OSHA’s Citation Policy for Paperwork and Written Program Requirement Violations (CPL 02-00-111)

OSHA recognizes that in some situations, violations of certain standards which require the employer to have a written program to address a hazard, or to make a written certification (e.g., hazard communication, personal protective equipment, permit-required confined spaces, and others), are perceived to be “paperwork deficiencies” rather than critically important implementation problems. In other circumstances, violations of such standards have a significant adverse impact on employee safety and health.  The purpose of this instruction is to provide guidance which will lead to consistent and effective enforcement of OSHA’s standards, particularly where technical violations involve employer obligations for posting, recordkeeping and documentation of performance, and have no adverse impact on worker safety and health.

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