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Archive for '1BY'

Cal/OSHA’s Abuse of the 1BY Process Continues

Employer advocate Fred Walter shares an e-mail from a duped safety manager to Cal/OSHA after he accepted an invitation to respond in writing about his employer’s safety program.

1BY Letters: The Death of Dialogue

Readers of this blog know that we disapprove of Cal/OSHA’s mis-use of Citation Notice letters, known by their form number as 1BY letters. Our advice to California employers in the past has been to be very careful how they respond, if they respond at all. Our latest advice is more simple: Do not respond at all. Here’s why: […]

1BY – An Enforcement Tool, Not A Good Faith Invitation to Dialog

Employer advocate Fred Walter discusses Cal/OSHA’s latest innovative use of the 1BY letter

Alternatives to Cal/OSHA’s 1BY

We have blogged twice now about our concerns that Cal/OSHA’s new 1BY form is a trap for the unwary, designed more as an enforcement tool than a true invitation to “dialogue” with employers before serious citations are issued. But to recap, why are we concerned about the 1BY form? First, the employer’s response portion of […]

1BY: A Set-Up for Failure… But Whose?

“If our only goal is to gather ‘employer admissions against interest’, rather than to thoughtfully consider an employer’s response, this all will fail. That will be regrettable.” — Anonymous CSHO Indeed it would. But that seems to be where we are headed. Achieving Cal/OSHA Chief Len Welsh’s grand vision of fewer, more defensible, “serious” citations […]

To 1BY, Or Not To 1BY

I just got off the phone with Employer Smith. I have never talked to him before; he had seen our website and just called with a “quick question.” I should have told him that there are few quick answers in the law. “I have this form that Cal/OSHA is saying I have to fill out,” […]