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One Inspector, Two Hats: OSHS/EPA Memorandum of Understanding


Be aware; the next time Occupational Health and Safety Administration (OSH) or Environmental Protection Agency (EPA) officials visit your facility or job site, they might be inspecting more than you think. Under a 1991 memorandum of understanding (MOU) between OSHA and EPA, officials from both agencies are directed to identify and report all potential OSHA and EPA violations.  Althought this MOU has been in place for more than twenty years, shrinking agency budgets have encouraged both agencies to make full use of this agreement.  More recently, OSHA inspectors observed potential EPA violations, and brought them to the attention of EPA officials, leading to a grand jury indictment of a New Hampshire company.  The indictment alleged the company unlawfully stored lead and cadmium at their foundry, exposing the company and its officers to up to $750,000 in fines.  This year, Region 1 OSHA and EPA officials signed an MOU reinforcing their commitment to interagency coordination.  With these two agreements in place, officials from both agencies are directed to observe and report all potential violations, not just those under laws for which each agency is directly responsible.

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