OSHRC decision on PRCS Tanker Truck Willfuls

This OSHRC decision reverses an ALJ decision which I posted in August 2013, but this case has some very interesting aspects that EVERYONE who manages a PRCS Entry program needs to read.  Most notably, this case involves: 

1. gas meter maintenance,  
2. program revision/employees not protected,
3. “Conditions” Required for Alternate Entry,
4. program revision/annual permit review,
5. enforcement,
6. specify acceptable entry conditions.

I have highlighted some key aspects, but this one the OSHRC got it right!