Many of the OSHA cases that cite “willful” violations present mysteries. The mysteries are why the alleged violations were categorized as willful. These charges are not a mystery to OSHA, but they are mysteries to readers of citations. Since the penalty for a willful violation can be over $130,000, there should not be any mystery about such charges.
Some OSHA citations and notice of penalty present clear reasons for the charge of willful violations. Some citations give only a hint of OSHA’s thinking. They leave the reader to infer OSHA’s reasoning.