This memorandum rescinds and replaces the memorandum dated January 26, 2023, on the same subject. This memorandum further clarifies the policy described in the earlier memorandum. Under this policy, Regional Administrators and/or Area Directors may refrain from grouping violations where the violations are separate and distinct, even if other OSHA policies or directives recommend grouping the violations. This enforcement discretion is an important tool to deter employers from disregarding their responsibilities to protect workers and comply with OSHA standards and regulations.