The OSHA inspection record guide.

The OSHA inspection record explains what happened on a workplace safety inspection and what citations followed. This is the practitioner's guide for federal procurement officers and primes vetting safety-sensitive contractors. Citation severity definitions, current penalty maximums, the State Plan blind spot, and a pattern-recognition framework that no OSHA.gov page will publish.
/ 01 · FOUNDATION

What an OSHA inspection record actually covers.

Every OSHA enforcement inspection produces a record in the OSHA Information System (OIS), surfaced publicly via Establishment Search at www.osha.gov/ords/imis/establishment.html. The records cover six programmatic categories per OSHA's Field Operations Manual:

Imminent danger
Hazard with reasonable certainty of death or serious physical harm immediately or before the imminence can be eliminated through normal enforcement procedures.
Fatality / catastrophe
Triggered by a worker death or three-or-more-employee hospitalization. Reported by the employer within 8 or 24 hours respectively.
Complaint
A worker, union, or other complainant raised an issue. Strongest signal for vendor screening.
Referral
Another agency, the media, or a previous OSHA inspection flagged the site.
Programmed
Site-Specific Targeting (SST), National Emphasis Programs, Local Emphasis Programs. Industry-wide sampling. Less signal about a specific employer than complaint or fatality inspections.
Follow-up
Verifies abatement of a prior cited hazard.

Why category matters for vendor screening: a complaint-triggered inspection signals a worker raised an issue; a fatality / catastrophe inspection signals an event already occurred; a programmed inspection is industry sampling and carries less signal about the specific employer.

/ 02 · CITATION TAXONOMY

Citation severity definitions.

OSHA categorizes citations under the OSH Act §17 (29 U.S.C. §666) framework and 29 CFR 1903. The categories drive penalty exposure and procurement implications.

Willful
Employer knew of a hazardous condition and either intentionally violated the standard or showed plain indifference. Requires evidence of conscious disregard. The only category that can support criminal referral when paired with an employee death.
Repeated
A substantially similar violation was previously cited and that prior citation became a final order within the last five years (OSHA Field Operations Manual, Chapter 4). The "substantially similar" test looks at hazard, not standard number.
Serious
Substantial probability of death or serious physical harm, AND the employer knew or should have known of the hazard. The "should have known" prong makes Serious the workhorse citation type.
Other-Than-Serious
Direct relationship to safety/health, but unlikely to cause death or serious physical harm.
Failure to Abate
Hazard cited in a prior inspection was not corrected by the abatement date. Penalty accrues per day past the deadline.
De Minimis
Technical violation with no direct or immediate relationship to safety/health. No penalty.
/ 03 · CURRENT MAXIMUMS

OSHA penalty maximums (2025 / 2026).

The current maximums are from OSHA's January 7, 2025 memo, effective for penalties assessed after January 15, 2025:

Serious
$16,550 per violation
Other-Than-Serious
$16,550 per violation
Posting Requirements
$16,550 per violation
Failure to Abate
$16,550 per day beyond the abatement date
Willful or Repeated
$165,514 per violation (Willful minimum: $11,823)
Why no 2026 adjustment
OSHA normally publishes an annual inflation adjustment in early-to-mid January under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. For 2026, the adjustment was cancelled by OMB Memorandum M-26-11 (Apr 17, 2026)because the October 2025 CPI-U data required for the calculation was not produced during the October-November 2025 government shutdown. Per OMB: "there will be no updated cost-of-living adjustment multiplier for 2026 and agencies will continue using the 2025 civil monetary penalty levels as applicable." The Jan 15, 2025 maximums above are current through 2026.

Two interpretive callouts that matter for federal contracting:

  • Each instance can be cited separately. A Willful covering 10 exposed employees can stack to 10 × $165,514 = $1,655,140 before contest.
  • Failure-to-Abate accrues daily. A 30-day overrun = up to $496,500 on a single uncorrected hazard.
  • Posted numbers are initial. Informal settlement typically reduces by 30-50% (per DOL OIG audits of OSHA penalty practices).
/ 05 · FIELD DECODER

Reading a citation record field-by-field.

A sample inspection page shows these fields, each with an interpretive role:

Activity Nr
Unique inspection ID. Use this when filing FOIAs or pulling Citation/Penalty PDFs.
Open / Closed dates
Time gap is a complexity proxy.
Inspection Type
Maps to the six categories in section 1.
Violation Items
Each row: Standard cited (e.g., 1926.501(b)(1) for fall protection), Issuance Date, Type (S / W / R / O / U for Serious / Willful / Repeated / Other / Unclassified), Current Penalty, Initial Penalty, Final Order Date, Abatement.
FTA flag
Failure to Abate flag, if present.
Emphasis Programs
Tells you why OSHA was on-site.
Initial vs Current Penalty
The delta is the settlement signal, typically 30-50% reduction post-informal-settlement.
/ 06 · FEDERAL CONTRACTING

What an OSHA pattern actually means for procurement.

The headline section. Most SERP results on "how to read OSHA citations" are written for employers facing citations, not for buyers screening employers. Here is the framework procurement officers should use, derived from FAR 9.104 responsibility factors:

  • One Serious citation alone is not disqualifying. OSHA cites a high percentage of inspections, and Serious is the modal type. A clean five-year record on a high-hazard NAICS is unusual.
  • A Willful citation is a serious flag, but not automatic disqualification. Look for: was it contested and downgraded; was a settlement reached; what was the abatement evidence.
  • Pattern matters more than any single citation. A working decision rule:
    • 3 or more Serious citations of the same standard within 36 months → systemic control failure
    • Any Repeated citation → prior abatement didn't stick
    • Any Willful + fatality → escalate to legal / contracting officer
    • Severe Violator Enforcement Program (SVEP) listing → near-automatic exclusion for safety-sensitive scope
  • Tie to FAR 9.104-1(d), "satisfactory record of integrity and business ethics", and FAR 9.104-3(b) responsibility determinations. OSHA history is one input, never the whole determination.
Editorial framework, not OSHA rule
The 36-month / 3-Serious threshold is DiligenceDesk's working framework drawn from FAR 9.104 responsibility factors. It is not an OSHA rule and not a regulatory standard. OSHA does not adjudicate vendor fitness, only standards compliance. The framework is offered as a starting point for procurement decisions, not a substitute for a contracting officer's judgment.
/ 07 · IN DILIGENCEDESK

How DiligenceDesk reads OSHA records.

OSHA inspections are one input into the broader integrity pillar (DOL Wage and Hour, OSHA, FAPIIS, court records, SAM exclusions). DiligenceDesk pulls Establishment Search, normalises the legal-name-vs-trade-name fuzziness, time-buckets findings, and surfaces the SVEP listing as its own evidence row.

See the methodology page for the verdict ladder, the DOL Wage and Hour search guide for the separate WHD enforcement dataset (often confused with WHD-investigated OSHA fields in the WHD dataset), and Step 3 of the contractor due-diligence checklist for where labor and safety enforcement fits in the workflow.

Pull an integrated labor and safety record on any federal vendor.

Free. OSHA + DOL WHD + FAPIIS + SAM exclusions + ITA sanctions + Section 889 + USAspending, eight federal sources reconciled in seconds.