If you have multiple facilities, you run the risk of repeat violations. Here’s a notice to give site managers to manage the liability risks.

The purpose of this Briefing is to notify you about the risk of being cited for repeat violations by OSHA and what we need you to do to help us manage this risk.

Background
As you know, [name of company] has [number] facilities across the U.S. OSHA inspectors may visit any one of these facilities at any time and issue a citation if they spot a hazardous condition. This can lead to fines, work stoppages and other penalties.

A repeat violation can occur when a company is cited more than once for the same violation. Repeat violations are a big concern because they can lead to fines up to $70,000, subject the company to further inspections under OSHA’s strict new enforcement program and damage its reputation. 

How Repeat Violations Can Occur
Repeat violations can occur when an inspector returns to a facility and finds that the problem he cited before hasn’t been fixed. But a company, like ours, that has many facilities can also get hit with a repeat violation if the same violation is found at more than one facility.

In other words, a citation at any one of our other facilities counts as strike one against all the others. And as far as repeat violations are concerned, you only get two strikes before you “strike out.”

What We Can Do To Prevent Repeat Violations
What this means is that when one facility gets cited for an OSHA violation, we’re all vulnerable. So we need to work together to protect the company. Some of the common measures we intend to take:

1. SHARE DATA. If your facility is inspected by OSHA, immediately send a copy of the inspection file including, but not limited to, notes from the opening and closing conferences, correspondence, settlement agreements, inspection notes and photos and steps taken to correct any violations, to the central office.
2. CREATE A COMPLIANCE COMMITTEE. A joint committee comprising representatives from each of the company’s [number] facilities will be formed shortly and shall meet monthly by conference call. Appoint yourself, a compliance officer or other designee to serve on this committee who will be responsible for reporting on OSHA-related activities at your site.
3. ISSUE MONTHLY REPORTS. Headquarters will coordinate compliance efforts among the facilities and issue a monthly report summarizing new initiatives, inspection results and other OSHA developments from each facility.