The OSHA Compliance Checklist Contractors Actually Use

The Reality Of OSHA Inspections

OSHA doesn't inspect randomly. Something triggers every visit. And they follow a predictable pattern once they arrive:

1. Opening conference with employer
2. Walkaround with employer + worker representative
3. Interviews with workers (private)
4. Document review
5. Closing conference
6. Citations issued within 6 months if warranted

The 7 Documents OSHA Always Wants To See

1. Written Safety & Health Program

Your master safety document. Signed by owner. Covers hazard identification, training, inspection, incident response, discipline. Under 1926.20 and 1910 subparts. Have this.

2. OSHA 300 / 300A Injury Logs

Every OSHA-recordable injury/illness must be logged within 7 days on OSHA Form 300. Annual summary (Form 300A) posted Feb 1 - Apr 30 each year. Employers with 20-249 employees in certain high-hazard industries must submit electronically by March 2.

3. Employee Training Records

For each worker: what training they received, when, by whom, and their signed acknowledgment. Required topics include HazCom, PPE, fall protection, and any hazard-specific training. No signed record = training never happened, in OSHA's eyes.

4. JHAs For Observed Work

The inspector watches your crew work. Then asks for the JHA for that specific task. If your JHA doesn't match the actual work being done — citation.

5. PPE Assessment

Under 1910.132(d) and 1926.28, employers must conduct a written hazard assessment identifying which hazards require PPE. Assessment must be documented and signed. Then PPE training records for each worker.

6. Hazard Communication (HazCom) Program

Under 1910.1200: written HazCom program, chemical inventory list, SDS binder (or electronic access), labels on all containers, worker training on chemicals used. This is #2 on OSHA's most-cited list every year.

7. Permits Where Applicable

Confined space entry permits, hot work permits, LOTO procedures, excavation permits. Signed, dated, filed. Even for tasks completed last month.

The Site Walkthrough Checklist

What OSHA inspectors physically look for on your jobsite:

Fall Protection

• Every worker 6+ ft above lower level has fall protection
• Guardrails 42 inches, mid-rail, toeboard
• Personal fall arrest systems in use, tied off properly
• Anchor points visible and rated
• Ladder use per 1926.1053 (extension 3 ft above landing, 1:4 ratio)

PPE

• Hard hats worn where required (ANSI Z89.1 marked)
• Safety glasses / face shields where required
• Steel toe or composite toe boots
• High-vis vests (Class 2 or 3 for roadway work)
• Hearing protection where noise >85 dB
• Respirators where required with fit-test records

Housekeeping

• Walkways clear
• Materials stacked stably
• Cords not creating trip hazards
• Trash removed daily
• Fire extinguishers accessible

Electrical

• GFCI on all temporary power
• Panels closed, labeled
• Cords not damaged
• LOTO procedures where required

Excavation

• Competent person daily inspection documented
• Sloping/shoring/shielding for 5+ ft depth
• Egress ladder within 25 lateral ft
• Utility marking (811)

What Triggers Citations (Even If Documents Are Perfect)

Even contractors with excellent paperwork get cited when the inspector observes:

• Workers not tied off at height
• Excavations without protective systems
• Workers wearing damaged PPE
• No guardrails or barricades around fall hazards
• Chemical containers without labels
• Missing SDSs for chemicals in use

Documents matter. But observed hazards matter more. Both must be right.

What To Do During An Actual OSHA Inspection

Opening Conference

• Request identification and inspection warrant if desired
• Ask what triggered the inspection
• Provide the requested documents
• Designate an employer representative for the walkthrough

Walkthrough

• Accompany the inspector everywhere they go
• Take photos of everything they photograph
• Take notes on everything they question
• Immediate abatement of observed hazards is permitted and encouraged

Worker Interviews

• Workers have the right to be interviewed privately
• You cannot retaliate against workers who cooperate
• Workers may but don't have to answer questions

Closing Conference

• Inspector may indicate likely citations
• You may present additional information
• Ask about informal settlement conferences

Frequently Asked Questions

Article by Anthony Forbes. 20 years field experience. Field supervisor on major wind, transmission, and utility projects. All templates on this site are written by Anthony directly.