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OSHA Instance-by-Instance Citations

In January, OSHA published a general news release announcing an initiative to save lives. They issued an enforcement guidance document to regional and area offices aimed at employers who expose workers to life-threatening hazards.

The initiative gives the Area Directors and Regional Administrators the authority to cite certain types of violations as “Instance-by-Instance Citations” when the agency identifies a violation as a high-gravity serious violation of the OSHA Standards. The instance-by-instance citation authority allows OSHA to issue a citation for each employee exposed to the violating condition. These conditions include lockout/tagout, machine guarding, permit-required confined space, respiratory protection, falls, trenching, and for cases with other-than-serious violations specific to recordkeeping. The initiative applies to general industry, agriculture, maritime, and construction industries.

In addition, in a second action, OSHA is reminding the Area Directors and Regional Administrators not to group violations, but to keep them separate to encourage employers to comply with the intent of the standards.

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