July 13, 1999
Mr. Patrick J. Cleary
Vice President
National Association of Manufacturers
1331 Pennsylvania Avenue, NW
Washington, DC 20004-1790
Dear Mr. Cleary:
Thank you for your November 18, 1998 letter seeking clarification of the Occupational Safety Health Administration's (OSHA's) definition of "repeated" violations. Your letter referred to the decision by the United States Court of Appeals for the Seventh Circuit in Caterpillar, Inc. v. Secretary of Labor. We apologize for the delay in our response.