They will also identify all of the employers on site and their relationships to one another. They will follow the “pay trail” and thereby assign the identifications of “controlling (host) employer,” “exposed employer,” “creating employer,” and “correcting employer” in relation to the hazards that were found in the inspection. A thorough discussion of the inspection may include other OSHA officers who have corroborating evidence or had previously inspected some of the employers involved.
The size of the companies, site-specific extenuating circumstances and a history of “good faith” abatement efforts in the past are some of the additional criteria considered by the director to determine whether citations will be issued and the value of penalties to be addressed. Depending on these evaluations and the scope of the inspection, this process may take hours or days to complete.