Not Adopted. This April 3, 2024 memorandum rescinds and replaces the memorandum dated January 26, 2023, on the same subject. This memorandum further clarifies the policy described in the earlier memorandum. Under this policy, Regional Administrators and/or Area Directors may refrain from grouping violations where the violations are separate and distinct, even if other OSHA policies or directives recommend grouping the violations. This enforcement discretion is an important tool to deter employers from disregarding their responsibilities to protect workers and comply with OSHA standards and regulations.
Despite the April 2024 date on this memo, it was released to OSHA’s field staff on July 25, 2024 and sent to state plans on August 2, 2024.
As was the case with the previous memo on this topic, the OSH Division will not adopt this memo and will continue to following the NC FOM as it relates to violation grouping guidance.
Archived Versions
| Title | File Name | Archived Date |
|---|---|---|
| Violation Grouping and Discretionary Ungrouping Memo April 3, 2024.pdf(archived) | Violation Grouping and Discretionary Ungrouping Memo April 3, 2024.pdf |