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UPDATES: BRIEFLY NOTED

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The Occupational Safety and Health Administration cannot force 80,000 employers to answer a survey on occupational injuries and illness sustained in 1995 because it did not issue a regulation mandating participation, U.S. District Court Judge Thomas P. Jackson ruled earlier this week in Washington. The American Trucking Assns. sued OSHA over the survey nearly a year ago, holding that the agency did not follow proper rule-making procedures. . . .Six African-American hourly employees at Texaco Inc. who are not a part of the company's proposed $176 million race-discrimination settlement are asking to intervene, alleging they are unfairly excluded from the settlement because it covers only salaried employees. . . .Wisconsin became the 21st state to sue the tobacco industry Feb. 5 when Wisconsin Attorney General James Doyle filed suit in Dane County Circuit Court in Madison, alleging the industry has engaged in a conspiracy to mislead, deceive and confuse Wisconsin residents about the health effects of tobacco and the addictiveness of nicotine. Among other things, the suit seeks reimbursement for state spending on tobacco-related health care costs. . . .The planned $86.7 million acquisition of Boston-based John Hancock Mutual Life Insurance Co.'s group health and related businesses to Woodland Hills, Calif.-based WellPoint Health Networks Inc., which had been scheduled for Jan. 31, has been postponed in light of an preliminary injunction by a federal judge in Detroit in favor of Troy, Mich.- based SelectCare Inc. SelectCare, which manages a network of doctors and hospitals, had filed suit Jan. 28 claiming consummation of the transaction would violate certain provisions of agreements between Hancock and SelectCare. Wellpoint and Hancock said while they have extended their agreement until March 1 to evaluate the order's impact, there "can be no assurance" the deal will be completed. . . .Abdoul Sesay, the former risk manager for the Los Angeles subway construction project, has been sentenced to 14 months in federal prison for tax evasion and accepting kickbacks from insurance consultants. He pleaded guilty to the felonies in July 1995. . . .Sphere Drake Holdings Ltd. has transferred its protection and indemnity business to the London unit of HIH Winterthur Insurance Group in Sydney, Australia. The P&I unit had a 1996 net premium income of about $20 million.