OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
October 16, 2003
| MEMORANDUM FOR: | REGIONAL ADMINISTRATORS |
| FROM: | RICHARD E. FAIRFAX, Director Directorate of Enforcement Programs |
| SUBJECT: | Enhanced Enforcement Program (EEP) IMIS Coding |
This memorandum amends Section H. of the Enhanced Enforcement Program memorandum signed by Assistant Secretary Henshaw on September 30, 2003 to add an additional IMIS coding instruction, see shaded information below. It should also be noted that the IMIS coding, N-08 SIGCASE, will remain valid for significant cases that are not EEP cases. Please advise your Area Directors.
H. Recording and Tracking of Inspections. This applies to follow-up inspections discussed in section A. above, SST inspections of establishments that were moved from the secondary list to the primary list, inspections of related establishments, and enhanced settlement agreements related to PECs.
All IMIS case file data for PECs conducted since March 12, 2003 opened October 1, 2003, or thereafter, should be modified to include the appropriate codes. Once a case has been identified as a PEC, complete the OSHA-1 by entering the code "EEP" in Item 42, Optional Information, for the inspection. EXAMPLE:
| Type | ID | Value |
| N | 08 | EEP |
If the case also receives an Enhanced Enforcement Settlement Agreement, modify the existing record to add the enhanced enforcement settlement agreement code using "ENHSA."
| N | 08 | EEP,ENHSA |
If the case is also determined to be a significant case, modify the existing record to add the significant case code using "SIGCASE" as shown below:
| N | 08 | EEP,SIGCASE |
Remember, if the inspection is a Non-Primary Insp in a Multiple Insp Significant Case the (S + Activity Number of Primary Inspection) code is to be used, as shown below:
| N | 08 | EEP,S######### |
If the case also receives an Enhanced Enforcement Settlement Agreement, modify the existing record to add the enhanced enforcement settlement agreement code using "ENHSA."
| N | 08 | EEP,SIGCASE,ENHSA |
| N | 08 | EEP,S#########,ENHSA |
In addition, enter all applicable SST, NEP, LEP program codes in Item(s) 25c and 25d when an inspection is conducted and the inspection also meets the protocol for other program(s). Also, enter all applicable Strategic Management Plan hazard/industry codes in Item 25f.