Vial v. California Occupational Safety & Health Appeals Board

75 Cal. App. 3d 997, 142 Cal. Rptr. 549, 1977 Cal. App. LEXIS 2076
CourtCalifornia Court of Appeal
DecidedDecember 16, 1977
DocketCiv. No. 16367
StatusPublished
Cited by1 cases

This text of 75 Cal. App. 3d 997 (Vial v. California Occupational Safety & Health Appeals Board) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vial v. California Occupational Safety & Health Appeals Board, 75 Cal. App. 3d 997, 142 Cal. Rptr. 549, 1977 Cal. App. LEXIS 2076 (Cal. Ct. App. 1977).

Opinion

Opinion

PARAS, J.

The Director of the California Department of Industrial Relations (hereinafter Director) and the Division of Industrial Safety (hereinafter Division) appeal from an order of the superior court denying their petition for writ of mandate. The question is whether a citation issued by the Division more than two months after one of its representatives inspected the site of a fatal, work-related accident, was [999]*999issued with “reasonable promptness,” within the contemplation of section 63171 of the California Labor Code.2

Section 6317 was enacted as part of the California Occupational Safety and Health Act of 19733 (hereinafter Cal/OSHA), a statutory scheme avowedly created “for the purpose of assuring safe and healthful working conditions for all California working men and women. . . .”4 It came in response to earlier federal legislation5 (hereinafter Fed/OSHA) covering the same subject matter but suggesting that states adopt “state occupational safety and health plans”6 and thereby assume primary [1000]*1000jurisdiction within their borders over safety and health matters at the workplace.7

The pertinent facts, as set forth in the findings of the trial court, are as follows. On January 17, 1975, a representative of the Division’s field office in Eureka inspected a place of employment maintained in Scotia, Humboldt County, California by Pacific Lumber Company (hereinafter Company)., The inspection was occasioned by a fatal accident suffered by a Company employee the previous day. Subsequent to the inspection, the representative requested a report from the county coroner in Eureka; the report arrived in the Division’s Eureka office approximately 13 days later. In the meantime, the Eureka office, manned by two safety engineers only, had to service four employee complaints which by Division policy were entitled to priority.8

On February 20, 1975, the preliminaiy paperwork relative to the investigation was forwarded from Eureka to the Division’s Santa Rosa office for review by the Division’s district manager. Division policy required such review, and approval of all preliminary reports and drafts, before issuance of a citation. The district manager contacted the Division’s legal department to clarify the applicability of construction or general industrial safety orders to the Company’s premises, and made a personal visit to the Eureka coroner’s office. A citation ultimately issued on March 18, 1975, charging Company with a “serious violation”9 of [1001]*1001California Administrative Code, title 8 section 1669, subdivision (a),10 and proposing a penalty of $600.

Company appealed to the defendant Occupational Safety and Health Appeals Board (hereinafter Board), contesting both the alleged violation and the reasonableness of the proposed penalty. Although Company did not claim or present evidence of prejudice from the two-month delay, the administrative law judge sua sponte raised the issue of “reasonable promptness” in the issuance of the citation. Deciding that question adversely to the plaintiffs, the judge vacated the citation and the proposed penalty, a decision which the Board affirmed in its decision after reconsideration.

Plaintiffs thereafter sought by this petition to have the superior court compel the Board to set aside its decision and adjudicate the case on its merits. After a hearing upon the return to the alternative writ, the court made certain findings of fact and conclusions of law and entered judgment denying the petition. This appeal ensued.

A. Scope Of Review

The manner in which plaintiffs’ opening brief frames the issue before us appears to invite a review of the factual determinations made by the administrative law judge and affirmed by the Board. If this were a case calling for such a review of findings, the pertinent inquiry by this court could be of no greater scope than to determine the existence vel non of substantial evidence to support the Board’s decision.11

[1002]*1002The trial judge, however, treated the matter as one raising a question of law (calling for statutory construction). We conclude that he did so correctly, for there is no dispute regarding the basic facts, only regarding the legal significance of those facts. (A. H. Robins Co. v. Department of Health (1976) 59 Cal.App.3d 903, 907 [130 Cal.Rptr. 901].)

B. Reasonable Promptness

We are called upon to determine whether the Board acted properly when it found that a citation issued by the Division 60 days after inspection of the accident site was not issued with “reasonable promptness.” It therefore becomes necessaiy to examine section 6317 in light of the statutoiy scheme of which it is a part, in order to ascertain construction to be given that phrase.12

C. Interpretations Advanced

The legislative command of section 6317 is: “If, upon inspection or investigation, the division believes that an employer has violated any standard, rule, order, or regulation ... it shall with reasonable promptness issue a citation to the employer.

“No citation or notice shall be issued by the division for a given violation or violations after six months have elapsed since occurrence of the violation.” (Italics added.)

The Board advances the following interpretation. The purpose of Cal/OSHA is to foster safe working conditions (§ 6300), a goal which can best be attained by preventing hazardous conditions from existing or, if they are already in existence, by requiring their prompt abatement. To [1003]*1003achieve this goal the Division is given a vast panoply of powers ranging from the power to issue nonpenalizing warning notices for “de minimis” safety violations (§ 6317), to the ultimate power to terminate an employer’s entire operation in cases of imminent hazard to employee safety (§ 6324 et seq.). An offending employer is not required to take any corrective action until the Division has issued a citation. (§ 6317.) The “reasonable promptness” requirement therefore can have but one rational purpose, which is to require the Division to proceed with dispatch when it learns of a workplace hazard so that the employer will take corrective measures promptly; this will reduce employee exposure to workplace hazards and ultimately decrease the number of work-related injuries. When the hazard is a serious one as in the instant case, the Board’s argument continues, it is particularly important that prompt corrective measures be taken, for the possible harm to employees is that much greater.13 Since the Division is required to proceed with dispatch, it must properly bear the burden of justifying any noteworthy delay between its discovery of a workplace hazard and its issuance of a citation.

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Cite This Page — Counsel Stack

Bluebook (online)
75 Cal. App. 3d 997, 142 Cal. Rptr. 549, 1977 Cal. App. LEXIS 2076, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vial-v-california-occupational-safety-health-appeals-board-calctapp-1977.