1. OSHA Inspections – Mr. Peterson participated in opening conferences, accompanied OSHA Compliance Officers during compliance inspections, and participated in closing conferences relative to 69 OSHA inspections conducted over a 40-year period. During the last 10 years of Mr. Peterson’s management of OSHA matters, OSHA inspected 16 of the projects of Mr. Peterson’s company, yet OSHA found only one violation in total; this single violation was classified as an “Other” violation (not “Serious”) with no monetary penalty.
2. OSHA Citations Contested – Mr. Peterson has contested citations, attended informal conferences, negotiated with Solicitors, and attended trials before Administrative Law Judges.
3. Pro Se Representation – Mr. Peterson represented his company (pro se) before Administrative Law Judges in four OSHA cases.
4. Testimony – Mr. Peterson testified at two OSHA negotiated rulemaking fact-finding hearings:
- Steel Erection Negotiated Rulemaking Advisory Committee (SENRAC), and
- Crane and Derrick Advisory Committee (CDAC)
- Safety and Health Partnership for Excellence (SHAPE) partnership with the U.S. Department of Labor (OSHA) – Mr. Peterson served for 15 years on the AGC Houston Task Force Committee that negotiated and maintained the partnership agreement.
- OSHA / AGC SHAPE Associate partnership agreement – On December 16, 2003, Mr. Peterson executed with OSHA the first such agreement in the country for a specialty contractor. Subsequently, he maintained the partnership from 2003 through 2012.
6. OSHA Regulations – Mr. Peterson’s knowledge of OSHA regulations is a result of:
a. Interaction with OSHA regarding the above matters
b. Receipt of training from third parties, and
c. Self-study of the following written materials:
- OSHA regulations
- OSHA guidelines
- OSHA directives
- OSHA letters of interpretation
- OSHA-provided safety training materials and booklets
- Articles related to OSHA found in peer-reviewed safety journals
© Copyright 2003-2018 Homer R. Peterson II