29 C.F.R. § 1903.17

Employer and employee contests before the Review Commission

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(a) Any employer to whom a citation or notice of proposed penalty has been issued may, under section 10(a) of the Act, notify the Area Director in writing that he intends to contest such citation or proposed penalty before the Review Commission. Such notice of intention to contest shall be postmarked within 15 working days of the receipt by the employer of the notice of proposed penalty. Every notice of intention to contest shall specify whether it is directed to the citation or to the proposed penalty, or both. The Area Director shall immediately transmit such notice to the Review Commission in accordance with the rules of procedure prescribed by the Commission.

(b) Any employee or representative of employees of an employer to whom a citation has been issued may, under section 10(c) of the Act, file a written notice with the Area Director alleging that the period of time fixed in the citation for the abatement of the violation is unreasonable. Such notice shall be postmarked within 15 working days of the receipt by the employer of the notice of proposed penalty or notice that no penalty is being proposed. The Area Director shall immediately transmit such notice to the Review Commission in accordance with the rules of procedure prescribed by the Commission.

Notes of Decisions
Cited in 11 cases (1 in the last 5 years), 1973–2022 · leading case: Sec'y of Labor v. Barretto Granite Corp., 830 F.2d 396 (1st Cir. 1987).
Sec'y of Labor v. Barretto Granite Corp., 830 F.2d 396 (1st Cir. 1987). · cites it 7× “” One of these regulations is 29 C.F.R. § 1903.17 (a), which requires that contestation of a citation or penalty be made in writing to the OSHA area director within 15 working days of the employer’s receipt of the notice of proposed penalty.”
D.R.T.G. Builders v. OSHC, 26 F.4th 306 (5th Cir. 2022). “20-61190 alternative modes of delivery, such as UPS, may be used where certified mail has been used first and failed.”
Raymond J. Donovan (Successor to Ray Marshall) Sec'y of Labor v. Anheuser-Busch, Inc., & Occupational Saf. & Health Review Comm'n, 666 F.2d 315 (8th Cir. 1982). · cites it 3× “§ 659 (a); 29 C.F.R. § 1903.17 (a). If the citation or proposed penalty, or both, are not timely contested by the employer, each becomes the final order of the Commission and is not subject to judicial review.”
Modern Drop Forge Co. v. Sec'y of Labor, 683 F.2d 1105 (7th Cir. 1982). “Under 29 C.F.R. § 1903.17 , the cited employer was informed that “[e]very notice of intention to contest shall specify whether it is directed to the citation or to the proposed penalty or both.”
Peter J. Brennan, Sec'y of Labor v. Occupational Saf. & Health Review Comm'n & Bill Echols Trucking Co., 487 F.2d 230 (5th Cir. 1973). · cites it 2× “Under 29 C.F.R. § 1903.17 , Echols could have obtained Commission review by notifying the Occupational Safety and Health Administration Area Director of its intention to contest within 15 days of its receipt of the notification of proposed penalty.”
Dan J. Sheehan Co. v. Occupational Saf. & Health Review Comm'n, & John T. Dunlop,Sec'y of Labor, 520 F.2d 1036 (5th Cir. 1975). “Under 29 C.F.R. § 1903.17 , the employer is instructed that “[ejvery notice of intention to contest shall specify whether it is directed to the citation or to the proposed penalty, or both.”
Lynn Martin, Sec'y of Labor v. Pav-Saver Mfg. Co. & Occupational Saf. & Health Review Comm'n, 933 F.2d 528 (7th Cir. 1991). “29 C.F.R. § 1903.17 (a). The Secretary also has promulgated regulations allowing an employer who has been cited for violations of the standards to have an informal conference with the Occupational Safety and Health Administration (OSHA) area director to discuss the citation, the…”
Penn-Dixie Steel Corp. v. Occupational Saf. & Health Review Comm'n, 553 F.2d 1078 (7th Cir. 1977). “Under the circumstances of this case, were we to view his testimony as “conclusive” on the issue of Penn-Dixie’s intent, we would be compelled to assume that this uncounseled layman understood the subtle, formalized distinctions expressed in 29 CFR § 1903.17 . Such an assumption…”
Marshall v. Haugan, 586 F.2d 1263 (8th Cir. 1978). “” 29 C.F.R. § 1903.17 (a) (1977). If the employer fails to notify the Secretary of its intention to con *1265 test the citation or proposed penalty within the allotted time period, “the citation and the assessment, as proposed, shall be deemed a final order of the Commission and…”
United States v. B & L SUPPLY CO., 486 F. Supp. 26 (N.D. Tex. 1980). “29 C.F.R. § 1903.17 (a). It is clear that B & L’s May 25 letter does not comply with the letter of the statute, since it was dated (and presumably postmarked) more than fifteen working days from B & L’s receipt of notice from the Secretary.”
Atl. Adjustment Co. v. U.S. Dept. of Labor, 90 F. Supp. 2d 627 (E.D. Pa. 2000). “” 29 C.F.R. § 1903.17 (a). The regulations also state that review shall not be taken by any court or agency unless filed "within 15 working days from the date of receipt of such notice.”
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