time off benefit falls within the definition of Accrued Paid Leave, there are two repercussions.  First, the proposed regulations seem to say that an employee cannot use Accrued Paid Leave and get PFML benefits at the same time.  If the employee uses Accrued Paid Leave while out for a PFML-qualifying reason, the employee will not receive PFML benefits for the same time period as is covered by such Accrued Paid Leave.  The absence will still count toward the employee’s annual total time off allotment, but they will not get any extra pay from the DFML.  Further, if the absence is paid through use of Accrued Paid leave, the Employer will not get any refund.  Employers do get a refund for paid disability, family and medical leave so long as the total dollars received by the employee do not exceed their regular weekly wage; however, employers will not get a refund if the benefit falls within the definition of Accrued Paid Leave.  

If our understanding is correct, there could be some unintended consequences of this approach.  Employers would have a financial incentive to retool their existing benefits so that a larger percentage falls outside of the definition of Accrued Paid leave.  Put another way, employers may seek to reduce vacation and sick time, and replace those benefits with benefits that would be reimbursable.  The end result may be that, after January 1, 2021, workers will have fewer paid days off and less flexibility with respect that time off.  Further, this proposed approach to Accrued Paid Time is arguably inconsistent with the law itself.  This is an important issue about which both employer and employee advocates need to offer commentary and suggestions.

Intermittent Leave

          The proposed regulations have a number of new provisions related to intermittent leave including:

  • The definitions clarify that intermittent leave shall be taken in increments of 15-minute intervals.  We note that this standard is different from both the standard under the FMLA regulations and under the Massachusetts Sick Time regulations.  2.02

  • If an employee’s utilization of intermittent leave is inconsistent with the DFML’s approval, it shall not be considered retaliation for an employer to request additional information related to the use of the leave.  2.13(2)

  • The employer shall furnish the DFML with information on wages paid to a person on intermittent leave, and if the person is found to have received wages from both the employer and the DFML for the same period, the DFML may seek a refund from the individual.  2.12(2)

  • There are some new provisions to deal with persons who have a varied schedule.  2.13(3)

  • In cases of intermittent leave approved by the DFML, the benefit year commences on the Sunday immediately preceding the first absence following the exhaustion of the prior benefit year.  2.13(5)

Retaliation and Fraud

The proposed revised section on the presumption of retaliation due to negative changes made in the six months following a leave clarifies that “a negative change shall not include trivial, or subjectively perceived inconveniences that affect de minimis aspects of an employee’s work.”  2.16(3)

Employers with a bona fide belief that an employee has committed fraud can notify the DFML and such act shall not be deemed retaliation.  2.16

The anti-retaliation provisions of the regulations apply to all leave associated with a qualifying reason, regardless of whether the individual has applied for benefits. 

The proposed regulations include a statement, “For the avoidance of doubt, leave taken by an employee under subsection (3) of this section [which is the section dealing with the six-month period for presumption of retaliation] shall be begin on the first day that an employee takes leave.”  2.16(3)  This provision could be subject to differing interpretations and, in our view, should be clarified.

An employer’s application of a pre-existing employment rule or policy is deemed “clear and convincing evidence” to rebut a presumption of retaliation.  2.16


We commend the DFML for its hard work on the proposed new regulations.  While many of the changes are excellent, there are some that may have unintended consequences, are susceptible to multiple interpretations, or which otherwise could be improved.  We look forward to continued dialogue about the proposed regulations with the labor and employment law community, and to sharing our comments and suggestions with the DFML. 

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Legislative Update
Legislative Update

Just like the economy, the 2019-2020 Legislative Session is seeing the impact of COVID-19. Normally at this point, we would be looking at the rush of the start of the final two months of the formal session. The usual legislative process will undoubtedly be different this year. Budget negotiations, a current main priority for the legislature, will follow a different process. Formal sessions may well continue into the fall and winter.

ASM recently submitted this letter House and Senate leaders outlining some of the major concerns that subcontractors are facing. With the establishment of the Governor’s Reopening Advisory Board, ASM, along with several other partner subcontractor associations, submitted this letter.

Because the Legislature is focused on addressing the COVID-19 crisis, a number of bills that ASM is tracking are in a temporary holding pattern. This includes our own indemnity reform; wage theft legislation, a contractor liability bill, a bill extending prompt pay to public work; MWBE bills; the large transportation bond bill, an OSHA violation notice legislation; a bill changing apprenticeship requirements for public work; and much more. At this point it is unknown when the legislature will turn their attention to these and many other bills. That could happen this summer or later into the fall. ASM remains focused and ready to engage on all these important issues.

One bill you may have heard about is a bill filed by the Baker-Polito Administration that gives additional authority to DCAMM and all awarding authorities. Specifically, it would allow the awarding authority to set MBE and WBE participation goals by requiring filed sub-bidders to subcontract up to 10% of the work on filed sub-bids or trade bids on projects where the overall value exceeds $5 million. The bill would also amend the filed sub-bid law to raise the threshold for which the law applies from $150,000 to $1,000,000 total job value and increase the individual bid value from $25,000 to $50,000.

ASM has a long history of supporting ways for more MWBE firms to enter the construction business but at the same time, we will raise some points of concern with some of the specifics in this bill. You may have participated in one of a series of outreach sessions hosted by DCAMM. Click here to access their presentation. ASM is currently planning another session with DCAMM specifically for ASM Members.

Are you interested in legislation and politics? If so, we would love to have you join our Legislative Committee. The Committee meets periodically to review and discuss pressing legislative and regulatory matters and how they would impact ASM and the members. Contact ASM if you would like to volunteer!

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Thank you to our 2020 Premium Sponsors



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Do You Have A Legal Question? Accessing The ASM Hotline

As an employer, you face a myriad of issues including employee leave, discrimination, wage and hour rules, hiring and termination.  As a construction business, you face a host of issues through the life of a project, including bidding, contract terms, payment and more. When issues arise, it’s often hard to know what to do. There is an easy way to get quick answers to your questions – ASM’s Hotline –FREE to ASM Members.

How do I access the Hotline? Send an email to We will forward your question to the appropriate attorney who will respond by phone or email.

Who are the attorneys?

Construction questions are referred to JohnM. Curran, Esq. at the law firm of Corwin & Corwin LLP, which has served as legal counsel to ASM for more than 65 years.

Employment questions are referred to David B. Wilson, Esq. and Catherine E. Reuben,Esq., at the law firm of Hirsch Roberts Weinstein, LLP.

Insurance questions are referred to David M. O’Connor, Esq. at the law firm of O’Connor & Associates, LLC.

What if I already have my own lawyer?
You can still call the Hotline. It is a privilege of membership in ASM.

What kind of help can I expect?
The attorney will typically spend 5-15 minutes addressing questions that can be answered easily based on years of experience in their areas of practice. You will receive information to help you determine whether to handle the issue yourself or to seek professional help to pursue legal action. The Hotline is limited in scope and does not include research or document preparation.

To pursue legal action, do I have to use the Hotline attorney? No. You are free to use your own attorney or you may retain a hotline attorney. The choice is up to you and it is a private matter between you and the attorney.

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Are You Following ASM On Social Media?

ASM is now on Instagram. Check us out, follow us, and comment on our photos!

Please also like the ASM Facebook page and follow us on Twitter and LinkedIn.



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Published by:

Associated Subcontractors of Massachusetts, Inc.
15 Court Square, Ste. 840
Boston, MA 02108