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How will the Office of Enforcement conduct on-site audits? Will they perform strict compliance inspections, or programmatic reviews?

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How will the Office of Enforcement conduct on-site audits? Will they perform strict compliance inspections, or programmatic reviews?

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Response: Subpart E Enforcement Process, which includes 851.40, Investigations and Inspections, outlines the scope of the enforcement process. The Director has discretion in using the means outlined in this section to affect improvements in contractor safety and health. Prototype inspections conducted during the summer of 2006 provided insight for future enforcement activities. Since 851 encompasses both program and standard requirements, a violation of a standard may also involve violations of program requirements and vice versa. Therefore, an inspection may not be limited to compliance with standards. The Office of Enforcement plans to conduct investigations, inspections and program reviews, which require on-site enforcement activity. While little or no notice may be given prior to an inspection, inspections may be conducted separately, but will more likely be performed in conjunction with an investigation or program review. 10 CFR 851 Appendix A – Worker Safety and Health Functional

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