Why This Checklist Matters
OSHA inspectors don't announce most visits. Referral inspections (triggered by employee complaints), follow-up inspections after previous citations, and programmed inspections targeting high-hazard industries like fabricated metals, plastics, and food processing can happen with little or no warning.
The good news: OSHA cites the same violations year after year. This isn't a mystery. OSHA publishes its top-10 violation list annually. If you close these 10 gaps, you eliminate the majority of your exposure before an inspector ever walks through your door.
This checklist references the relevant CFR standard for each item. OSHA's general industry standards are in 29 CFR 1910; construction is in 29 CFR 1926. Most small manufacturers fall under general industry.
Advisory note
This guide is for informational purposes and does not constitute legal or compliance advice. OSHA standards are detailed and context-dependent. Always consult the full standard text and qualified EHS counsel for your specific situation.
The Top 10 OSHA Violations in Manufacturing
HazCom is OSHA's perennial #1 violation. You need a written HazCom program, Safety Data Sheets (SDS) accessible for every hazardous chemical on-site, and proper GHS-format container labels. Check that SDS binders (or digital systems) are current and that workers have received documented training.
Common gaps: outdated SDS, labels missing pictograms or signal words, no documented employee training records.
If workers use respirators — even voluntarily — you need a written respiratory protection program, medical evaluations, fit testing, and documented training. This standard is violated constantly in facilities where respirators are handed out without the required program infrastructure around them.
Common gaps: no written program, no medical clearance before fit testing, using voluntary-use respirators without the Appendix D information requirement.
Control of hazardous energy is critical wherever workers service or maintain machinery. You need: a written LOTO program, machine-specific energy control procedures for every piece of relevant equipment, annual audits of the procedures, and documented employee training. LOTO failures cause amputations and deaths — OSHA treats violations here seriously.
Common gaps: machine-specific procedures missing for even one machine, no annual audit documentation, contractors not covered by the program.
Any machine part, function, or process that may cause injury must be guarded. Point-of-operation guarding, nip points, rotating parts, flying chips — all need adequate guards that prevent contact. Walk every machine and verify guards are in place and not bypassed or removed.
Common gaps: guards removed for maintenance and not replaced, inadequate guarding for infrequent operations, no guarding on belts/pulleys/gears.
Forklift operators must be trained, evaluated, and certified before operating. Certification must be renewed every three years, or sooner after an accident, near-miss, or unsafe observation. Pre-shift inspections must be documented. Charging areas need ventilation and posted instructions.
Common gaps: expired operator certifications, no pre-shift inspection records, informal "he trained himself" situations.
You must conduct and document a PPE hazard assessment for each job task, select appropriate PPE based on the hazards identified, and train employees on proper use, care, and limitations. The written assessment must be certified with a date and signature.
Common gaps: no documented hazard assessment, PPE provided but not matched to specific hazards, no training records for PPE use.
Aisles and passageways must be kept clear, marked, and in good repair. Any work surface where employees could fall 4 feet or more (or into dangerous equipment) requires fall protection — guardrails, safety nets, or personal fall arrest systems. Loading dock edges and elevated platforms are common problem areas.
Common gaps: blocked emergency egress, damaged floor markings, unguarded mezzanine edges, no fall protection at dock areas.
Electrical panels must be accessible (36-inch clearance), all knockouts and breaker gaps must be closed, and exposed wiring must be in proper conduit or enclosures. Extension cords are for temporary use only and cannot substitute for permanent wiring. GFCIs are required in wet or damp locations.
Common gaps: open electrical panels, daisy-chained extension cords used as permanent wiring, missing covers on junction boxes.
Every facility with more than 10 employees must have a written emergency action plan covering evacuation procedures, emergency escape routes, accounting for employees after evacuation, and procedures for employees who perform critical shutdown operations. The plan must be reviewed with each new employee and when the plan changes.
Common gaps: plan exists but was never reviewed with employees, no documented drill records, no designated employee assembly point.
Establishments with 10+ employees in most industries must maintain OSHA injury and illness records: the 300 Log, 301 Incident Report, and 300A Summary. The 300A Summary must be posted from February 1 through April 30 each year. Electronic submission is required for high-hazard industries with 100+ employees.
Common gaps: incidents not recorded within the required 7-day window, 300A not posted in February, first aid cases incorrectly recorded as recordable incidents.
How to Use This Checklist
Walk your facility with a clipboard (or phone) and treat each item above as a discrete audit point. For each one, ask three questions: Do we have the required written program? Can we produce documented training records? Is the physical condition compliant right now?
Most citations happen because one of those three elements is missing. A facility might have the right equipment but no training records. Or good intentions but nothing documented. OSHA inspectors aren't just looking at the physical conditions — they're asking for your paperwork.
After your self-assessment, prioritize the items marked "High Risk" above. These standards generate the most citations, carry the heaviest penalties, and are often tied to serious injuries. Get those right first, then work down the list.
Beyond the Checklist: Ongoing Compliance
A one-time checklist walk gets you to a baseline. But OSHA compliance is ongoing — new employees need training, equipment changes require updated LOTO procedures, and chemical inventories shift. The facilities that stay ahead of citations are those with regular internal audits baked into their routine, not a scramble every time they hear about an inspection in their industry.
If you want to automate this process, the Prudence EHS Compliance Checklist Generator builds customized checklists based on your specific industry and operations — so you're not checking standards that don't apply to your facility, and you're not missing the ones that do.