Introduction
Each year, OSHA (including Cal/OSHA and other state plans) issue close to 100,000 citations to employers for health and safety violations. For many organizations, receiving a citation can be stressful, confusing, and potentially damaging.  Beyond the actual penalties associated with citations, having violations on record can reduce your ability to do business with others in the future and harm your organization’s brand. At Citadel EHS, we help employers understand what citations really mean, how to respond and appeal effectively, and how to strengthen your organization’s health and safety programs in the process.

Why Some Citations May Not Hold Up
We often see citations that don’t fully line up with the facts or with the intent of the regulations. For example:

• The cited standard doesn’t actually apply to the situation (e.g., confusing lockout/tagout with machine guarding).
• The inspector overlooked important safety practices already in place.
• The citation is based solely on the fact that an accident occurred and failed to determine whether the accident was caused by an employee who was acting independently and against company policy.

You May Have Defenses
Many employers don’t realize that they may have valid affirmative defenses, such as:

• Employee misconduct: If the company had strong policies, training, and supervision in place, but an employee acted outside of those safeguards.
• Feasibility issues: Sometimes the regulation is not technically or economically feasible, and the employer has implemented an effective alternative.
• Timing: OSHA citations must be issued within a set period of time (typically 6 months).

Understanding these defenses can make the difference between accepting a costly citation or reducing its classification or even vacating it.

Why the 15-Day Deadline Matters
From the day you receive a citation, the clock starts ticking. In most states, you have 15 working days to file an appeal. If you do nothing, the citation becomes final, even if it wasn’t justified. Acting quickly ensures you preserve your right to appeal.

The True Cost of “Just Paying the Fine”
Some employers decide not to contest citations, especially if the dollar amount looks small. But this can be shortsighted. Accepting a citation can:

• Create a “forever” public record that potential clients, partners, and regulators can see.
• Cause you to lose business if your customers or clients vet safety performance.
• Increase the chance of “Repeat” or “Willful” violations in the future, which carry much higher penalties.
• Damage business reputation through OSHA press releases, media coverage, or third-party tracking services that flag companies with safety violations.

In short, even “small” citations can have long-term consequences.

How Citadel EHS Helps
As consultants and experts in health and safety, we can help you achieve the best possible outcome. We help clients:

• Review the citation and OSHA case file to understand your situation.
• Develop an appeal strategy, including possible defenses.
• Represent you during interactions with OSHA and the Administrative Law Judge.  In some cases, we may advise that you retain an attorney, but not always.
• Work toward resolution, whether that means vacating, downgrading, or consolidating citations.
• Improve your safety program so similar issues don’t arise in the future.

Protecting Your Business and Your Reputation
OSHA citations don’t just affect penalties. They can influence client trust, contractor relationships, insurance rates, and even the ability to bid on projects. That’s why it’s critical to carefully evaluate your options.

At Citadel, our mission is to help you navigate citations with confidence, while strengthening the safety programs.

If your organization is facing an OSHA citation, don’t go it alone, and don’t miss your opportunity to file an appeal and contest the citation. We’re here to help you understand your options and achieve the best possible outcome.

To reach a Citadel consultant, visit https://citadelehs.com/contact-us/.