Occupational Safety and Health Review Commission (OSHRC): A Guide for New Government Contractors

Understanding OSHRC

What is OSHRC?

The Occupational Safety and Health Review Commission (OSHRC) is an independent federal agency that adjudicates disputes between employers and the Occupational Safety and Health Administration (OSHA) regarding workplace safety violations. OSHRC serves as a neutral party in cases where employers challenge OSHA citations, penalties, or corrective actions.

OSHRC does not create workplace safety regulations or conduct inspections—that responsibility falls under OSHA (a part of the Department of Labor). Instead, OSHRC reviews contested cases, holds hearings, and issues decisions on employer appeals related to workplace safety violations, employee protections, and compliance with OSHA standards.

Key Areas of Focus:

  • Administrative Court Proceedings: Serving as an independent tribunal to resolve disputes between OSHA and businesses.
  • Review of OSHA Citations and Penalties: Evaluating employer appeals against workplace safety violations.
  • Legal Analysis of Workplace Safety Standards: Interpreting OSHA regulations and determining employer liability.
  • Ensuring Due Process for Employers: Providing a fair and impartial hearing process.
  • Issuing Precedent-Setting Decisions: Establishing case law on workplace safety compliance.
  • Alternative Dispute Resolution (ADR): Encouraging mediation and settlements before formal litigation.

Mission and Goals

OSHRC’s mission is to ensure due process and fair adjudication of OSHA-related disputes while maintaining efficiency, transparency, and impartiality. Its primary goals include:

  • Providing a fair appeals process for employers challenging OSHA citations.
  • Ensuring compliance with OSHA safety regulations while considering legal interpretations.
  • Promoting alternative dispute resolution to reduce caseloads and litigation expenses.
  • Enhancing transparency and accessibility of legal proceedings for businesses and workers.

OSHRC Organization

OSHRC consists of three main divisions:

  1. The Commission: The three-member panel that reviews administrative law judges’ decisions and issues final rulings.
  2. Administrative Law Judges (ALJs): Handle initial case hearings, reviewing evidence and issuing decisions on OSHA disputes.
  3. Office of the General Counsel (OGC): Provides legal guidance on procedural and policy matters.

OSHRC has three offices:

  • Washington, D.C. (Headquarters) – Central office for case review and Commission decisions.
  • Atlanta Regional Office – Covers cases from southeastern U.S.
  • Denver Regional Office – Handles cases from western states.

Advancing Your Career as a Contractor with OSHRC

Helpful Tips for IT Professionals and Consultants:

  • Understand OSHRC’s Role in Workplace Safety Law: Contractors should focus on legal document management, case tracking, and compliance software solutions.
  • Stay Current with Government Procurement Guidelines: OSHRC follows Federal Acquisition Regulations (FAR), particularly FAR Part 8 (Simplified Acquisitions) and FAR Part 15 (Contracting by Negotiation).
  • Master OSHRC’s Legal and Case Management Systems: Learn about:
    • E-File System – Used for submitting legal documents electronically.
    • Case Management Systems (CMS) – Platforms for tracking case progress and court filings.
    • Legal Research Databases – Tools that support legal analysis and case precedent tracking.
  • Prioritize Cybersecurity and IT Compliance: Contractors handling OSHRC’s digital infrastructure must follow FISMA (Federal Information Security Modernization Act) and NIST 800-171 cybersecurity standards.
  • Effective Communication with Legal and Administrative Staff: Many contracts involve working with administrative law judges, attorneys, and case managers.
  • Agile and Process Automation in Legal Technology: Implementing AI-driven legal research tools, process automation, and cloud-based case management can improve OSHRC’s operational efficiency.
  • Continuous Learning and Professional Development: Stay informed on federal labor laws, administrative court technology, and digital transformation in legal settings.
  • Networking and Collaboration: Attend OSHRC contractor outreach events, labor law conferences, and technology briefings to explore new contracting opportunities.
  • Focus on Digital Access and Legal Transparency: Many OSHRC projects require user-friendly case filing systems, online public records access, and digital legal archives.
  • Document and Share Knowledge: Ensure thorough documentation of legal IT frameworks, cybersecurity policies, and compliance protocols.

Helpful Links for Contractors: