Employer self-audits and OSHA enforcement

October 22, 1991
Mr. D.E. Miller
President and Chief Operating Officer
The Gates Corporation
[Recipient address omitted]

Dear Mr. Miller:

Thank you for your letter of August 20 to Secretary of Labor Lynn Martin, regarding the role of self-audits in safety and health programs.

It is indeed encouraging that you have already incorporated safety and health audits into your program. We share your belief in their utility and efficacy as a tool for all levels of management. You raised a concern that the Occupational Safety and Health Administration (OSHA) may use your self-evaluations against the company in an enforcement action. I must tell you that, if a company fails to treat the significant findings of its audit appropriately and fails to correct serious conditions to which its employees are exposed, the company may very will be involved in an enforcement action. We encourage you, therefore, to continue to take the audit process seriously, and to defend against citations simply and directly, by eliminating whatever hazards you may find.

We appreciate your support and your concern for workplace safety and health. If we may be of assistance to you, please let us know.
Sincerely,
Gerard F. Scannell
Assistant Secretary
[Corrected 10/22/2004]