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See Marshall v. Barlow's, Inc., 436 U.S. 307, 98 S.Ct. 1816, 56 L.Ed.2d 305 (1978). In Barlow's, the Supreme Court held that warrants are required for administrative inspections under the Act. Id. at 325, 98 S.Ct. at 1827. The Court also stated that probable cause justifying the issuance of a warrant for administrative purposes may be based either on 'specific evidence of an existing violation' or 'on a showing that 'reasonable legislative or administrative standards for conducting an ... inspection are satisfied with respect to a particular [establishment].' ' Id. at 320, 98 S.Ct. at 1824. Expounding on the second basis, the Court noted that a 'warrant showing that a specific business has been chosen for an OSHA search on the basis of a general administrative plan for the enforcement of the Act derived from neutral sources ... would protect an employer's Fourth Amendment rights.' Id. at 321, 98 S.Ct. at 1824-25 (emphasis added). Because administrative and legislative guidelines ensure that employers selected for inspection pursuant to neutral administrative plans have not been chosen simply for the purpose of harassment, courts have held that administrative plan searches may properly extend to the entire workplace. ...

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