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In December 1999, OSHA issued a directive (CPL 2-0.124) to its offices nationwide clarifying the citation policy for multi-employer worksites. The directive applies to multi-employer worksites in all industry sectors and outlines the criteria OSHA compliance officers must use to cite more than one employer for a hazardous condition that violates a standard.

OSHA compliance officers apply the following two-step process to determine whether more than one employer is to be cited.

  1. The first step is to classify the employer as creating, exposing, correcting, or controlling. An employer may have multiple roles and fall under several categories. Note: Only exposing employers can be cited for General Duty Clause violations.
  2. The second step is to determine if the employer’s actions were sufficient to meet its obligations under OSHA standards. The extent of the actions required of employers varies based on which category applies.