The recent appointment of David Michaels as the new head of OSHA signals an aggressive OSHA with an active enforcement agenda. For employers, this means more inspections and more citations. But it also means that a greater portion of citations issued will be of higher gravity: more Willful citations, more Repeat citations, and more citations issued under OSHA’s “egregious penalty policy,” which gives the agency the ability to issue separate citations on a per-instance or per-employee basis.
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