Occupational Safety and Health Administration (OSHA) enforcement history has been more aggressive in the last two years than at any other time in the agency's history. This program will provide specific recommendations to in-house counsel in advising their companies on OSHA compliance. The number of "significant" (i.e., "really big penalty") OSHA citations has increased by 30 percent, and the average penalty for "serious violations" has more than doubled from the 2010 levels. Our panel will provide guidance on the critical elements of an effective safety and health compliance program, and how the application of these elements can reduce legal exposure and improve employee safety. The use of safety metrics, incentive programs, audits, key compliance programs and OSHA's targeting programs will be fleshed out.