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The new employer's OSHA compliance checklist

Just crossed into OSHA coverage — or just realized you have been covered all along? The first-90-days sequence that builds a defensible safety baseline.

7 min readUpdated

First: understand what applies to you

The OSH Act covers most private-sector employers with employees, from headcount one. What varies is which duties attach: recordkeeping depends on company size and industry, specific standards depend on your operations and exposures, and the work-site jurisdiction determines whether federal OSHA or an OSHA-approved State Plan enforces.

Two universal duties apply regardless of size: the General Duty Clause (furnish a workplace free from recognized serious hazards) and severe-injury reporting under 29 CFR 1904.39 — the 8- and 24-hour clocks bind even the smallest, most exempt employer.

The first-90-days sequence

Work the list in order — each step feeds the next:

  • Post the notices. The official workplace-rights poster (OSHA 3165 federally; State Plans have equivalents) is free from the agency and mandatory. While you are at that wall, plan the February 300A posting spot.
  • Settle recordkeeping coverage. Count employees company-wide against the 10-or-fewer exemption and check your NAICS code against the low-hazard list — then set up the 300/301/300A workflow if covered (see our recordkeeping guide).
  • Stand up severe-injury reporting. Decide today who calls OSHA when the worst happens, with the 8/24-hour rules and agency contacts written into the incident-intake step — not searched for during the emergency.
  • Run the hazard assessment. A documented walkthrough of your operations (1910.132(d) requires a written PPE hazard assessment) tells you which standards and written programs apply.
  • Build the written programs the assessment demands. Hazard communication if chemicals are present, emergency action plan, lockout/tagout, PPE, and whatever else your exposures trigger — current, site-specific, and matching actual practice.
  • Train against the standards, in a language employees understand, and document every session: topic, standard, date, trainer, attendees, verification.
  • Establish incident intake. One capture path for every injury, near miss, and hazard report — the record that feeds the log, the claim, the corrective action, and the inspection response.

Free help most employers never use

OSHA's On-Site Consultation Program provides free, confidential consultation visits for small and medium employers, separate from enforcement — findings are not citations and are not reported to inspection staff, provided identified hazards are corrected. For a new program, it is the cheapest expert audit available.

The agency's small-business resources, standard-by-standard eTools, and the published inspection data are all free inputs a new safety program should be built on.

What growing past thresholds changes

Growth flips duties on: crossing 11 employees ends the recordkeeping size exemption the following year; crossing 20 in a designated industry adds the March 2 electronic submission; new activities (construction work, chemicals, powered trucks) attach new standards. Put a headcount-and-operations review on the calendar annually so the obligations list never lags reality.

Educational content, not legal advice. This guide summarizes federal requirements in plain English. Regulations change and jurisdictions differ — verify against the current official text and your work-site jurisdiction's rules before acting. SafeGora helps you prepare and organize; filings, postings, and legal determinations remain yours.

Frequently asked questions

The baseline, systematized from day one

SafeGora gives a new program its spine: incident intake, recordkeeping artifacts, training tracking, and written-program evidence — organized per establishment from the first employee.

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