I’ll Be Back: Oregon OSHA’s “For-Cause” Inspection Program May Result in an Unlawful Return Visit
Seyfarth Synopsis: Oregon OSHA institutes program for comprehensive follow-up inspections based on an employer’s violation history, which necessitates employer care during inspections and negotiation of settlements. Oregon Governor Tina Kotek signed Senate Bill 592 into law in 2023, requiring Oregon OSHA to increase penalties and implement a program for follow-up inspections for significant citations. In response, Oregon OSHA implemented its “ Programmed Inspections for Cause ” enforcement program designed to prioritize comprehensive inspections against employers with histories of multiple high-classification (Repeat or Willful) citations or citations issued in response to a fatality. Comprehensive Follow-up Inspections A “comprehensive inspection” is a wall-to-wall examination of the worksite to assess compliance with occupational safety and health regulations. Unlike focused inspections, which target specific hazards or complaints, a comprehensive inspection re...