Following the fatality of a contractor, OSHA launched an investigation. Immediately following the fatality, and contemporaneously with OSHA’s investigation, our client implemented an overall safety compliance audit and implemented best practices well in advance of receiving the OSHA citations. Our designed strategy was to proactively address safety improvements, whether possibly related to the accident or not, in an effort to demonstrate an overall safety commitment to OSHA. This strategy was effective. The cited items and fines were well-below the expected range for the length of the inspection at issue and the underlying fatality. Significantly, the citation contained no allegation that the Company’s purported failure to comply with the cited regulations caused or contributed to the contractor’s death. This resulted in a favorable settlement for our client.