- Dr. Douglas Burrin, Baylor University
- Dr. James Drackley, University of Illinois
- Dr. Richard Hartel, University of Wisconsin
- Dr. Al Kertz, Andhil LLC
- Dr. Adam Lock, University of Vermont
- Dr. Jack Odle, North Carolina State University
- Dr. Mike Van Amburgh, Cornell University
- Dr. Wang Jiaqi, Institute of Animal Science, Chinese Academy of Agricultural Sciences
Manufacturing facilities with multi-sites should be aware that if a facility currently receiving a citation and has received an OSHA citation at another site within three years for the same violation will be considered as a repeat citation. Here is an excerpt from Andy Purvin a member of the Online Safety Community that describes the situation
I ran into this a lot at my previous employer. OSHA says since the company has a large enough communications network, relaying information between plants wouldn't be a hardship. Therefore, since they could have "learned" from the previous inspection citations, it technically IS repeat violations.
I argued similar points to yours, but lost. Companies that have multi-site designation are going to be held accountable to update all plants on Regulatory Activity. To combat this, at my current company, when OSHA "visited" one of our locations, I communicated the results to all and confirmed corrective actions had taken place at EVERY location to avoid repeat violations.
Here is additional helpful info that Bryan Haywood CEO & President, SAFTENG.net LLC shares with his comment on "repeat violations" at the LinkedIn Combustible Dust Policy Institute Group discussion:
"Although I can not speak to the question of "new ownership" I can state that a repeat citation can be issued to the facility if a different plant within the company that falls within Federal OSHA and NOT a state plan, has been cited for the same violation. The cited repeat violation does NOT have to have occurred at the same facility...just a facility within the company that falls under Federal OSHA, as I think was this case. You mentioned a MN facility and MN is a state plan, which means citations at the MN facility can NOT be used to issue repeats at a plant under Federal OSHA.