Compliance Walk-Through
12 Findings Inspectors See First
A walk-the-facility punch list for safety leaders. Built around OSHA's FY 2025 most-cited standards plus the environmental + fire-protection gaps that show up on nearly every audit. Each item links to the deeper article on that topic.
How to Use This List
Most companies do not fail audits because they do not care about compliance — they fail because nobody walked the facility with the regulator's checklist in hand before the regulator did. This walk-through is built for that pre-audit walk.
The 12 findings below are drawn from OSHA's Fiscal Year 2025 most-cited standards plus environmental and fire-protection gaps that show up on the majority of facility audits but rarely make OSHA's headline list. Items marked ★ OSHA TOP 10 were among the ten most-cited federal standards in FY 2025.
For each item we cover: what the standard requires, why it's commonly missed, what to physically look for, and a link to the deep article on the topic.
The 12 Findings
Why it's missed: OSHA's #2 cited general-industry standard year after year. The hardest-to-catch failures are secondary containers and spray bottles filled from a bulk drum — they almost never carry a label and almost always exist in every facility.
- Containers without labels, or with faded/damaged GHS pictograms
- Spray bottles or other secondary containers carrying nothing but a Sharpie scribble
- SDS binder missing, incomplete, or stored where employees cannot reach it
- No documented HazCom training records (initial + when a new chemical is introduced)
- Employees unable to explain the hazards of chemicals they handle
- Incompatible chemicals stored together; flammables near ignition sources
Why it's missed: Not in OSHA's published top 10, but one of the most consistently observed deficiencies in real-world audits. The 36-inch working clearance in front of electrical panels (NFPA 70E §130 / NEC §110.26) is regularly violated by storage that drifted in over time.
- Storage blocking the 36" working clearance in front of breaker panels
- Breakers not labeled — or labeled but with directories that no longer match the panel
- Unused breaker positions left in the ON position with nothing connected
- Exposed energized contacts — knockouts left open, missing covers, deadfront screws absent
- Outlet covers missing or broken; cord-and-plug equipment with damaged jackets
Why it's missed: Failure to control hazardous energy during equipment servicing. A perennial OSHA top-10 entry. The two most common gaps: no written equipment-specific procedures, and the annual procedure inspection (147(c)(6)) is missing or incomplete.
- No written energy-control program OR no equipment-specific procedures for each piece of equipment with multiple energy sources
- Missing or inadequate locks/tags — tags without warning text, locks shared between employees
- Servicing equipment without de-energizing first — including "minor servicing" exceptions that do not actually qualify
- No documented annual LOTO procedure inspections (147(c)(6) requires one inspection per procedure per year)
- No periodic re-training for authorized employees
Why it's missed: Missing or inadequate guards on rotating equipment, points of operation, and moving parts. Consistently in the top 10. Most violations follow a maintenance event — the guard came off, the machine went back into service, and the guard never came back.
- Guards removed during maintenance and not replaced before the equipment returned to service
- Rotating equipment (fans, pulleys, shafts, belts) operating without guards within 7 feet of a walking surface
- Nip points and pinch points unguarded — the gap between two rollers, between a rotor and a fixed surface, etc.
- Guards modified, propped open, or otherwise rendered ineffective for the sake of speed or convenience
- No documented machine-specific risk assessment or hazard analysis
Why it's missed: The first item most safety professionals miss because it is enforced by EPA and state environmental agencies, not OSHA. If you store oil above 1,320 gallons aggregate aboveground (or 42,000 gallons underground), you are subject to SPCC — and a containment failure is an immediate violation.
- Containment areas with standing water, snow, or accumulated liquid — capacity is reduced by anything sitting in the dike
- Visible cracks, holes, or deterioration in containment walls or floor — concrete, coatings, or liners
- Drainage valves left open or unlocked — these should be normally closed and locked, with documented inspection before any drain event
- Tanks or drums with no secondary containment at all
- No SPCC plan on file, or one that has not been reviewed and updated in 5+ years
Why it's missed: Workers using respirators without a written program, medical evaluations, or fit testing. The standard is well-known but the documentation gap is widespread — particularly in smaller facilities where respirator use is informal or 'voluntary.'
- No written respiratory protection program (required even for voluntary N95 use beyond filtering-facepieces)
- Employees fit-tested without prior medical clearance — the order matters: medical evaluation first, then fit test
- Annual fit testing not documented (or fit test on the wrong make/model/size of respirator)
- Respirators stored improperly — in toolboxes, lockers, or PPE kits without protection from contamination, dust, sunlight, or deformation
- Cartridge change-out schedule not documented for chemical cartridges (1910.134(d)(3)(iii))
Why it's missed: Recordkeeping is the first thing an inspector asks for at the opening conference. Missing or incomplete logs signal that other compliance areas may be neglected — and the violation is provable from documents alone.
- No OSHA 300 Log maintained, or not updated within 7 calendar days of becoming aware of a recordable case
- 300A Annual Summary not posted from February 1 through April 30 each year
- First-aid cases incorrectly recorded as recordable (or the reverse — recordable cases recorded as first-aid)
- No designated person or department responsible for maintaining records
- Records not retained for the required 5-year period (current year + 5)
- Establishments with 100+ employees not submitting 300/301 data through the ITA portal annually
Why it's missed: OSHA #1 cited standard for 15 consecutive years. The threshold is 6 feet in construction, 4 feet in general industry — both lower than most workers expect. Damaged guardrails and unsafe ladder use are the most common findings.
- Guardrails on raised platforms (above 4' GI / 6' construction) damaged, missing, or with toprail below 39"–45"
- No fall protection system for workers exposed to edges at the threshold height
- Portable ladders used incorrectly — wrong angle, top three rungs used, side-loaded, damaged side rails
- Skylights and floor openings without covers, guards, or fall arrest
- Roof edges with no warning lines, no parapet, and no PFAS for workers performing maintenance
Why it's missed: Fire extinguishers are required by OSHA in nearly every workplace and are one of the most commonly overlooked compliance items in small facilities. Annual inspections and 6/12-year service intervals get missed because nobody owns the schedule.
- Annual inspection tag expired or missing — NFPA 10 §7.3 requires annual external maintenance with a tag
- Pressure gauge needle in the red zone (discharged) or above the green (overcharged)
- Mounted higher than 60" (top-of-unit max for 40 lb+) or 60" handle / ADA-conflicted; or blocked by storage, equipment, or a closed door
- Wrong type for the hazard — Class A only in a kitchen, no Class K where cooking oil is present, no Class C in an electrical room
- 6-year internal maintenance and 12-year hydrostatic test not documented on the unit
- Monthly inspection (1910.157(e)(2)) not initialed on the back of the tag
Why it's missed: Outside the OSHA scope, but a major audit finding for industrial facilities. If you have an NPDES Multi-Sector General Permit (MSGP) or any individual stormwater permit, the inspection and documentation requirements are continuous — and regulators inspect those records.
- No SWPPP on file, or not reviewed/updated in the last year
- Required quarterly visual stormwater inspections not conducted, or not documented
- Exposed materials, drums, or waste near storm drains — these become Significant Materials and trigger permit conditions
- NPDES permit-specific monitoring (benchmark, indicator, effluent) not being tracked or reported through NetDMR
- No designated SWPPP team and no annual SWPPP training documentation
Why it's missed: Often the PPE exists but nobody enforces its use. The other big gap is the written PPE hazard assessment (1910.132(d)) — it is required and almost never done outside of a paper certification.
- No written PPE hazard assessment certifying which PPE applies to which task
- Employees observed working without required PPE (eye protection in machine areas; cut-resistant gloves in slaughterhouses; high-vis on roadways; etc.)
- PPE in poor condition — cracked safety lenses, worn-out gloves, damaged respirators, illegible high-vis
- No documented PPE training (general PPE training is required initially and when the workplace changes)
- Hard hats expired (most manufacturers stamp a 5-year shell life from date of issue)
Why it's missed: Forklift violations are almost always about two things: insufficient operator training (initial + 3-year refresher + after any incident or evaluation) and missing pre-shift inspections (1910.178(q)(7)). Both are easy for an inspector to verify on the spot.
- No documented operator training and certification — and no 3-year refresher / after-incident re-training
- Pre-shift inspection checklists not completed, or not retained
- Forklifts with obvious damage (leaking hydraulics, damaged forks, inoperative seatbelt or horn) being operated
- Operators traveling with elevated loads (fork height should be ~6" off the ground when traveling)
- No documented evaluation of each operator at least once every three years
- Pedestrian exposure — no marked walkways, no separation, no high-vis policy in forklift travel zones
The Records Pass
After the physical walk, sit down at a table and ask for these documents. If the on-site safety lead can produce them in 15 minutes, you have a defensible compliance program. If they cannot, you have a finding waiting to happen.
- OSHA 300 Log + 300A Annual Summary — current year, prior 5 years; signed by an officer if 300A.
- Written HazCom program + SDS binder — the binder must be accessible during all shifts.
- Written LOTO program + equipment-specific procedures + annual procedure inspection (1 per procedure per year).
- Written respiratory protection program + medical clearance forms + fit-test records.
- Written PPE hazard assessment + training records.
- Fall protection plan + training records.
- Forklift operator training + 3-year evaluations + pre-shift inspection logs.
- Fire extinguisher annual maintenance tags + monthly inspection initials.
- SPCC plan (if oil > 1,320 gal aggregate aboveground) + monthly visual inspection records.
- SWPPP (if NPDES MSGP or individual permit) + quarterly visual inspections + annual training.
Doing This Yourself vs With Help
The first walk-through always finds more than the team expected — usually 30–60 individual findings even at facilities that consider themselves "compliant." That's normal. The point of the walk-through is not to fail; it's to surface what an inspector would surface, in the order they'd surface it, while you still have time to fix it.
If you prefer a second set of eyes for the first pass, our AI Photo Hazard Finder can scan workplace photos for the same categories of finding (electrical, fall, PPE, fire extinguisher, machine guarding) and the JHA + 5×5 Risk Matrix tool gives you a structured way to score and prioritize what you find.
Frequently Asked Questions
How is this list different from OSHA's published Top 10?
How do I actually walk a facility with this list?
Which findings can a regulator verify in the first 15 minutes of an inspection?
My facility has fewer than 10 employees — does any of this still apply?
What is the single highest-leverage compliance fix?
Where do I find the FY 2025 OSHA top-10 citation counts referenced in the walk-through?
References
1. OSHA, Top 10 Most Frequently Cited Standards (FY 2025), U.S. Department of Labor.
2. 29 CFR 1910 (General Industry) and 29 CFR 1926 (Construction).
3. 29 CFR 1904 — Recording and Reporting Occupational Injuries and Illnesses.
4. NFPA 10 (2022 ed.) — Standard for Portable Fire Extinguishers.
5. NFPA 70E (2024 ed.) — Standard for Electrical Safety in the Workplace.
6. 40 CFR 112 — Oil Pollution Prevention (SPCC), and 40 CFR 122 — NPDES permit program, U.S. EPA.
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