unnecessary to effectuate the congressional policy underpinning the substantive provisions of the statute. Jeter at 977.

e. Appeals Process

An employer who wishes to contest a citation must submit a written objection to OSHA within fifteen working days of receiving the citation. 29 U.S.C. 659(a). The objection will then be forwarded to OSHRC for disposition. Failure to object to a citation within fifteen days will result in the citation and proposed penalty becoming a final order of the OSHRC without further appeal. An orally expressed disagreement will not suffice. The written notification is called a Notice of Contest. The Notice of Contest must clearly identify the basis of the employers objection to the citation and/or proposed penalty.

If an appeal of the citation is filed within fifteen days of receiving the citation, the OSHRC will afford the opportunity for a hearing. 29 U.S.C. 659(c). The employer may also appeal the rulings to the appropriate United States Court of Appeals. In the states with OSHA approved plans, the appeal process is generally similar to Federal OSHA, but a state review board or equivalent authority may hear the case.

f. Settlement

It is the policy of OSHA to encourage settlement at any stage of the proceedings. 29 C.F.R. 2200.100(a). The area director is authorized to enter into a settlement agreement that revises citations and penalties to avoid prolonged legal disputes and results in speedier hazard abatement. See, OSHA Publication 2098, 2002 (Revised).