McNeil Safety Consulting is based in San Gabriel, California, and works across thirteen states: California, Nevada, Arizona, Oregon, Washington, Idaho, Montana, Utah, Wyoming, Colorado, New Mexico, North Dakota and South Dakota. California is the primary service area. The other ten are not marketing territory — they are jurisdictions whose regulatory structure this firm has worked inside, and the scope of what we do in each one is set out plainly below.
Every engagement in every one of those states is handled in house. Michael Karl McNeil performs the site work, the sampling, the program writing and the citation defense personally; Zennin Sedacey-McNeil, LVN covers the occupational health and medical surveillance side. We do not subcontract, broker, or hand work off to a third-party network. The person you retain is the person who walks the site, writes the report, and sits across from the compliance officer.
The Eleven States, and What We Do in Each
Occupational safety enforcement in the United States is split. Federal OSHA enforces directly in some states; twenty-two states operate their own OSHA-approved state plans covering private-sector employers, and a handful more cover public employees only. That split decides two practical things: which rulebook a citation is written under, and who is allowed to stand up and answer it. The scope below follows that split, not a sales map.
Federal OSHA jurisdictions — Idaho, Montana, Colorado, North Dakota, South Dakota
These five states have no approved state plan for private-sector employers. Enforcement runs through federal OSHA under 29 CFR Parts 1910, 1926 and 1904, and contested citations go to the Occupational Safety and Health Review Commission. Full scope in these states: citation defense, informal conference representation, contest and OSHRC proceedings, inspection response, abatement documentation, and the full EHS consulting practice — programs, training, industrial hygiene sampling, and expert work.
Non-attorney representation is expressly permitted in those proceedings. The Commission’s own procedural rule at 29 CFR 2200.22 provides that a party may appear through a representative who is not an attorney. That is the federal rule, not an interpretation of one.
Approved state plans where we represent employers — California, Nevada, Oregon, New Mexico, Wyoming
California is the primary service area and the deepest practice: Cal/OSHA citation defense, Appeals Board proceedings, Title 8 written programs, and the full industrial hygiene and environmental scope. California’s procedural rule at 8 CCR §378(a) permits an employer to appear through a representative who is not required to be an attorney at law — the state-level parallel to the federal rule above.
Nevada, Oregon, New Mexico and Wyoming each operate an OSHA-approved state plan with its own adopted standards and its own appeals process. Full consulting scope applies in all four, along with citation defense and appeals representation, because each has adopted a rule of its own permitting a party to appear through someone who is not a lawyer. Nevada is the most direct: NAC 618.701(4) provides that a representative “is not required to be an attorney at law,” without qualification, and NAC 618.809(1) gives opposing parties the right to cross-examine. Nevada also allows the longest window of the four — 30 calendar days under NRS 618.475(1), not 15 working days. Oregon’s rule at OAR 438-085-0431(2) provides that a representative “is not required to be an attorney at law or have any other special qualification,” subject to a written designation signed by a corporate officer under subsection (3). New Mexico’s rule at 11.5.5.111(A) NMAC provides that an advocate “may, but need not, be a lawyer,” while requiring an entity party to appear through an advocate rather than on its own behalf. Wyoming is the most explicit of the three: Chapter 6, § 3(d) of the Wyoming OSHA Rules of Practice and Procedure states that nothing in those rules, the Administrative Procedure Act or the Act “shall be construed as requiring any party (including a corporation) to be represented by an attorney-at-law,” and § 13(g) permits an individual appearing in a representative capacity to examine and cross-examine witnesses, subject to the hearing officer determining that a representative capacity exists.
Consulting only — Washington, Utah and Arizona
In these three states the firm performs consulting, industrial hygiene, program development, training and expert work, but does not appear as a representative in appeals. Washington’s Board of Industrial Insurance Appeals limits who may appear under WAC 263-12-020(3)(b), and that list does not clearly extend to an outside safety consultant in a citation appeal. Utah is explicit: Utah Admin. Code R602-1-3(3) requires a corporate party before the Labor Commission’s Division of Adjudication to be represented by counsel admitted to practice in Utah. Arizona is the unresolved one: A.R.S. §23-429 appears to let an employer designate any person to represent it, but the Arizona Supreme Court’s rules limit non-lawyer representation of an entity before a state agency to an uncompensated full-time officer or employee, and no authority we can find reconciles the two. Saying so up front is more useful to an employer than discovering it after a contest deadline has run.
Where the line is drawn
Thirteen states, and no further. A consultant who claims all fifty is telling you something about their marketing, not their practice. Within the thirteen, the scope is set by each state’s own rules rather than by preference: we appear as a representative where the state has adopted a rule permitting it, and we do consulting and expert work where it has not.
Why a California Firm Has Standing Outside California
The multi-state work is not an extension of a California practice into unfamiliar ground. It comes out of twenty-five years in federal fire service, where assignments moved across the Western United States and the governing standards were federal ones. Interagency qualifications were carried under the National Wildfire Coordinating Group (NWCG) system, which is federal and portable by design, and federal law enforcement training was completed at the Federal Law Enforcement Training Centers (FLETC).
That background matters for a specific technical reason. Federal agency occupational safety programs run under 29 CFR Part 1960, which applies the substantive 29 CFR 1910 and 1926 standards to federal employers. Working under Part 1960 across state lines means working under the same federal standards that federal OSHA enforces against private employers in Idaho, Montana, Colorado, North Dakota and South Dakota — while operating physically inside states with their own plans, their own adopted amendments, and their own inspectors.
The result is a working familiarity with both halves of the American enforcement structure: the federal rulebook as written, and the state-plan variations layered over it. Full detail on the background and credentials behind this is on the About Michael Karl McNeil page.
Every Engagement Is Handled Personally — Nothing Is Farmed Out
McNeil Safety Consulting is a two-person practice by design, and the distinction matters more than it may sound. The two roles do not overlap: Michael carries the consulting and defense work, Zennin carries the medical side.
- Michael Karl McNeil — REP, RIHP, REPP, QSD — performs the site work, the sampling, the program writing, the citation defense and the expert analysis himself. Not a junior technician, not a franchise affiliate, not a contract inspector hired for the day.
- Zennin Sedacey-McNeil, LVN (VN 741259) — a California Licensed Vocational Nurse on staff — handles the medical side: occupational health, infection control and OSHA medical surveillance. Those matters are not referred out to a clinic network either.
- No subcontracting. Work is not brokered to a national vendor network, resold to a regional partner, or assigned to whoever a staffing pool has available in that state. When an out-of-state engagement is accepted, the same two people travel to it.
- No intake layer. Calls go to Michael McNeil. There is no account manager between the client and the person doing the work, and no handoff after the proposal is signed.
The trade-off is deliberate: this firm takes fewer engagements than a staffed consultancy can, and turns down work outside the thirteen states listed above. What a client gets in exchange is continuity — the person who saw the site is the person who signs the report and the person who defends it.
Every state, in detail
Each state has its own citing agency, its own contest deadline and its own rule on who may represent an employer. Those differences decide cases, so each one is set out on its own page with the governing statute or rule cited. California is covered across the service pages.
- Colorado — Federal OSHA. Denver and Englewood Area Offices. Representation available.
- Idaho — Federal OSHA, San Francisco Region. Logging emphasis. Representation available.
- Montana — Federal OSHA plus the Montana Safety Culture Act. Representation available.
- North Dakota — Federal OSHA. WSI premium-discount programs. Representation available.
- South Dakota — Federal OSHA. Manufacturing and ammonia PSM. Representation available.
- Nevada — State plan. 30 calendar days to contest, not 15 working days. Representation available.
- Arizona — State plan. Heat emphasis program. Consulting, industrial hygiene and expert work only.
- Oregon — State plan. 30 days to appeal. Representation available.
- New Mexico — State plan. Two deadlines. Representation available.
- Wyoming — State plan. Rule expressly permits a non-attorney. Representation available.
- Washington — State plan. Consulting, industrial hygiene and expert work only.
- Utah — State plan. Consulting, industrial hygiene and expert work only.
Frequently Asked Questions
Do you take OSHA cases outside of California?
Yes. Citation defense and appeals representation are offered in California, Nevada, Oregon, New Mexico and Wyoming, and in the federal OSHA jurisdictions of Idaho, Montana, Colorado, North Dakota and South Dakota. In Washington, Utah and Arizona the firm performs consulting, industrial hygiene and expert work but does not appear in appeals, because each of those states either restricts who may represent a corporate party or leaves the question unresolved.
Can someone who is not an attorney represent an employer in an OSHA case?
In federal OSHA proceedings, yes — 29 CFR 2200.22 permits a party to appear before the Occupational Safety and Health Review Commission through a non-attorney representative. California’s Occupational Safety and Health Appeals Board applies the same principle at 8 CCR §378(a), which allows an employer to appear through a representative not required to be an attorney at law. Other state plans set their own rules, which is why the scope above is broken out state by state rather than stated as a blanket claim.
Do you subcontract out-of-state work to local consultants?
No. The consulting, industrial hygiene, program writing and citation defense work is performed personally by Michael Karl McNeil, and the occupational health and medical surveillance side by Zennin Sedacey-McNeil, LVN. Work is never brokered to a partner firm, a national vendor network, or a contract inspector hired locally for the assignment. That is the reason the service area is thirteen states and not fifty.
How quickly can you respond to an out-of-state inspection or accident?
Call (626) 546-9384 and you will reach Michael McNeil directly. Out-of-state deployment is arranged case by case; the contest and appeal deadlines that follow a citation are short and unforgiving, so the first call should not wait for the paperwork to arrive.
Talk to Michael Directly
Whether the site is in Los Angeles or in Bismarck, the call goes to the same person. (626) 546-9384 — mike@mcneilsafetyconsulting.com.