Employers in the EEP are subject to follow-up inspections, inspections of other company sites, notification of OSHA enforcement to the corporation, enhanced settlement provisions, and federal court enforcement under Section 11 (b) of the Occupational Safety and Health Act. According to an OSHA official, over the past four years, the agency has logged 2,129 EEP cases, averaging 524 cases each year. OSHA has found that 67 percent of the EEP employers had 100 or fewer employees.

According to the directive, a large percentage of inspections have involved employers with 25 or fewer employees.These small employers have had only one serious violation related to a fatality and no significant OSHA history within the previous three years, according to the directive.

An employer's history of OSHA violations will be based on the employer's nationwide inspection history, including violations in state plan states, as well as those under federal OSHA jurisdiction.The prior history must be based on a final order, not simply citations that were issued. Past violations include those that are "similar in kind" to the current violation. For example, if there are violations of OSHA's fall protection standards, a prior fall from a scaffold is considered similar in kind to a current fall through a floor opening or from a roof, the directive said.

OSHA has expanded the criteria for enhanced enforcement cases to include:

• a fatality inspection in which OSHA finds one or more willful or repeated violations related to the death;
• a fatality inspection in which OSHA finds one or more serious violations related to the death and the employer has either an OSHA history of violations similar in kind to the violation that led to the current fatality consisting of at least one serious, willful, or repeat violation within the last three years, or the occurrence of another fatality within the last three years regardless of whether any citation was issued;
• an inspection that results in the citation of three or more serious violations that are also classified as willful or repeat and the employer has an OSHA history of violations similar in kind to one or more of the violations found in the current inspection consisting of at least one serious, willful, or repeat violation within the last three years;
• an inspection that results in one or more failure-to-abate notices where the underlying violations were classified as serious;
• any egregious case or a significant case consisting of one or more inspections in which the proposed penalties total more than $100,000;
• grouped and combined violations that are counted as one violation;
• an unclassified violation, depending upon what the citation classification was, or would have been, if the unclassified designation was not used.

For more information regarding OSHA's revised Enhanced Enforcement Program, contact Stephanie Salmon, AFS Washington office, at ssalmon@afsinc.org, or Fred Kohloff, AFS director environmental, health and safety, at fhk@afsinc.org,

Casting Cost Estimating Course Available
The Cast Metals Institute (CMI) will be offering a Casting Cost Estimating course Feb. 19-20 at AFS Headquarters, Schaumburg, Ill. This course uses a workshop approach to take students through the basics of predicting job costs using example jobs, as well as prints students bring to class. Estimates based on blueprints will be presented and discussed. Methods for determining cost centers also will be discussed, along with ideas for assigning standard costs. Students will review sample estimates using a form created during the lectures.