1.   Scope of Inspection

     a.   Date inspection initiated; 
     b.   Statute of limitations date for citation issuance;
     c.   Type of inspection (e.g., unprogrammed or programmed,
          safety or health);
     d.   Nature of employer's business, corporate-wide and at
          the inspected worksite;
     e.   Total number of employees overall and at the inspected
          worksite; and
     f.   Names of labor unions representing employees.

2.   Inspection History

     a.   Numbers and dates of previous inspections; and
     b.   Previous violation history at this establishment and in
          the corporation nationwide.

               NOTE: National citation history can be obtained by
               requesting the information from the Regional IMIS

3.   Inspection Methodology

     a.   Were warrants, medical access orders or administrative
          subpoenas necessary?  Why?  Were they obtained and
     b.   What written records or other documents were examined
          or obtained?
     c.   What are the names of compliance personnel who
          conducted the inspection?
     d.   Were experts or other consultants used in the
          inspection?  If so what are their names and
     e.   Have depositions been taken?  Are any planned?  Who
          will be deposed?

4.   Inspection Findings

     a.   Summary of Violations

          (1)  Number and Classification
          (2)  Types of Title 8 Safety Orders Violated

    b.   Proposed Citations

          (1)  How is the violation-by-violation penalty to be
          (2)  How many violations are there?
          (3)  Are there additional violations not subject to the
               violation-by-violation penalty?

5.   Documentation Relating to Additional Penalty Factors

     a.   Determination of Willfulness:

          (1)  What were the firm's guidelines or policies
               relating to safety and health in general and, in
               particular, to the subject violation, e.g., hazard
               communication, machine guarding, use of
               respirators, maintenance of pressure vessels? 
               What was the local facility's safety and health

          (2)  Do corporate or plant policies or guidelines
               differ from Cal/OSHA requirements, or other
               relevant standards, regulations or guidelines? 
               What is management's explanation for differences
               between its policies and Cal/OSHA's requirements?

          (3)  Did responsible persons actually know of the
               requirements of the relevant Cal/OSHA standards,
               guidelines or instructions?  Who were they and how
               did such persons come to know Cal/OSHA's

          (4)  Did responsible persons actually know of the
               existing hazardous conditions?  Did they recognize
               the hazardous nature of these conditions?  If so,
               who were these persons and for how long had they
               recognized the hazard?

          (5)  How did the employer explain the existence of the
               violations?  Did the employer claim that any steps
               to abate had already been taken?  Was any
               documentation available to support such previous

          (6)  Had the company done anything toward identifying,
               evaluating or correcting the hazardous conditions
               prior to the Division's visit?  Was an abatement
               program in place or had one been proposed?  What
               progress had been made toward implementing it? 
               Does it seem adequate?  What was the company's
               explanation as to why more progress had not been

          (7)  Are any memoranda, letters, minutes, accident
               reports or other documents addressing the hazards,
               violations or corrective measures available? 
               Describe them.  Did management admit knowledge of
               these documents?  Had management responded in any
               to them?  How?

     b.   Penalty Factors

          (1)  How many violations of each standard are involved
               and how extensive (pervasive) is the problem? 
               What is the nature of the violation?  (How many
               machines?  How many different engineering
               controls?  How many employees exposed?)

          (2)  What kind of safety and health program exists in
               the plant?  What is management's attitude toward
               safety and health?  What do management officials
               actually say?

          (3)  What training was given to employees and
               supervisors regarding compliance with the standard
               or regulation, or abatement of the hazard?  If
               none is given, what did management admit or what
               explanation did they offer?

          (4)  Did the company enforce its own policies and

          (5)  What were the most serious reasonably predictable
               injuries or illnesses that could result from
               exposure to the hazard?  Would these potential
               injuries or illnesses be classified as serious? 
               Did management admit recognition of the potential
               for these injuries and illnesses?

          (6)  What was the company's record (especially relating
               to workers' compensation claims) for injuries
               and/or illnesses associated with alleged
               violations?  What kind and how many such injuries
               or illnesses?

          NOTE: All of the above questions are to be directly
          asked of management personnel and their responses
          carefully recorded in writing or electronically.  A
          second compliance person or other reliable witness
          shall be present if at all possible.  Documentary
          evidence shall be sought throughout the investigation,
          using administrative subpoenas as appropriate.

                 C-10A, Attachment (08/01/94)