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with significant bleeding, and strains) resulting from the CLOSING CONFERENCE &
work environment, work practices, or processes unless the PARTICIPANTS
employer did not or could not know about the violation. At the conclusion of an inspection, CSHOs will conduct a
To issue a serious violation, the compliance officer closing conference with the employer and the employee repre-
must be able to do four things: 1) Identify the type of sentatives, jointly or separately, as circumstances dictate. The
potential exposures to a hazard that violated the standard closing conference may be conducted on-site or by telephone.
or the general duty clause. 2) Identify the most serious If the employer refuses to allow a closing conference, the cir-
injury or illness that could reasonably be expected to result cumstances of the refusal will be documented and the case will
from the potential hazardous exposure identified in Step be processed as if a closing conference had been held. CSHOs
1. 3) Determine whether the type of injury or illness iden- normally hold the conference with employee representatives first,
tified in Step 2 could include death or a form of serious unless the employee representative requests otherwise. This pro-
physical harm. 4) Determine whether the employer knew, cedure ensures that worker input is received before employers are
or with reasonable diligence could have known, of the haz- informed of violations and proposed citations.
ardous condition. During the closing conference CSHOs will discuss the
apparent violations and other pertinent issues found during
OTHER-THAN-SERIOUS VIOLATIONS: Where the accident/inci- the inspection and note relevant comments, including input
dent or illness most likely to result from a hazardous con- for establishing correction dates. Everything discussed
dition would probably not cause death or serious physical during the closing conference will be documented in the case
harm but would have a direct and immediate relationship to file, including a note describing printed materials distributed
the safety and health of employees. and any unusual circumstances related to the conference.
CSHOs will discuss the strengths and weaknesses of
DE MINIMIS VIOLATIONS: Where the employer has implemented the employer’s occupational safety and health system and
a measure different from one specified in a standard that has any other applicable programs, and advise the employer of
no direct or immediate relationship to safety or health.

REPEAT VIOLATIONS: Where the employer has been cited Geise
previously in the last five years for the same or a sub-
stantially similar condition or hazard and the citation
has become a final order of the Occupational Safety and Engineering
Health Review Commission.
Sales and Engineering
GENERAL DUTY REQUIREMENTS: Where the employer failed to
keep the workplace free of a hazard to which employees were Magic
exposed, the hazard was recognized, the hazard was causing Carpet®
or likely to cause death or serious physical harm, and there
was a feasible and useful method to correct the hazard.

WILLFUL VIOLATIONS: Where the employer has demonstrated
either an intentional disregard, plain indifference, or crim-
inal disregard for the requirements of the Act. For details
on the guidelines and procedures that apply to Willful
Violations, visit www.osha.com.
Handle Tow Lifts
COMBINING & GROUPING VIOLATIONS/MULTI-EMPLOYER
VIOLATIONS: In some instances of multiple or interrelated
violations, the CSHO may decide to combine or group the www.geise-engineering.com
violations. Also, on multi-employer worksites, more than one
employer may be cited for a hazardous condition. Types of 570-490-2818
grouping violations are also described on the OSHA website.

WINTER 2017 | NSAA JOURNAL | 19