OSHA State comparison.xlsx

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1	OSHA State Plan Comparison Cheat Sheet																						© 2025 Steven Shaw – All rights reserved
2	Feature	Federal OSHA	Cal/OSHA (California)	WA DOSH (Washington)	Michigan (MIOSHA)	Oregon OSHA	Nevada (Nevada OSHA)	Tennessee (TOSHA)	NJ Public Employees OSHA	IL OSHA (Illinois)	SC OSHA (South Carolina)	IN OSHA (Indiana)	KY OSH (Kentucky)	VT OSHA (Vermont)	NC OSH (North Carolina)	MD OSHA (Maryland)	IA OSHA (Iowa)	AZ OSHA (Arizona)	NM OSHA (New Mexico)	MN OSHA (Minnesota)	CT OSHA (Connecticut)	AKOSH (Alaska)	PR OSHA (Puerto Rico)
3	Jurisdiction	Private sector workers; federal employees	Private + all public sector employees	Private + all public sector employees	All private and public sector employees	All private and public sector employees	Private sector and all state/local government employees	Private sector and all public sector (state/local) employees	Only apply to public employees.	Only apply to public employees.	Private + all public sector employees	Private + public sector employees	Private + public sector employees	Private + public sector employees	Private + public sector employees	Private + public sector employees	Private + public sector employees	Private + public sector employees	Private + public sector employees	Public and private sector employees	Only apply to public employees.	Private + public sector employees	Private + public sector employees
4	Enforcing Agency	U.S. Department of Labor	California Department of Industrial Relations	Washington State Department of Labor & Industries (L&I)	Michigan Occupational Safety and Health Administration (MIOSHA)	Oregon Occupational Safety and Health Division (OR-OSHA)	Nevada Department of Business and Industry, Division of Industrial Relations	Tennessee Department of Labor and Workforce Development (TOSHA Division)	NJ Department of Labor and Workforce Development	IL Department of Labor	SC Department of Labor, Licensing & Regulation	Indiana Department of Labor (IDOL)	Kentucky Labor Cabinet	Vermont Department of Labor	NC Department of Labor	Maryland Department of Labor	Iowa Division of Labor Services	Arizona Division of Occupational Safety and Health (ADOSH)	New Mexico Environment Department, OSHB	Minnesota Department of Labor and Industry, MNOSHA	Connecticut Department of Labor	Alaska Department of Labor and Workforce Development	Puerto Rico Department of Labor and Human Resources
5	Written Safety Programs Required	Generally not required for all industries	Yes – Injury & Illness Prevention Program (IIPP) required	Yes – Accident Prevention Program (APP) required	Required – must include hazard communication and emergency procedures	Required – must consist of a safety committee or representative	Required for employers with 11+ employees or in hazardous industries	Yes – Employers must have a written safety program	Required for public agencies	Required for public sector employers	Yes – Required for General Industry and Construction	Required for general industry and construction	Required – especially in construction	Required – especially in high-risk sectors	Required – Accident Prevention Program (APP)	Yes – general and industry-specific requirements	Yes – encouraged but not always mandatory	Yes – required for certain industries	Yes – required for general industry and construction	Yes – AWAIR Program required for certain employers	Required for public employers	Required – especially in high-hazard industries	Required – especially in high-risk sectors
6	Permissible Exposure Limits (PELs)	Based on outdated 1970s data	Often stricter (e.g., silica, lead, noise)	Similar to Cal/OSHA – more stringent in some areas	Similar to federal, with some state-specific limits (e.g., noise, lead)	Often stricter than federal PELs (e.g., silica, manganese)	Often adopts stricter standards (e.g., crystalline silica, noise)	Largely follows federal standards	Follows Federal OSHA	Follows Federal OSHA	Follows Federal OSHA limits	Follows Federal OSHA	Follows Federal OSHA	May adopt stricter limits depending on industry	Mostly mirrors federal, minor state-specific limits	Follows federal PELs	Same as federal OSHA	Same as federal, though stricter for certain exposures	Same as federal unless NM adopts stricter limits	Enforces the stricter 1989 PELs. This makes it more protective than federal in many cases.	Follows federal PELs	Same as federal, with some stricter standards (e.g., cold exposure)	Same as federal OSHA
7	Heat Illness Prevention Standard	No federal standard (as of 2025)	The indoor heat rule (T8CCR §3396) went into effect in July 2024. Some spreadsheets or notes may still list only the outdoor rule.	Adopted permanent indoor heat rules in 2024, in addition to its outdoor standard.	No formal standard; general duty clause applies	Yes – comprehensive rule including planning, training, shade, and water	A new regulation was adopted in late 2024 (R131-24AP), requiring workplace heat illness prevention. Ensure it’s marked as “active.”	No specific rule; enforced under General Duty Clause	No specific rule	No specific rule	No standalone rule, general duty applies	No specific rule, relies on general duty	No specific rule	No specific rule	No specific rule	No state-specific standard	No specific standard	Yes – general duty + enforcement guidance	Drafting rules; applies general duty clause	Enforced under General Duty Clause; active outreach	No state-specific standard	General duty + guidance due to extreme cold/heat environments	Draft guidance based on tropical conditions
8	Workplace Violence Regulation	No comprehensive rule (guidance only)	Yes – healthcare-specific violence prevention	Draft rules in progress (for healthcare)	Guidelines only – no formal standard	Draft rules underway; guidance exists for certain sectors	No formal rule, but enforced under General Duty Clause	No state-specific rule; general duty clause enforcement	Required for certain public healthcare settings	No comprehensive rule	No comprehensive rule	No comprehensive rule	Guidance provided; no formal regulation	Healthcare guidance only	Draft healthcare rule under consideration	Guidance only	Guidance only	Developing healthcare-specific guidelines	Proposed rule in progress	Healthcare-specific prevention plan required (nursing homes, etc.)	Guidance only	Guidance; targeted focus in healthcare	Limited guidance; some programs in healthcare
9	Penalties (as of 2025)	~$16,000 per serious violation (adjusts annually)	Can exceed $25,000 per serious violation	Similar to Cal/OSHA; state adjusts independently	Up to $7,000 per serious violation; up to $70,000 for willful/repeat	Similar to federal – adjusted annually	Can exceed federal limits; includes daily penalties for failure to abate	Same as federal	Same as Federal for public employers	Same as Federal for public employers	Similar to Federal (adjusts annually)	Mirrors Federal maximums (updated annually)	Similar to Federal	Matches Federal levels	Slightly higher base fines than Federal	Similar to federal OSHA	Same as federal	Similar to federal OSHA	Matches federal penalty schedule	Matches or exceeds federal amounts depending on severity	Matches federal penalties	Matches or exceeds federal; subject to Alaska adjustment	Follows federal penalty levels
10	Reporting Requirements	Severe injury: 24 hrs; fatality: 8 hrs	Same, but stricter enforcement	Same, strict enforcement	Same as federal	Same as federal	Same as federal	Same	Mirrors Federal, stricter follow-up	Same as Federal	Same as Federal (8 hrs fatality / 24 hrs inpatient hospitalization)	Same as Federal (8/24 hr standard)	Mirrors Federal standards	Follows Federal	Same as Federal	Fatality: 8 hrs; serious injury: 24 hrs	Same as federal	Same as federal	Same as federal OSHA	Same as federal OSHA	Same as federal OSHA	Same as federal OSHA	Same as federal OSHA
11	Fall Protection Trigger Height	6 ft (general industry/construction)	4 ft fall protection trigger in general industry should be highlighted more clearly (T8CCR §3210), as it's stricter than federal.	Often 4 ft in construction (stricter than federal)	Same – strict enforcement in construction	Often 6 ft, but includes stricter rules for ladder use and roofing	6 ft standard with stricter construction enforcement	No formal ergonomics regulation	6 ft construction / 4 ft general industry	6 ft construction / 4 ft general industry	6 ft (construction); 4 ft (general industry)	6 ft (construction); 4 ft (general industry)	6 ft standard	6 ft in construction	4 ft for construction (stricter than Federal)	6 ft (same as federal)	6 ft	6 ft; stricter enforcement in construction	6 ft general; 4–6 ft in some industries	6 ft; additional state-specific fall protection rules apply	6 ft (applies to public works projects)	6 ft; may be stricter in slippery or elevated worksites	6 ft; construction heavily enforced
12	Ergonomics Standard	Repealed in 2001	Stronger guidance and limited enforcement	Some industry-specific rules (e.g., agriculture)	Ergonomic evaluation encouraged; no formal rule	Required for high-risk industries; mandatory assessments and corrections	Encouraged; no formal rule except in casinos and hospitality	Based on 29 CFR 1926 with additional Tennessee modifications	No formal rule	No formal rule	No formal rule; voluntary guidance	Voluntary programs encouraged	No formal rule	Guidance for healthcare and office settings	No formal rule	No specific standard	No standard	Guidance for office environments	Guidance only	Ergonomics rule rescinded, but industry-specific guidelines in place	Guidance only	Stronger focus on fisheries, seafood processing	General guidance; no specific rule
13	Construction Standards	Based on Subparts from 29 CFR 1926	Includes additional California-specific rules	WAC Chapter 296-155 applies for construction	Part 1–50 of Michigan Construction Safety Standards	Division 3 of Oregon Administrative Rules	Adopts federal 1926 standards with state-specific additions	Prioritizes high-risk industries and complaint-based inspections	Based on 29 CFR 1926	Based on 29 CFR 1926	Based on 29 CFR 1926	Based on 29 CFR 1926	Based on 29 CFR 1926	Based on 29 CFR 1926	NC-specific additions to 1926 in some trades	Based on 29 CFR 1926	Follows federal construction standards	State-specific interpretations of 1926	Includes state supplements to federal rules	State supplements federal construction regulations	Follows federal for public works	Includes cold-weather and regional modifications to 29 CFR 1926	Includes minor Puerto Rico-specific amendments
14	Inspection Frequency	Limited resources – fewer proactive inspections	More proactive inspections & citations	Frequent inspections, especially high-risk sites	Frequent inspections for high-hazard industries	High frequency, especially in agriculture, construction, and manufacturing	High frequency in construction, casinos, and industrial operations	Prioritizes high-risk industries and complaint-based inspections	Targeted inspections in public sector	Targeted inspections of public agencies	Regular proactive inspections; focus on high-hazard industries	Moderate inspection activity, focused on high-risk industries	Moderate to high inspection activity	Small state = fewer inspections, but detailed enforcement	High inspection frequency, proactive in hazardous industries	Moderate inspection levels; public sector emphasis	Moderate; often complaint-driven	High frequency in high-risk industries	Active inspection program with emphasis on oil & gas	Higher inspection rates; state focuses on high-hazard industries	Low to moderate; limited to public sector	High – especially in oil, fishing, construction	Moderate; often focused on compliance education
15	Training Requirements	Requires training under specific standards (e.g., hazard communication, forklift use); Outreach Training Program (OSHA 10/30) is voluntary but widely used.	Mandatory safety training on IIPP topics, heat illness, ergonomics (for specific industries), and industry-specific hazards.	Requires documented training in APP, PPE, fall protection, and industry-specific topics; online training tools provided.	Requires training tailored to job duties; some state-specific courses provided by CET Division.	Mandatory training on hazard recognition, PPE, and job-specific risks; free training and consultation services available.	OSHA 10 or 30 required for all construction workers (NRS 618.980). Other job-specific training mandated.	Training must align with hazard exposure; state provides free materials.	Requires employee awareness training; offers extensive free public sector training through NJ PEOSH program.	For public employees only. Requires training on hazard awareness and safety procedures.	Mirrors federal training expectations; consultation and education programs available.	Training based on hazard exposure; INSafe provides support and education programs.	Requires training in lockout/tagout, hazard communication, and job-specific risks; Kentucky OSH offers regional training events.	Training required per federal standards; Vermont’s VOSHA Project offers free education programs.	Mandatory hazard-specific training; NCDOL provides consultation and training resources.	Training aligned with federal OSHA; Maryland Occupational Safety and Health (MOSH) offers outreach and education.	Mirrors federal training rules; free assistance through Iowa OSHA Consultation and Education.	OSHA 10/30 required for construction (A.R.S. § 23-493). General training required based on exposure.	Training must match job hazards; state conducts training seminars and workshops.	Outreach and free training programs; required training must match job duties.	Public employers must train on workplace hazards and maintain documentation.	Follows federal training standards; provides targeted training to high-risk industries.	Requires training under federal and local standards; offers bilingual safety training programs.
16	Notable Differences	Baseline for all programs; applies to private sector and some federal workers only.	Most comprehensive; stricter PELs, heat illness standard, workplace violence rule, injury prevention plan required.	APP required, ergonomics guidance, strong inspection program; lower fall protection thresholds.	Independent standards for ergonomics, lockout/tagout; frequent updates.	Stronger in agriculture and forest sectors; early heat and wildfire smoke standards.	Requires OSHA 10/30 cards; proactive inspections in construction.	Minor procedural differences; aligns closely with federal OSHA.	Public sector only; mandates training and hazard communication for government workers.	Public sector only; general alignment with federal OSHA.	Higher enforcement rates and quicker response to complaints.	Maintains close federal alignment; uses state-specific inspection priorities.	Extensive public training and support; frequent outreach programs.	Strong emphasis on public sector safety; uses customized compliance strategies.	Developed unique fall protection guidance and inspection priorities.	Strict training documentation requirements and local enforcement strategies.	Emphasizes construction safety; offers many local consultation services.	Mandates OSHA 10/30; proactive approach to site inspections.	Greater enforcement emphasis in oil/gas regions.	Applies different enforcement policies for small businesses and agricultural employers.	Covers only public sector; strong training and outreach focus.	Focused heavily on remote, high-risk workplaces; unique requirements for Arctic industries.	Includes culturally specific safety programs and bilingual enforcement tools.
17	Website / Contact Info	osha.gov	https://dir.ca.gov/dosh/	lni.wa.gov	michigan.gov/miosha	osha.oregon.gov	dir.nv.gov/OSHA	tn.gov/workforce	nj.gov/health/workplacehealthandsafety	https://labor.illinois.gov/laws-rules/safety.html	scosha.llronline.com	in.gov/dol	labor.ky.gov	labor.vermont.gov	labor.nc.gov	dllr.state.md.us	iowadivisionoflabor.gov	azica.gov	env.nm.gov	dli.mn.gov	https://portal.ct.gov/dol/divisions/conn-osha?language=en_US	labor.alaska.gov/lss	trabajo.pr.gov
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