Compliance Services Authority

Workplace Safety Compliance: OSHA and US Standards

Workplace safety compliance in the United States operates under a federally enforced framework that affects approximately 10 million workplaces and 130 million workers, as documented by the Occupational Safety and Health Administration (OSHA). Noncompliance carries measurable financial and operational consequences: OSHA's penalty structure, updated in 2023, sets serious violation fines at up to $15,625 per violation and willful or repeated violations at up to $156,259 per violation (OSHA Penalties). This page covers the definition and scope of workplace safety compliance, its operational mechanics under OSHA and related standards bodies, common enforcement scenarios, and the decision boundaries that determine which rules apply to which employers.

Definition and scope

Workplace safety compliance refers to an employer's adherence to legally mandated standards, codes, and regulations designed to prevent occupational injury, illness, and death. The primary federal authority is OSHA, established under the Occupational Safety and Health Act of 1970 (29 U.S.C. § 651 et seq.), which applies to most private-sector employers and, through separate mechanisms, to federal government employers.

OSHA's authority does not extend uniformly to every worker. Three categories fall outside direct OSHA jurisdiction:

  1. Self-employed individuals with no employees
  2. Immediate family farm workers on farms not employing outside labor
  3. Workers covered by other federal agencies, including miners under the Mine Safety and Health Administration (MSHA), transportation workers under certain Federal Railroad Administration rules, and atomic energy workers under the Nuclear Regulatory Commission

In states operating OSHA-approved State Plans — 29 states and territories as of the most recent OSHA count (State Plans) — a state agency assumes primary enforcement authority and must maintain standards "at least as effective" as federal OSHA requirements. California (Cal/OSHA), Michigan (MIOSHA), and Washington (L&I/WISHA) exemplify active state plan jurisdictions with supplemental regulations that exceed the federal baseline in specific industries.

Understanding compliance scope is essential before determining which specific standards apply to a given worksite or employer type.

How it works

OSHA's regulatory framework operates through two parallel tracks: industry-specific standards and the General Duty Clause.

Industry-specific standards are codified in Title 29 of the Code of Federal Regulations. The four primary industry groupings under 29 CFR are:

  1. General Industry (29 CFR Part 1910) — covers manufacturing, warehousing, retail, healthcare, and service industries
  2. Construction (29 CFR Part 1926) — governs residential and commercial building, demolition, and excavation
  3. Maritime (29 CFR Parts 1915–1918) — applies to shipyards, marine terminals, and longshoring
  4. Agriculture (29 CFR Part 1928) — addresses field sanitation, equipment guarding, and pesticide exposure

The General Duty Clause (Section 5(a)(1) of the OSH Act) functions as a catch-all provision. When no specific standard addresses a recognized hazard, OSHA may cite an employer for failing to provide a workplace "free from recognized hazards that are causing or are likely to cause death or serious physical harm." This clause is frequently applied to ergonomic hazards, workplace violence in high-risk settings, and novel chemical exposures not yet covered by a specific standard.

Enforcement begins when OSHA receives a complaint, observes a fatality or severe injury report (employers must report fatalities within 8 hours and hospitalizations of 3 or more workers within 24 hours under 29 CFR 1904.39), or initiates a programmed inspection. Inspections follow a priority hierarchy: imminent danger situations, fatalities and catastrophes, worker complaints, referrals, and programmed inspections of high-hazard industries.

A well-structured compliance program integrates hazard identification, written safety plans, training records, and incident documentation to demonstrate good-faith compliance during any inspection.

Common scenarios

Three workplace scenarios illustrate how OSHA standards translate into operational obligations:

Scenario 1 — Construction fall protection. Falls are the leading cause of construction worker deaths (OSHA Construction eTool). Under 29 CFR 1926.502, employers must provide fall protection systems — guardrails, safety nets, or personal fall arrest systems — for workers at elevations of 6 feet or more above a lower level. Failure to implement a site-specific fall protection plan triggers citation under the specific standard and, in cases of prior citations, a willful classification.

Scenario 2 — Hazard Communication (HazCom). Employers handling hazardous chemicals must comply with OSHA's Hazard Communication Standard (HCS), 29 CFR 1910.1200, which aligns with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Requirements include Safety Data Sheets (SDS) for each chemical, labeled containers, and documented employee training. HazCom violations are among the top 10 most frequently cited standards each year (OSHA Top 10 List).

Scenario 3 — Recordkeeping under 29 CFR Part 1904. Employers with 10 or more employees in industries not specifically exempted must maintain OSHA 300 logs (Log of Work-Related Injuries and Illnesses), OSHA 300A summaries, and OSHA 301 incident reports. Establishments with 100 or more employees in designated high-hazard industries must electronically submit 300A data annually through OSHA's Injury Tracking Application (ITA).

Decision boundaries

Determining which OSHA standards apply to a specific employer requires resolving four classification questions in sequence:

  1. Federal vs. State Plan jurisdiction — Is the worksite located in a state with an approved State Plan? If yes, state standards govern, though they must meet or exceed federal minimums.
  2. Industry classification — Does the work fall under General Industry, Construction, Maritime, or Agriculture? Misclassification — applying General Industry standards to a construction site, for example — can result in incorrect hazard controls.
  3. Employee count and industry code — Recordkeeping obligations, electronic submission requirements, and exemptions from programmed inspections depend on employee headcount and NAICS code classification.
  4. Specific standard vs. General Duty Clause — If a recognized hazard exists but no specific standard addresses it, the General Duty Clause applies. Employers who document hazard assessments and implement feasible abatement measures reduce exposure to General Duty citations.

The contrast between specific standards and the General Duty Clause is consequential: specific standard violations allow OSHA to cite with precision and assess per-violation penalties, while General Duty citations require OSHA to prove the hazard was recognized, likely to cause serious harm, and correctable by feasible means — a higher evidentiary bar that employers can contest more effectively with documented abatement efforts.

Compliance monitoring and auditing practices that include regular internal inspections, corrective action tracking, and recordkeeping audits directly support the defense posture an employer needs when OSHA initiates a formal inquiry.

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