Recently, we have begun to see many instances where employers receive many OSHA citations which appear to allege substantially similar violations, some of which contain separate monetary penalties. In many instances, these citations are properly identified as “duplicative” and should not have been issued and should be vacated. Unfortunately, unless the employer is aware that it can assert this type of a defense, the employer may be accepting citations with increased monetary penalties and which also expose the employer to Repeat citations over the next three years. The enclosed article discusses this defense and how to assert it.
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