REGULATORY PITFALLS in MANAGING MULTIPLE EMPLOYERS

摘要

You are a plant manager/engineer responsible for a PSM (Process Safety Management) covered chemical process. You open your mail and to your surprise find an OSHA citation. You are familiar with the cited incident and know that it involved a contract worker and did not involve any of your processes. You ask yourself, “How could this happen? We pre-qualified our contractors according to OSHA’s PSM regulation. Our company attorneys have included “Additional Insured” and “Indemnity” clauses into each contract. None of our employees were involved and we did not create the incident. Why are we getting a citation from OSHA? I thought we were covered!”