OSHA’s “Hit List” for 2026: Act Now or Pay Later

A practical OSHA readiness guide for Operations & HR leaders

It’s almost National Safety Month, which puts an emphasis on safety in the workplace. If OSHA arrived at your facility tomorrow, would your team know exactly what to do in the first 30 minutes?

In a recent HireLevel webinar, safety consultant Alan Lombardo with MarshMcLennan Agency shared a reality many HR and operations leaders learn the hard way: “So much happens in the first half hour or so of them showing up.” And when companies don’t have a plan, they often “say too much,” expand the scope of the inspection, and turn a manageable situation into a costly one.

This blog breaks down:

✔️The most frequently cited OSHA standards (and what they signal about enforcement priorities)

✔️What typically triggers inspections

✔️A clear OSHA inspection game plan

✔️The OSHA risk areas that quietly drive your biggest losses: slips/trips/falls, ergonomics, and training

✔️The added layer most safety blogs ignore: how OSHA expectations change when you use staffing or temp-to-hire labor

Check out the Top 10 Safety Tips for Managers to Implement

Why OSHA’s Top Citations Matter (Even If You’ve “Never Had an OSHA Visit”)

Every year, OSHA publishes the Top 10 most frequently cited standards, a useful “early warning system” for employers. OSHA explicitly shares this data so employers can find and fix common hazards before OSHA shows up. [osha.gov]

OSHA Top 10 Most Cited Standards (FY 2025)

Here’s the federal OSHA Top 10 list for fiscal year 2025 (published/updated April 2026):

1. Fall Protection – General Requirements

2. Hazard Communication

3. Ladders

4. Lockout/Tagout

5. Respiratory Protection

6. Scaffolding

7. Fall Protection – Training Requirements

8. Powered Industrial Trucks

9. Eye & Face Protection

10. Machine Guarding

What this tells HR and Ops leaders: enforcement is consistently focused on falls, hazard communication, energy control, forklifts, and machine guarding, areas that also tend to drive severe claims and operational disruption.

Alan highlighted a key pattern: multiple top citations tie back to falls and fall prevention, which aligns with what many employers see internally as a major cost driver.

(Download and Print your Monthly Safety Calendar here)

What Triggers OSHA to Show Up? (And Why Severe Incident Reporting Matters)

OSHA prioritizes inspections based on risk, starting with imminent danger, severe incidents, complaints, and targeted programs.

The #1 trigger: severe incidents (fatalities and hospitalizations)

Your reporting obligations are not optional, and they can bring OSHA to your door quickly.

✔️Report a work-related fatality within 8 hours

✔️Report an in-patient hospitalization, amputation, or loss of an eye within 24 hours

Alan noted this is the most common reason he sees OSHA appear on-site: a serious injury occurs, it’s reported, and OSHA arrives the next day or shortly thereafter. Complaints can escalate but not always to an on-site visit

OSHA may initiate a document request first (e.g., “show us forklift training records”). A thorough, relevant response can sometimes resolve the issue without an on-site inspection.

OSHA Inspection Readiness: What to Do in the First 30 Minutes

OSHA inspections generally follow a predictable structure: credentials → opening conference → walkaround → closing conference.

Here’s the practical “playbook” from the webinar translated into a simple plan your managers can actually follow.

1) Verify credentials and control the start

✔️Ask for credentials immediately and identify your designated OSHA point person.
If your safety lead is off-site, it is reasonable to request time for them (or your consultant) to arrive before starting.

✔️Action step: Pre-assign a Primary + Backup OSHA Lead (and train them yearly).

2) Define and limit scope at the opening conference

The opening conference sets the “why” and the “where.” You want clarity on:

✔️Why they’re there (incident, complaint, programmed emphasis, etc.)

✔️Action step: Decide in advance how you’ll route OSHA to relevant areas without walking through the entire facility.

3) During the walkaround: mirror everything

✔️Action step: Keep an “OSHA walkaround kit” ready: PPE, notepad, camera-enabled device, and a document checklist.

4) Closing conference: reduce surprises

Use the closing conference to ask what they saw, what standards they believe apply, and what next steps are expected. Alan noted it’s not uncommon to feel like things went fine then citations arrive later so documentation and clarity matter.

After the Inspection: Don’t Skip the Informal Conference

If citations are issued, many employers benefit from requesting an informal conference, which can be the window to discuss abatement strategy and potential reductions or reclassification. Alan shared that reductions are often possible when employers “put their best foot forward.

Important exception: for Willful or Repeat citations, Alan recommends legal representation because stakes can be significantly higher.

The “Quiet” Risk Drivers: Slips/Trips/Falls & Ergonomics

Many employers focus on the “big” compliance topics (lockout/tagout, guarding, PITs) and underestimate the injuries that quietly destroy budgets: same-level slips and falls and ergonomic strains. Alan described a single same-level fall that appeared minor on video but resulted in multiple fractures, surgeries, and a long recovery.

Common slip/trip/fall hazards to address now

Examples discussed in the webinar include unsafe walking surfaces, spills, cords in travel paths, clutter, poor lighting, and improper storage.

Practical upgrades with outsized payoff:

✔️Formal “spill response” expectations (and accountability)

✔️Better lighting (LED conversions often improve hazard visibility)

✔️Footwear policies that match floor conditions

✔️A documented corrective-action process so hazards don’t sit unresolved for months

Ergonomics: why it’s now easier (and cheaper) to improve

Alan highlighted how AI-based ergonomics tools can analyze video and flag high-strain points (often color-coded as green/orange/red). This helps employers identify exactly where small process changes could eliminate high-risk movements.

OSHA Heat Enforcement: A 2026 Update HR & Ops Leaders Should Track

Heat is no longer a “seasonal wellness issue” it’s an enforcement priority.

OSHA updated its Heat National Emphasis Program (NEP) in April 2026

On April 10, 2026, OSHA issued an updated National Emphasis Program, Outdoor and Indoor Heat-Related Hazards to focus enforcement and outreach in higher-risk industries. [osha.gov], [dol.gov]

Heat rulemaking is in progress (still not final)

OSHA’s Heat Injury and Illness Prevention rulemaking remains active; OSHA notes the proposed rule was published in 2024 and hearing/comment phases have occurred. [osha.gov]

What to do now (even before a final standard):

✔️Identify hot zones (indoor processes, mezzanines, dock areas)

✔️Ensure water, rest, cool-down areas, and supervisor training on heat illness signs

✔️Document your approach because OSHA can still cite heat hazards under existing enforcement authority, and the NEP increases attention on heat conditions [osha.gov]

Here are some more Summer Safety Tips for National Safety Month

A Practical OSHA Readiness Checklist

Today (1–2 hours)

✔️Assign an OSHA inspection lead + backup

✔️Create an “OSHA kit” (PPE, camera, document list, contact list)

✔️Confirm severe incident reporting responsibilities (8 hours / 24 hours)

This week

✔️Review your top exposure areas: falls, hazcom, LOTO, PITs, guarding

✔️ Spot-check forklift training records and traffic rules

✔️Conduct a same-level slip/trip/fall walkthrough (floors, lighting, clutter, cords)

This month

✔️Refresh orientation and ongoing “safety huddles/toolbox talks”

✔️Add a corrective-action tracker with owners + due dates (so issues get closed)

Download our New Employee Safety Training Checklist

Where HireLevel Helps (Staffing + Safety Alignment)

At HireLevel, we know safety performance and staffing performance are connected especially in high-turnover, high-demand environments. If you’re hiring temp or temp-to-hire, a few process upgrades can reduce incidents, lower disruption, and improve retention without slowing production.