BACKGROUND: Safety inspections of the shop and parts department have revealed that many employees are not wearing appropriate footwear that can adequately protect them from foot injuries caused by crushing or falling objects, such as a rotor or a battery.  Sharp objects left on the shop floor can also penetrate the shoe and injure the foot. Footwear in the shop area must be slip resistant to protect employees should they encounter slippery surfaces (slip hazards are common due to accidental spills of lubricants in the shop).  The porters are subject to abnormally wet locations (car wash) and as such, their shoes must provide traction.  Recently, an automobile dealer was cited for failure to provide safety shoes.  A penalty of $5850 was assessed by Cal/OSHA for this serious violation.  California Court of Appeals has also upheld a citation against employers not providing proper safety footwear. See Home Depot U.S.A., Inc. v. Cal. Occupational Safety & Health Appeals Bd., E070417 (Cal. Ct. App. Oct. 17, 2019)

WHAT DO THE CALIFORNIA REGULATIONS SAY:

The Cal/OSHA regulation (T8CCR3385) is stated as follows:

1. Appropriate foot protection shall be required for employees who are exposed to foot injuries from electrical hazards, hot, corrosive, poisonous substances, falling objects, crushing, or penetrating actions, which may cause injuries or who are required to work in abnormally wet locations.
2. Footwear which is defective or inappropriate to the extent that its ordinary use creates the possibility of foot injuries shall not be worn.
3. (1) Protective footwear for employees purchased after January 26, 2007 shall meet the requirements and specifications in American Society for Testing and Materials (ASTM) F 2412-05, Standard Test Methods for Foot Protection and ASTM F 2413-05, Standard Specification for Performance Requirements for Foot Protection which are hereby incorporated by reference.  The ASTM standard as quoted in the OSHA standard has been updated.  See note below.

Note 1: ASTM F2412-18a and ASTM F2413-18 are the most current standards in the industry. ASTM F2413-18 contains basic requirements to evaluate footwear, which include: Impact resistance (I), Compression resistance (C), Metatarsal protection (MT), and Conductive properties (CD) to limit static electricity buildup. In addition to these requirements, this standard requires labeling on the safety footwear to identify specific protections.

Note 2:  Cal/OSHA regulations, as mentioned above, state that footwear that creates the possibility of foot injuries shall not be worn and hence, any shoes that may cause injuries from ordinary use in the shop area should not be used.

WHAT DO THE FEDERAL REGULATIONS SAY: 

Federal Regulation as stated in CFR 1910.136(a) is as follows:  The employer shall ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, or when the use of protective footwear will protect the affected employee from an electrical hazard, such as a static-discharge or electric-shock hazard, that remains after the employer takes other necessary protective measures.

Note 3:  The criteria for protective footwear is listed in 1910.136(b)(1)(i) where the footwear must meet the ASTM F-2412-2005, “Standard Test Methods for Foot Protection,” and ASTM F-2413-2005, “Standard Specification for Performance Requirements for Protective Footwear,” which are incorporated by reference in § 1910.6.  As noted above the ASTM regulations have been updated in 2018 and should be used for selection of footwear.

BEST PROTECTION:  Shoes for staff must meet ASTM standard as listed in Note(s) above.  The shoe must have metatarsal protection with a skid resistance sole. Metatarsal protectors consist of a guard that fits over the instep protecting the top of the foot from heavy items and are normally manufactured from aluminum, steel, or lightweight composites.  The car wash staff and any staff that encounter slippery surfaces must also wear shoes with soles that provide slip resistance and good traction.

HAZARD ASSESSMENT: OSHA regulations require that the employer conduct a workplace hazard assessment and provide PPE for protection from physical and health hazards present at the workplace.  If the hazard assessment of parts and service employees indicates the possibility of a foot hazard injury from falling objects, PPE should be provided.  See Title 8 California Code of Regulations Section 3380.  Fed-OSHA requirements on Hazard Assessment and Personal Protective Equipment selection are listed under CFR 1910.132 (a-d).

WHO PAYS-CA: The California Labor Code requires employers to “furnish and use safety devices and safeguards…” (Labor Code § 6401). The term “safety device” includes “any practicable method of mitigating or preventing” danger. Protective footwear is covered as a safety device. The Labor Code also requires employers to “provide and use safety devices and safeguards reasonably adequate to render the employment and place of employment safe.” (Labor Code § 6403).  Legal opinion on this matter has been made clear by the California Supreme Court. The Court has ruled that the words “provide” and “furnish” mean that the employer both supplies and pays for the personal protective gear.  (See Bendix Forest Products Corp. v. Division of Occupational Safety & Health (1979) 25 Cal. 3rd 465, 471-473).

WHO PAYS-Federal:  The shoes with metatarsal protection and slip resistant shoes are considered specialty footwear and require the employer to pay for the protective footwear.  OSHA has exempted employers from payment when the safety shoes are non-specialty type.

PROTECTIVE SHOE POLICY & ENFORCEMENT: The employer must provide shoes to each employee subject to foot injury hazards. Since shoes must be fitted for size and comfort, it is practical to seek help from a professional shoe supply company. Replacement upon wear and tear of the PPE is also the responsibility of the employer, along with instructions on proper usage, care, cleanliness, and maintenance. A written protective footwear policy should be adopted and distributed to all employees, and employee acknowledgment should be retained in files. Enforcement of policy, along with disciplinary action against employees violating the policy must also be put into effect.

SUMMARY: Proper footwear for certain employees is not an option but is a requirement under the law. Employees with their feet protected are less likely to be injured from falling objects. Shoes with good traction help mitigate slip and fall hazards. Fewer injuries translate to fewer workers’ compensation claims and a reduction in related premiums. Improved productivity, better employee morale, and increased shop efficiency are also a given. 

DISCLAIMER:  The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.   Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

California has enacted regulations that require employers to comply with a series of employee health & safety and workers’ comp regulations.  The regulations are lengthy and complex. This newsletter highlights Cal/OSHA Emergency Temporary Standard (ETS) and COVID-19 ETS FAQ. The ETS is currently effective till October 2, 2021 and may be readopted twice thereby extending the effective life of this regulation.  Legal challenges to ETS by employer trade groups are pending in LA County and San Francisco Courts and a possible adverse ruling to the ETS may provide relief to employers.

Key Definitions:

1. “COVID-19” means coronavirus disease, an infectious disease caused by the severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2).
2. “COVID-19 case” means a person who:
   1. Has a positive “COVID-19 test” as defined in this section;
   2. Is subject to a COVID-19-related order to isolate issued by a local or state health official; or
   3. Has died due to COVID-19, in the determination of a local health department . . .
3. “COVID-19 exposure” means being within six feet of a COVID-19 case for a cumulative total of 15 minutes or greater in any 24-hour period.
4. “COVID-19 hazard” means exposure to potentially infectious material that may contain SARS-CoV-2
5. “Exposed workplace” means any work location, working area, or common area at work used or accessed by a COVID-19 case during the high-risk period.
6. “COVID-19 Outbreak” means three or more COVID-19 cases in an exposed workplace within a 14-day period. The employer shall contact the local health department immediately but no longer than 48 hours after the employer knows of three or more COVID-19 cases for guidance on preventing the further spread of COVID-19 within the workplace.

The COVID-19 Prevention Program: To comply with the ETS, an employer must develop a written COVID-19 Prevention Program. The employer must implement the following:

1. Communication to employees about the employer’s COVID-19 prevention procedures
2. Identify, evaluate, and correct COVID-19 hazards
3. Physical distancing of at least six feet unless it is not possible
4. Use of face coverings
5. Use engineering controls, administrative controls and personal protective equipment as required to reduce transmission risk
6. Procedures to investigate and respond to COVID-19 cases in the workplace
7. Provide COVID-19 training to employees
8. Provide testing to employees who are exposed to a COVID-19 case, and in the case of multiple infections or a major outbreak, implement regular workplace testing for employees in the exposed work areas
9. Exclusion of COVID-19 cases and exposed employees from the workplace until they are no longer an infection risk
10. Maintain records of COVID-19 cases and report serious illnesses and multiple cases to Cal/OSHA and the local health department, as required.
11. Return to work criteria.

COVID-19 ETS FAQ:

Q: What is the criteria for an employee exposed to a COVID-19 case in the workplace to return to work?
A: Employees with COVID-19 exposure may return to the workplace 14 days after the last known COVID-19 exposure.

Q: What training must an employer provide employees under the ETS?
A: Employee training must cover:

• Employer policies and procedures to protect employees from COVID-19 hazards.
• COVID-19 related benefit information, from either the employer or from federal, state, or local government, that may be available to employees impacted by COVID-19. Information on COVID-19 benefits such as paid sick leave and workers’ compensation benefits is posted on the Department of Industrial Relations’ Coronavirus Resources webpage.
• The fact that COVID-19 is an infectious disease that can be spread through the air when an infectious person talks or vocalizes, sneezes, coughs, or exhales; that COVID-19 may be transmitted when a person touches a contaminated object and then touches their eyes, nose, or mouth, although that is less common; and that an infectious person may show no symptoms.
• The importance of physical distancing and wearing face coverings.
• The fact that particles containing the virus can travel more than six feet, especially indoors, so physical distancing must be combined with other controls, including face coverings and hand hygiene, to be effective.
• The importance of frequent hand washing for at least 20 seconds and use of hand sanitizer when handwashing facilities are not available.
• Proper use of face coverings, and the fact that they are not respiratory protection.
• The symptoms of COVID-19 and the importance of not coming to work and getting tested if an employee has symptoms.

Q: What are the criteria for a COVID-19 case to return to work?
A: A COVID-19 case may return to work when any of the following occur:

• For employees with symptoms all of these conditions must be met:
  1. At least 24 hours have passed since a fever of 100.4 or higher has resolved without the use of fever-reducing medications.
  2. COVID-19 symptoms have improved; and
  3. At least 10 days have passed since COVID-19 symptoms first appeared.
• For employees without symptoms, at least 10 days have passed since the COVID-19 case’s first positive test.
• If a licensed health care professional determines the person is not/is no longer a COVID-19 case, in accordance with California Department of Public Health (CDPH) or local health department recommendations.

Q: What engineering controls and administrative controls must an employer implement?
A: Requirements include:

• Engineering controls
  • Install cleanable solid partitions that reduce the risk of aerosol transmission between fixed work locations where it is not possible to physically distance (such as Plexiglas barriers)
  • Maximize the amount of outside air to the extent feasible, unless there is poor outside air quality (an AQI of 100 or higher for any pollutant) or some other hazard to employees such as excessive heat or cold
• Administrative controls
  • Implement effective cleaning procedures of commonly touched surfaces, such as doorknobs, elevator buttons, equipment, tools, handrails, handles, controls, bathroom surfaces, and steering wheels
  • Inform employees and employees’ authorized representatives of cleaning and disinfection protocols and planned frequency and scope of cleaning
  • Minimize to the extent feasible the sharing of tools, equipment and vehicles
  • If tools, equipment and vehicles must be shared, disinfect between users

Cal/OSHA has posted a Model COVID-19 Prevention Program on its website for employers fill out and use.

Reference: https://www.dir.ca.gov/dosh/coronavirus/COVID19FAQs.html; https://www.dir.ca.gov/dosh/coronavirus/ETS.html; dl 01052021

DISCLAIMER:  The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.   Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at http://www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

Frequently Asked Questions – RECORDING INJURIES ON LOG

1. Do employers have to record COVID-19 illnesses on their Log 300?

Yes, California employers that are required to record work-related fatalities, injuries and illnesses must record a work-related COVID-19 fatality or illness like any other occupational illness. To be recordable, an illness must be work-related and result in one of the following:

1. • Death.
   • Days away from work.
   • Restricted work or transfer to another job.
   • Medical treatment beyond first aid.
   • Loss of consciousness.
   • A significant injury or illness diagnosed by a physician or other licensed health care professional.

If a work-related COVID-19 case meets one of these criteria, then covered employers in California must record the case on their 300, 300A and 301 or equivalent forms.  For work-related criteria, see Question 3 below.

See California Code of Regulations, title 8, Chapter 7, Subchapter 1, Article 2, Employer Records of Occupational Injury or Illness for details on which employers are obligated to report and other requirements.

1. Does a COVID-19 case have to be confirmed to be recordable?

Pursuant to recent federal OSHA guidance, a COVID-19 case should generally be confirmed through testing to be recordable. However, due to testing shortages and a variety of other reasons, not all persons determined to have COVID-19 have been tested.

Thus, while Cal/OSHA considers a positive test for COVID-19 determinative of recordability, a positive test result is not necessary to trigger recording requirements. There may be other situations in which an employer must make a recordability determination even though testing did not occur, or the results are not available to the employer. In these instances, the case would be still be recordable if it meets any one of the other general recording criteria from Section 14300.7 described above, such as resulting in days away from work. Cal/OSHA recommends erring on the side of recordability.

1. How does an employer determine if a COVID-19 case is work-related for recordkeeping purposes?

For recordkeeping purposes, an injury or illness is considered work-related if an event or exposure in the work environment either caused or contributed to the resulting condition, or significantly aggravated a pre-existing injury or illness. An injury or illness is presumed to be work-related if it results from events or exposures occurring in the work environment unless an exception in section 14300.5(b)(2) specifically applies.

A work-related exposure in the work environment would include interaction with people known to be infected with COVID-19 working in the same area where people known to have been carrying COVID-19 had been; or sharing tools, materials or vehicles with persons known to have been carrying COVID-19. Given the disease’s incubation period of 3 to 14 days, exposures will usually be determined after the fact.

If there is not a known exposure that would trigger the presumption of work-relatedness, the employer must evaluate the employee’s work duties and environment to determine the likelihood that the employee was exposed during the course of their employment.  Employers should consider factors such as:

1. • The type, extent, and duration of contact the employee had at the work environment with other people, particularly the public.
   • Physical distancing and other controls that impact the likelihood of work-related exposure.
   • Whether the employee had work-related contact with anyone who exhibited signs and symptoms of COVID-19.

See title 8 section 14300.5 for details and the exceptions.

1. Is time an employee spends in quarantine considered “days away from work” for recording purposes?

No. Unless the employee also has a work-related illness that would otherwise require days away from work, time spent in quarantine is not “days away from work” for recording purposes.

Frequently Asked Questions – REPORTING INJURIES to Cal/OSHA

1. When do employers have to report COVID-19 illnesses to Cal/OSHA immediately?

In addition to the recordkeeping requirements discussed above, California employers must also report to Cal/OSHA any serious illness, serious injury or death of an employee that occurred at work or in connection with work within eight hours of when they knew or should have known of the illness. (See section 342(a).) This includes a COVID-19 illness if it meets the definition of serious illness.  Failure to report carries a penalty of $5,000.

A serious illness includes, among other things, any illness occurring in a place of employment or in connection with any employment that requires inpatient hospitalization for other than medical observation or diagnostic testing. (See section 330(h).) This means that if a worker becomes ill while at work and is admitted as in-patient at a hospital — regardless of the duration of the hospitalization — the illness occurred in a place of employment, so the employer must report this illness to the nearest Cal/OSHA office. Reports must be made immediately, but not longer than eight hours after the employer knows or with diligent inquiry would have known of the serious illness.

Fed-OSHA Reporting Guidelines:  Employers have to report the following events to Fed-OSHA:

• All work-related fatalities
• All work-related in-patient hospitalizations of one or more employees
• All work-related amputations
• All work-related losses of an eye

Employers must report work-related fatalities within 8 hours of finding out about it. For any in-patient hospitalization, amputation, or eye loss employers must report the incident within 24 hours of  learning about it. Only fatalities occurring within 30 days of the work-related incident must be reported to OSHA. Further, for an inpatient hospitalization, amputation, or loss of an eye, then incidents must be reported to OSHA only if they occur within 24 hours of the work-related incident.

1. What if the employee became sick at work but the illness is not work-related?

For reporting purposes, if the employee became sick at work, it does not matter if the illness is work-related. Employers must report all serious injuries, illnesses or deaths occurring at work without making a determination about work-relatedness. For some diseases such as COVID-19, associated respiratory symptoms such as difficulty breathing can be caused by a variety of occupational exposures. It is important for employers to report these cases to Cal/OSHA so that the Division can make the preliminary determination of work-relatedness.

1. What if an employee started to show symptoms outside of work?

Reportable illnesses are not limited to instances when the employee becomes ill at work. Serious illnesses include illnesses contracted “in connection with any employment,” which can include those contracted in connection with work but with symptoms that begin to appear outside of work. An employer should report a serious illness if there is cause to believe the illness may be work-related, regardless of whether the onset of symptoms occurred at work.

For COVID-19 cases, evidence suggesting transmission at or during work would make a serious illness reportable. An employer should consider factors similar to those described above in the answer to Question 3 under Recording:

1. • Multiple cases in the workplace.
   • The type, extent, and duration of contact the employee had at the work environment with other people, particularly the public.
   • Physical distancing and other controls that impact the likelihood of work-related exposure.
   • Whether the employee had work-related contact with anyone who exhibited signs and symptoms of COVID-19.

Where there is uncertainty about whether an employee contracted COVID-19 at work, the employer should err on the side of reporting the illness to Cal/OSHA.  Reporting a serious injury will trigger an OSHA investigation that may lead to further penalties, an employer is well served to determine whether the injury is work related or not as soon as possible.

1. Do I report an illness even if COVID-19 has not yet been diagnosed?

Yes, even if a suspected COVID-19 case has not been diagnosed by a licensed health professional, an employer should still report it to Cal/OSHA if the illness occurred in connection to any employment related issue as described above and if it resulted in death or in-patient hospitalization.

1. Am I admitting to liability when I report a serious illness?

No. Reporting a serious illness is not an admission that the illness is work-related, nor is it an admission of responsibility.

1. How does the Governor’s Executive Order on COVID-19 and workers’ compensation eligibility affect Cal/OSHA reporting and recording requirements?

Governor Newsom’s Executive Order N-62-20 addresses eligibility for workers compensation benefits. FAQs on the Order are available on Cal/OSHA’s website. The Order does not alter employers’ reporting and recording obligations under Cal/OSHA regulations.

Source: https://www.dir.ca.gov/dosh/coronavirus/Reporting-Requirements-COVID-19.html

DISCLAIMER:  The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.   Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety.  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

As of April 17, 2020, Cal/OSHA had received over 1,500 complaints about employers who allegedly failed to provide proper protection during the ongoing pandemic related to the COVID-19 crisis.  OSHA’s investigative powers are limited in their ability to fully investigate all these complaints.  Cal-OSHA Reporter noted that in the first quarter of 2019, OSHA had investigated only 488 complaints.  For 2020, the number of investigations will likely increase.

WHAT IS OSHA LOOKING FOR:  The regulations that allow OSHA to investigate COVID-19 related complaints at auto dealerships are as follows:

Personal Protective Equipment:  Personal Protective Equipment (PPE) requires using gloves, eye and face protection, and respiratory protection when job hazards warrant it.  When respirators are necessary to protect workers, employers must implement a comprehensive respiratory protection program in accordance with the Respiratory Protection standard.  Compliance requires an assessment of hazards and then proving proper PPE that addresses those hazards.  PPE must be provided at no cost and employees provided with training in proper usage.

Hazard Communication Program:  Employers must also protect their workers from exposure to hazardous chemicals used for cleaning and disinfection. Employers should be aware that common sanitizers and sterilizers could contain hazardous chemicals. Where workers are exposed to hazardous chemicals, employers, must comply with this standard.  Requirements include a written program, providing SDS, proper labels on containers and training on understanding the hazards related to chemicals in use.

General Duty Clause:  The clause requires employers to provide each worker “a place of employment, which [is] free from recognized hazards that are causing or are likely to cause death or serious physical harm.”  This is literally the catch-all provision that OSHA inspectors can use when no standard seems to be violated.

HOW TO HANDLE AN OSHA INSPECTION

Inspections are always conducted without advance notice.  As a matter of policy, it is considered acceptable that the OSHA inspector may be kept wait for 20-minutes prior to the inspection process beginning  Management can alert all responsible Managers on the premises regarding the presence of OSHA and possible involvement in the inspection process.

WHAT DOES THE INSPECTION PROCESS INVOLVE?

Inspectors’ Credentials: When the OSHA compliance officer arrives at the establishment, he or she displays official credentials and asks to meet an appropriate employer representative.  In the opening conference, the compliance officer explains how the establishment was selected and what the likely scope of the inspection will be. Take written notes during the opening conference and note the scope indicated by the inspector.

The compliance officer asks the employer to select an employer representative to accompany the compliance officer during the inspection. This person must stay with the inspector until departure from the company premises.

Limitation on OSHA Inspections:  OSHA has limitations on inspection authority when visiting a place of employment. OSHA officers may try to expand the scope of inspection during the visit and upon informed consent may proceed to collect evidence that can significantly increase the violations detected and related penalties. Therefore, it is critical that the employer only provides OSHA with access to the location that is related to the underlying cause of inspection.  Such boundaries must be established during the opening conference with the OSHA officer.

In a recent case, the US Court of Appeals limited the scope of inspection available to OSHA.  The case involved an employee who was injured while repairing an electrical panel.  See USA v. Mar-Jac Poultry, Inc., No. 16-17745 (11th Cir. 2018).  The employee was hospitalized triggering a report to OSHA under federal regulations. OSHA inspected the facility and was granted access by the employer to look at the electrical panel area. Upon request, OSHA inspectors were provided Injury Log 300 by the employer. Upon review of Log 300, OSHA filed for a search warrant to investigate other locations at the plant where the injuries as reported on the Log 300 had occurred. The search warrant was granted. Subsequently, the employer filed a motion to vacate the search warrant which was granted by the District Court. OSHA appealed the lower court’s decision to the 11th Circuit Court of Appeals.

The appeals court held that logs are merely records of injuries and not proof of OSHA violations. The mere existence of injuries, the court noted in this case, does not mean that injuries were caused by OSHA violations, nor do they justify the issuance of administrative warrant for gathering evidence of OSHA violations. Recordkeeping regulations as found in 29 CFR Part 1904 state that the recording of injuries on Log 300 does not mean that an employer is at fault or that an OSHA violation has occurred. This decision serves as guidance to employers to limit OSHA inspections to the complaint area. Unless the employer consents, a judicial warrant is required under the Fourth Amendment. If OSHA wishes to expand its search under information procured during initial inspection, the employer should seek legal counsel to limit the inspection as available under the current law.

Walk-Through: Do not allow the inspector to veer in a direction not agreed in the scope at the opening conference! The compliance officer will observe safety, health conditions, and practices.

When compliance officer finds a violation in open view, called the “plain view exception,” the scope of inspection now incorporates the plain view observation. The employer may shut down the area of the shop where the inspector will  walk-through.  The compliance officer may wish to interview employees to get their opinion of the accident at the workplace.

Closing Conference: At the conclusion of the inspection, the compliance officer conducts a closing conference with the employer.  The compliance officer gives the employer and all other parties involved a copy of Employer Rights and Responsibilities Following an OSHA Inspection for their review and discussion. The compliance officer discusses with the employer all unsafe or unhealthy conditions observed during the inspection and indicates all apparent violations for which he or she may issue or recommend a citation and a proposed penalty. The compliance officer will inform the employer of appeal rights.

The office will request documents related to the inspection be mailed to OSHA in a specified time.  Discuss the documents prior to submission with your counsel.  At times, documents may be held back for reasons of privacy or relevance.

CITATIONS & PENALTIES ?

Citations: OSHA citations inform the employer and employees of the regulations and standards alleged to have been violated and note the proposed length of time set to correct alleged violations. The employer must post a copy of each citation at or near the place a violation occurred for 3 days or until the violation is abated, whichever is longer.  Certain notable violations for general industry in California for 2010-2016 can be found at https://www.dir.ca.gov/dosh/citation.html

Sam Celly of Celly Services, Inc. has been helping automobile dealers comply with EPA and OSHA regulations since 1987.  Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  His newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.