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January 29 1990
MEMORANDUM FOR: REGIONAL ADMINISTRATORS
THROUGH: LEO CAREY
OFFICE OF FIELD PROGRAMS
FROM: THOMAS J. SHEPICH, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Handling of Large-penalty Cases
In the past several months, "non-egregious" cases have been developed in
which proposed penalties totaled more than $100,000. Citations were issued,
appropriately, without the type of National Office screening required where
violation-by-violation penalties are involved.
These cases demonstrate the potential for eventual decentralization of all
major cases, as we discussed at Salt Lake City; they also indicate a
continuing need for notification of the National Office when large penalties
are being issued. Particularly, it is essential that the Secretary and her
spokespersons be informed of such cases, since they are likely to generate
national publicity.
We will continue to screen egregious cases in the National Office. You
should continue to coordinate those cases through the Directorate of
Compliance Programs. In non-egregious, large-penalty cases, however, you
should notify the Office of Field Programs at least 2 weeks before citations
are issued, so that appropriate notifications can be made.
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