Category Archives: willful


When OSHA Assistant Secretary Michaels and Jordan Barab famously admitted that OSHA was utilizing large penalties accompanied by harsh press releases to “motivate” employers to comply, I had mixed feelings.  Fear is a great motivator.  Aggressive publication of legitimate noteworthy OSHA citations … Continue reading

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Combustible Dust Explosions and Compliance – Especially For Food Processors

  I have linked to an Interview by the good folks at, an excellent publication and provider, especially for food processors and related businesses.  We represented construction employers at the 2008 Port Wentworth Sugar Plant (Imperial Sugar) explosion and … Continue reading

Posted in civil and criminal exposure, combustible dust, consensus standards, emergency response, food processing, general duty 5(a) citations, manufacturing, OSHA, willful | Tagged , , , | Leave a comment

It Took 12 Years To Decide That’s Not Willful?!

  Let’s continue our discussion of employer “Willful” behavior.  OSHA can be inconsistent in its application of the classification, and it is often up to the employer to establish the distinction between “serious” and “willful” behavior during and after an OSHA … Continue reading

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Is that a Willful Violation?

  Employers are uncertain about the difference between a “Willful” classification and a “serious” classification of an OSHA citation.  I confess that I sometimes struggle to understand the basis for a particular Area Office or Judge’s decision.  First, a basic definition … Continue reading

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