The Secretary of Labor prevailed on petition for review. The Sixth Circuit reversed the OSHRC's decision vacating three citations for unguarded scaffolds, holding that § 10(b) of the OSH Act does not bar citations for violations at separate worksites occurring at different times, even if an earlier citation for the same condition is pending.
What This Ruling Means
**Court Rules OSHA Can Issue Multiple Safety Citations to Same Company**
This case involved Manganas Painting Company, which received multiple citations from the Occupational Safety and Health Administration (OSHA) for having unguarded scaffolds at different work locations. The company argued that OSHA couldn't issue new citations while an earlier citation for the same type of safety violation was still pending in the system.
The court disagreed with the company and sided with the Department of Labor. The Sixth Circuit Court of Appeals ruled that OSHA can issue separate citations for the same type of safety violation when those violations occur at different worksites and at different times, even if an earlier citation is still being processed.
This decision is important for workers because it strengthens workplace safety enforcement. It means employers cannot use bureaucratic delays to avoid accountability for repeated safety violations. If a company continues to expose workers to the same hazards at multiple locations—like dangerous unguarded scaffolds—OSHA can cite them for each violation rather than waiting for previous cases to be resolved. This helps ensure that employers take immediate action to fix safety problems and protect workers from preventable injuries.
This summary was generated to explain the ruling in plain English and is not legal advice.
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