LF Martin LLC

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Mock Regulatory Audits

Finding the Citation Before the OSHA Compliance Officer Does

An OSHA inspection is a compliance audit conducted on the government’s schedule, scored in citations, and preserved in a public database that opposing counsel reads. A mock regulatory audit is the same examination conducted on the employer’s schedule, scored in findings, and closed out in corrective action. This paper describes what a credible mock audit covers in general industry and construction, assembles the enforcement data and penalty structure that make the economics unambiguous, and traces the regulatory and litigation doctrines under which a documented program of self-audit and prompt correction is among the strongest evidence of good faith an employer can create — and an uncorrected finding among the most damaging.

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