LF Martin LLC

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Attacking OSHA’s Sampling Methodology

When the Industrial Hygiene Data Does Not Support the Citation

In an overexposure case, the citation is only as strong as the measurement beneath it. Every exposure-based citation OSHA issues — silica, lead, benzene, asbestos, noise — rests on a chain of technical steps that the Secretary must prove and that a qualified industrial hygiene expert can independently audit. When any link fails, the citation fails with it. This paper maps the vulnerabilities and the documented cases where they decided the outcome.

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LF Martin LLC / lfmartinphd@gmail.com / 401.663.7058
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