On December 10, 1999, OSHA issued a compliance (CPL) directive number CPL 2-0.124 to clarify the Agency's multi-employer citation policy(1). On multi-employer worksites, more than one employer may be citable for a hazardous condition that violates an OSHA standard. Employers may be the facility owner, contractor(s) and/or sub-contractor(s), construction managers, engineering firms, and others, depending upon their roles on the project. The policy gives clear and detailed guidance on when citations should and should not be issued to exposing, creating, correcting and controlling employers. This paper applies these guidelines to various scenarios applicable to typical industrial maintenance painting projects.

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