ROSSMAN, Presiding Judge.
In this proceeding under the Oregon Safe Employment Act, ORS chapter 654, employer seeks review of an order of the Workers' Compensation Board affirming a citation of the Oregon Occupational Safety and Health Division (OR-OSHA) and assessing a penalty against employer for failing fully to develop and maintain a "written hazard communication program," as required by OAR 437-155-015(1).
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