from a reader comment…if you are in porn you NEED to pay attention to this Thanks Lurking reader
the September complaint spells it out with the added field..EMPHASIS: S: Targeted Compl & Consult
The S is an internal OSHA code for compliance officers to look for any and all violations by a willful violator. With penalties up to 70k for each willful violation any company earning this S designation is a nightmare. Complaints move to the top of the list and trying to sidestep the offered consult services by OSHA to mitigate fines becomes nearly impossible.
Part of OSHA is free consult services where they don’t fine for violations found in the consult process to develop adequate appropriate safety protocols for business. Utilizing the consult part of targeted compliance is how even a workplace death can result in low or no fines…because the risk is not an ongoing concern.
Now that there is a ten year history of OSHA trying to work with the industry with five years of direct industry involvement via advisory committees Kinks options for fine mitigation are minimal. OSHA offering consult services is a double edged sword…kink could avoid fines for violations found in the process IG the remodeling extension cords would easily go away with correction…barrier protection violations during the consult will get a free pass but guarantee escalating willful violation penalties. With a 50k penalty already imposed they can expect to get the 70k max for subsequent violations after the consult period…if they refuse the consult services…essentially automatic max penalties. This is OSHA saying…times up folks
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OSHA To Knk Times Up Folks http://t.co/77er3I8GRN
Does anyone know the exact rules pertaining to enforcement dates? Meaning who’s at risk for fines? Does the 6 month rule apply here as in they can go back 6 months to enforce regulations?
What about scenes that were shot in the last 6 months that violate regulations? Can they be released without penalty?
I have a feeling the answer would be “no,” but thought maybe one of you would know for sure? If they have made it perfectly clear that they are capable of enforcing regulation through just scene release only then when would it start? Or, did it already start? Or, would they start at 6 months ago and go forward?