The OSHA Audit Reality Check

What OSHA Compliance Officers Request

OSHA Audit Readiness

This post outlines what OSHA compliance officers actually request during an audit and how you can be prepared.

The OSHA inspector walks in at 9:47 AM on a Tuesday. Your training manager is on vacation. Records are scattered everywhere. You’ve got four hours to prove your workers are trained and your record keeping is current.

Here’s the part nobody wants to admit: OSHA’s 2025 maximum recordkeeping fine is $16,589 per violation. With instance-by-instance citations now being applied to recordkeeping, those numbers stack up fast. Most companies discover their gaps when the inspector’s already standing there with a clipboard.

Let’s talk about what inspectors actually ask for and what gets you cited.

What Happens When OSHA Shows Up?

OSHA’s Field Operations Manual tells compliance officers to review “OSHA 300 logs, 300A summaries, and 301 incident reports” during the opening conference. This isn’t optional. It happens every single time.

On every OSHA inspection, they’re going to ask for your hazard communication program and up to three years of OSHA 300 recordkeeping information. Sometimes five years.

Beyond that, they’ll request training documentation, safety programs, and whatever else is relevant to why they’re there. The clock starts immediately.

When OSHA asks for records under Part 1904, you’ve got four business hours to hand them over.

Not four days. Not "let me call our IT guy." Four hours from the moment they ask.

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The Forms You Need to Produce Right Now

OSHA Form 300 (Log of Work-Related Injuries and Illnesses)

This is your running list of every recordable injury and illness. Form 300 entries must be completed within seven calendar days of learning about a recordable case (29 CFR 1904.29). Seven actual days, not business days.

Where companies screw this up? Cases that should be on there but aren’t. Delayed entries because someone forgot to tell the safety manager. When the required records are kept but there’s no entry for a specific injury that meets the recording criteria, a citation for failure to record the case will normally be issued.

OSHA Form 300A (Annual Summary of Work-Related Injuries and Illnesses)

Year-end totals. The Form 300A Annual Summary must be posted from February 1 through April 30 (29 CFR 1904.32) where workers can see.

Where companies screw this up? Forgetting to post it entirely. Or taking it down in March because you needed the bulletin board space. Remember Posting Requirements violations can result in penalties up to $16,550.

OSHA Form 301 (Injury and Illness Incident Report)

The full story behind every case on your 300 Log. Form 301 must be completed within seven calendar days for each recordable case (29 CFR 1904.29).

Where companies screw this up? Improperly completed forms. No coordination between what’s in workers’ comp records and what’s on the OSHA forms.

How Long Should You Keep Them?

You must save the OSHA 300 Log, the privacy case list if you have one, the annual summary, and the OSHA 301 forms for five years following the end of the calendar year they cover.

That injury from 2020? You need those records through December 31, 2025. Not from the date of the injury. From the end of that calendar year.

Training Records: Yes, They Ask For Them

Training records are not part of the 29 CFR 1904 injury and illness logs, but OSHA routinely requests them during inspections under the FOM (2025).
They request training certification and documentation for PPE, fall hazards, general safety and health, plus “any and all documentation of training” for relevant employees.

What Are They Checking?

  • Did you train the people who are required to be trained?
  • Can you prove it?
  • Does the training actually meet the requirements of the OSHA standard?

Where Companies Fail?

  • Records scattered across multiple vendor portals and spreadsheets
  • Certificates with no details about what was actually covered
  • That classic response: “I know José took the course, I just can’t find the certificate right now”
  • Login credentials for old vendor platforms that don’t work anymore

The Electronic Submission Requirement (Don't Miss This)

Here’s something a lot of companies don’t know about: Covered employers must submit their OSHA injury and illness records electronically using OSHA’s Injury Tracking Application by March 2 each year.

Who has to submit?

Everyone submits Form 300A if:

Your establishment had 250 or more employees in the prior calendar year, OR
Your establishment had 20-249 employees and you’re in certain high-risk industries listed in Appendix A to Subpart E

You also submit Forms 300 AND 301 if:

Your establishment has 100 or more employees and is in an industry listed in Appendix B to Subpart E

The deadline: March 2 of the year following the covered year (for example, March 2, 2026 for calendar year 2025 data)

What happens if you don't submit?

If a company is inspected by OSHA and failed to submit these forms when required, it may result in an Other-Than-Serious citation.

Keep your 2025 records current because you’ll need to submit them by March 2, 2026.

Use OSHA’s ITA Coverage Application to determine if you’re required to electronically submit your data.

The Instance-By-Instance Problem

When OSHA issues incident-by-incident penalties it can get very expensive very fast.

Incident-by-incident citations were first employed in recordkeeping cases, and it’s very easy to make a mistake on your records log and end up paying egregious violation fines for it.

The Real Audit Readiness Test:

Stop right now. Don’t open any files or log into anything. Just answer these questions:

  1. Can you name where your OSHA 300 Log is for this year and the past three years?
  2. Do you know if your Form 300A was actually posted from February through April 2025?
  3. Can you tell me right now if you have complete Form 301s for every single entry on those 300 Logs?
  4. Did you submit your 2024 data electronically by March 2, 2025 if you were required to?
  5. If I asked for training records for five random workers, where would you look first? And how long would it take you?
  6. Can you do all of this within four business hours if an OSHA inspector walks in?

If you hesitated on any of those, or if your answer involved calling someone who’s not available, you’re not ready.

OSHA CITATION REALITY CHECK

Maximum $16,550  per violation  X

instance-by-instance citations
Missing Form 300A
$16,550
5 incomplete Form 301
$82,750
8 unapproved training records
$132,400

One messy audit total

$231,700

Instance-by-instance citations mean every missing or incomplete record = separate penalty. What looks like “just some record keeping gaps” becomes a six-figure problem fast.

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