What is an OSHA inspection action plan?
An inspection action plan (or corrective action plan) is the document that turns an OSHA Citation and Notification of Penalty into a dated, assignable to-do list: what must be corrected, who owns it, by when, and what proof you will keep. A good plan does two things at once — it gets the hazard abated before the deadline, and it builds the evidence file you will need at the informal conference and to certify abatement to OSHA.
The builder above produces a prioritized timeline (immediate / short-term / medium-term), an evidence and document checklist tailored to the violation topics you select, the training records inspectors expect, and the procedural deadlines tied to your inspection stage. It is a planning aid — not legal advice and not a certification that any specific correction satisfies a cited standard.
The OSHA citation timeline (and the deadlines that matter)
After a compliance officer issues a citation, several clocks start at once. Missing any of them is expensive: an un-contested citation becomes a final order, and a missed abatement date triggers a Failure-to-Abate penalty. These are the procedural deadlines the plan keys off of:
| Step | Deadline | CFR |
|---|---|---|
| Post each citation at/near the cited location | Until abated, or 3 working days, whichever is longer | 29 CFR 1903.16 |
| File a Notice of Contest (penalty, citation, or abatement date) | 15 working days from receipt of the citation | 29 CFR 1903.15 |
| Request an informal conference | Within the 15-working-day contest period (does not stay the clock) | 29 CFR 1903.19 / 1903.20 |
| Certify abatement to the Area Director in writing | Within 10 calendar days after each abatement date | 29 CFR 1903.19(c) |
| Submit an abatement plan (long corrections) | When any abatement period exceeds 90 calendar days | 29 CFR 1903.19(e) |
“Working days” exclude weekends and federal holidays. Requesting an informal conference does not extend the 15-working-day contest period (29 CFR 1903.20) — file a protective Notice of Contest if that deadline is close.
Penalty exposure — and why abatement is the priority
2026 federal maximums — the 2025 figures carried forward, with no inflation adjustment. 2026 amounts unchanged from 2025 (no CPI adjustment; OMB M-26-11). Not an increase. The line that drives the action plan is the last one: a missed abatement date can cost up to $16,550 per day.
| Violation type | Maximum penalty | CFR |
|---|---|---|
| Serious | $16,550 | 29 CFR 1903.15(d)(3) |
| Other-Than-Serious | $16,550 | 29 CFR 1903.15(d)(4) |
| Willful | $165,514 | 29 CFR 1903.15(d)(1) |
| Repeated | $165,514 | 29 CFR 1903.15(d)(2) |
| Failure to Abate | $16,550 / day | 29 CFR 1903.15(d)(5) |
Penalties verified 2026-10-05. Some State Plans set their own amounts: California and Oregon can fine more on at least one class; Indiana, Kentucky, Michigan, South Carolina and Tennessee cap serious violations at $7,000 and willful or repeated ones at $70,000; New Mexico, Utah and Virginia publish caps just below federal. Check your state.
How abatement and documentation reduce the penalty
Penalties are commonly reduced at an informal conference (29 CFR 1903.19). Under the OSHA Field Operations Manual (CPL 02-00-164 Ch.6 (rev. July 14, 2025)), a serious / other-than-serious gravity-based penalty is reduced by company size, then by good faith (up to 25% for a documented written program) and history (20% for a clean 5-year record). The size reduction alone:
| Company size | Size penalty reduction |
|---|---|
| 11–25 | −70% |
| 26–100 | −30% |
| 101–250 | −10% |
| 251+ | −0% |
Source: OSHA Field Operations Manual, CPL 02-00-164 Ch.6 (rev. July 14, 2025), Table 6-2. Repeated violations receive the size reduction only; willful violations use a separate schedule and get no good-faith credit. Bring dated abatement evidence and your size/good-faith/history documentation to the conference.
Worked examples
1. Serious HazCom citation, 22-employee drywall contractor, open case. The citation sets a 20-day abatement date for unlabeled secondary containers and a missing written program. The plan calendars the 15-working-day contest deadline, posts the citation (1903.16), and assigns immediate actions (label all containers, restore SDS access), a one-week task (refresh training, collect sign-in sheets), and a 30-day task (recurring SDS review). After abatement, the contractor certifies in writing within 10 days (1903.19(c)). At the informal conference the 22-employee size band supports up to a 30% size reduction plus good-faith credit for the now-documented program.
2. Missed abatement date. A contractor lets a serious fall-protection abatement date pass uncorrected. Each day past the deadline accrues a Failure-to-Abate penalty of up to $16,550 (1903.15(d)(5)); even with the FOM’s usual ~30-day cap, that is roughly $496,500 on top of the original citation. The plan flags this as a critical item: correct, photograph, and certify immediately to stop the accrual.
What to do next
- Calendar the contest deadline first — 15 working days from receipt of the citation (29 CFR 1903.15). After that it becomes a final order.
- Post each citation at or near the cited location until abated, or 3 working days, whichever is longer (29 CFR 1903.16).
- Abate promptly and document it with dated photos, receipts, and signed records — this is the strongest penalty-reduction lever and it prevents a Failure-to-Abate penalty of up to $16,550/day.
- Certify abatement in writing within 10 calendar days of each abatement date (29 CFR 1903.19(c)).
- Prepare for the informal conference with abatement evidence and your size / good-faith / history documentation. Requesting it does not stop the contest clock.
Frequently asked questions
What should I do right after an OSHA inspection?
Document everything immediately: photograph the cited conditions, gather your written programs and training records, and begin correcting obvious hazards. Read your Citation and Notification of Penalty closely — it lists each cited standard and a specific abatement date. Post each citation at or near the cited location (29 CFR 1903.16) and start a corrective-action log with an owner and due date for every item. You have 15 working days from receipt to contest, so calendar that deadline first.
How long do I have to fix (abate) an OSHA violation?
Each citation item lists its own abatement date — there is no single universal period. Serious hazards are often set at 15–30 days, but the date is whatever the Area Director assigns. You must complete the correction by that date and, within 10 calendar days afterward, certify the abatement to OSHA in writing (29 CFR 1903.19(c)). If a correction will take longer than 90 calendar days, an abatement plan may be required (29 CFR 1903.19(e)).
What is a Failure-to-Abate (FTA) penalty?
If you miss the abatement date, OSHA can assess a Failure-to-Abate penalty of up to $16,550 for EACH day the violation continues past the deadline (29 CFR 1903.15(d)(5)). In practice the Field Operations Manual normally caps the total at roughly 30 times the daily amount for the initial assessment, but that still turns a single missed deadline into a six-figure exposure. Completing and certifying abatement on time is the single most important way to control inspection cost.
Does requesting an informal conference stop the contest clock?
No. Requesting an informal conference does NOT stay the 15-working-day Notice-of-Contest deadline (29 CFR 1903.20). If that deadline is near, file a protective Notice of Contest in writing as well — otherwise the citation, penalty, and abatement date become a final order that cannot be appealed.
What documents does OSHA ask for after an inspection?
Common requests include written safety programs (HazCom, Fall Protection, Respiratory Protection, LOTO), training records with sign-in sheets, equipment inspection logs, SDS/chemical inventories, competent-person designations, and dated corrective-action records. The Evidence Pack this tool generates lists the universal items plus the documents specific to each violation topic you select.
Can fixing the hazard reduce my penalty?
Prompt, documented abatement is the strongest lever for a reduced penalty at the informal conference, and it prevents an FTA penalty entirely. Bring dated abatement evidence plus your size, good-faith, and history reduction documentation. Under the Field Operations Manual (CPL 02-00-164 Ch.6 (rev. July 14, 2025)), a serious/other-than-serious gravity-based penalty can be reduced by up to 70% for size, up to 25% for a documented written program, and 20% for a clean 5-year history.
Is this action plan legal advice?
No. This tool produces a planning template based on common OSHA inspection procedures and the cited deadlines. It is not legal advice and does not certify that any specific correction satisfies a particular cited standard. For a contested citation or a complex case, consult a qualified safety professional or attorney. State-Plan states may set different procedures and penalty amounts.
Sources & verification
- https://www.osha.gov/memos/2026-05-21/2026-annual-adjustments-osha-civil-penalties
- https://www.osha.gov/penalties
- https://www.osha.gov/fom/chapter-6
- OSHA citation, abatement & contest procedures — 29 CFR 1903.15, 1903.16, 1903.17, 1903.19, 1903.20.
- OSHA Field Operations Manual, CPL 02-00-164 Ch.6 (rev. July 14, 2025) (penalty calculation & reductions).
Regulatory facts verified 2026-10-05 against eCFR, OSHA.gov, and the Federal Register. This tool produces a planning template; it is an estimate for planning only and is not legal advice or a prediction of any specific citation outcome.
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