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OSHA Compliance Checklist for Small Business

Three documents and three sheets that test your company-wide size, each location's own industry code and any state mandate separately, not as one national answer.

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What you get

Pack of 6 files: 3 documents, 3 spreadsheets

OSHA Compliance Checklist for Small Business
  • Requirement RegisterSpreadsheet
  • Required Postings ListDocument
  • Safety ProgrammeDocument
  • Training and Inspection LogSpreadsheet
  • Incident ProcedureDocument
  • Incident RegisterSpreadsheet
RiverOSHA Compliance Checklist for Small Business

Requirement Register

[Company], Inc. — every location, tested on its own terms

Size is tested company-wide. Industry is tested location by location. A national checklist has room for one answer; a location can need two different ones.

LocationNAICS CodeSize Test (Company-Wide)Industry Test (This Location)Recordkeeping Required?
—————
—————
—————

Two tests, answered separately, for the same location

One national checklistOne yes-or-no answer to whether you keep the log, read the same at every location a company has
Requirement RegisterThe company-wide size test and this location's own industry test, answered separately, since either one alone can exempt or reach a location the other doesn't

A location can fail the size exemption because the company around it is large, and still clear the industry exemption on its own NAICS code, or the reverse. A checklist with one row per company cannot hold both answers at once.

"Do I have to keep the OSHA log" sounds like one question with one answer, and most checklists treat it that way. It is actually three separate tests, answered separately, and a business with more than one location can land on different answers at different addresses from the same facts. The size exemption is tested against a company's entire headcount, not any single location's, so a company with more than 10 employees company-wide owes the log everywhere, including a 3-person site that would clear the exemption alone.

Harrow & Vale Custom Cabinetry, a fictional cabinetry business, runs three locations that answer these tests three different ways. Its design studio in downtown Columbus, Ohio carries 7 employees under NAICS code 5414. Its production workshop eight miles away in Groveport, Ohio carries 21 under NAICS 337110. A 5-person install and service crew it opened in Sacramento, California in 2025 carries NAICS 238350. Company-wide headcount is 33, which fails the 10-employee size exemption everywhere, including at the 5-person crew, whose own headcount would have cleared that exemption alone.

The industry test runs the opposite direction. It is decided establishment by establishment, not company-wide. NAICS 5414 sits on the federal recordkeeping exemption list, so the design studio owes no injury and illness log at all. NAICS 337110 and 238350 do not, so the workshop and the Sacramento crew both keep one despite failing the size test too. Sacramento then adds a third, state-only layer with no size or industry exemption: a written safety programme every California employer must maintain, and its own posted notice in place of the federal one.

Every sheet in the pack, filled in for one business

Requirement Register, Training and Inspection Log, Incident Register and Required Postings List, worked through for one company.

OSHA Compliance Checklist for Small Business
RiverRequirement Register

Requirement Register

Harrow & Vale Custom Cabinetry. Company-wide 2025 peak headcount: 33.

LocationNAICS CodeSize Test (Co-Wide)Industry TestRecordkeepingState Overlay
Design Studio, Columbus OH5414Fails, 33 co-wideExempt, Appendix ANoNone
Production Workshop, Groveport OH337110Fails, 33 co-wideNot exemptYesNone
Sacramento Install Crew238350Fails co-wide; 5 alone would passNot exemptYesCA IIPP + CA poster

The Sacramento crew is the sharpest row: its own 5 employees would clear the size exemption alone, but the test runs against the 33-employee company around it, and it owes a state programme neither Ohio location does.

RiverTraining and Inspection Log

Training and Inspection Log

4 of 9 rows shown: the two currently overdue, plus their context.

LocationItemStatusNotes
Production WorkshopMonthly self-inspectionCurrentOne expired extinguisher tag replaced the same day
Production WorkshopPowered industrial truck operator evaluationOverdueTwo operators due for re-evaluation
Sacramento CrewNew-equipment inspection and training, powered scissor liftOverdueDue since 2026-05-01, the day the lift went into service
Sacramento CrewWeekly jobsite safety walkCurrentNo findings the week checked

The scissor lift row is the one a calendar-based checklist cannot show: nothing was ever scheduled for it, so it never became overdue on any date a reminder would fire on.

RiverIncident Register

Incident Register

All 3 incidents on file.

LocationWhat HappenedRecordable?Reportable?
Production WorkshopTable saw kickback, sutured lacerationYes, sutures are medical treatmentNo
Sacramento CrewStepladder fall, overnight hospital admissionYesYes, both federal and Cal/OSHA
Design StudioBox cutter nick, bandage onlyNo, first aid onlyNo

The stepladder fall is the only row reportable on a clock, and it is reportable on two separate channels at once because Sacramento owes both the federal report and California's own.

RiverRequired Postings List

Required Postings List, excerpt

Which notice, at which location.

Design Studio and Production Workshop, Ohio. Federal "Job Safety and Health: It's the Law" poster. Ohio runs no OSHA-approved state plan, so the federal notice is the only one either location posts.
Sacramento Install Crew, California. California's own "Safety and Health Protection on the Job" notice. California runs its own approved plan, so its state notice replaces the federal one at this location rather than sitting alongside it.

Same company, three locations, two different posters, and the federal poster is the wrong one to print for the third.

Edit with AI

What's in the pack

01

Requirement Register

Every location run through the size test, the industry test and any state overlay separately, with the specific basis for each answer rather than one national conclusion. An obligation triggered by headcount, revenue or a new state instead of a physical location belongs in the industry compliance checklist instead.

02

Required Postings List

What goes on the wall at each location, matched to that location's own recordkeeping status and its state, since a location in a state with its own approved plan posts that state's notice instead of the federal one, not both. A required licence or permit posting, rather than a safety notice, is tracked in the licence and permit pack's own sequencing instead.

03

Safety Programme

The hazard-specific programs your actual equipment and materials require, plus any state's own written injury and illness prevention mandate layered on top, reviewed again the day new equipment or a new hazard actually shows up.

04

Training and Inspection Log

Every recurring training and inspection date, plus a separate column for whatever new equipment or process triggered its own inspection outside the calendar. Once every item here is current, the recurring dates move to the compliance calendar instead.

05

Incident Procedure

What actually counts as first aid versus medical treatment, and the separate clock for reporting a fatality, hospitalization, amputation or eye loss that runs regardless of whether a location keeps a log at all.

06

Incident Register

Every incident logged with its recording determination and its reporting determination stated separately, so a stitched laceration and a stepladder fall requiring overnight admission read as the two different findings they actually are. Proving the insurance coverage behind a claim is the next document that incident usually needs.

How to use it

  1. 1

    Open in River, or download it

    Install the pack so the agent runs all three tests against your real locations, or take the blank Word and CSV files away and fill them in yourself.

  2. 2

    Send every location, not just offices

    Every address with even one employee, the headcount there, and what the work actually is, specific enough to assign a real NAICS code to each one.

  3. 3

    See what each location actually owes

    The size test run once against your whole company, the industry test run separately for each location's own NAICS code, and any state overlay flagged where it applies with no exemption of its own.

  4. 4

    Track what's overdue, not just what's due

    A new-hazard trigger gets flagged from the date the equipment or process changed, not from the next date on a calendar, so it doesn't sit invisible until an inspector finds it first.

Frequently asked questions

Is this template free?

Yes. Three documents and three sheets download as Word and CSV files with no signup and no credit card. "Edit with AI" is a separate, optional path for founders who want the agent to run all three tests against their own locations. The rest of the packs sit in the template library.

What format are the downloaded files?

Word documents (.docx) for the three narrative documents, and CSV (.csv) for Requirement Register, Training and Inspection Log and Incident Register, zipped together. They open natively in Word, Pages, Google Docs, Excel, Numbers and Sheets, with nothing to convert.

What does 'Edit with AI' actually do?

It creates a free River account and installs this exact pack as a private workspace. The agent asks about every location where you have even one employee, works out each one's NAICS code, then runs the size test, the industry test and any state overlay separately.

Does a small headcount at one location ever exempt it from a state's own safety programme mandate?

No, and this is the specific confusion the size exemption invites. California requires every employer to maintain a written injury and illness prevention program with no size exemption at all, though a location under 10 employees may document several of its elements more lightly rather than skip them.

Does a location's federal recordkeeping exemption cover its posting duty too?

No, and this is the second most common gap. The federal safety notice is required at every location regardless of size or industry, and a location in a state running its own approved plan posts that state's own notice instead, not in addition to skipping either one.

Do I still need a lawyer or safety consultant?

For a citation, a serious incident, or a first location in a new state, yes, and this is not legal advice. What changes is what you hand them: a register stating which test each location passed or failed and why. Responding to a citation once one arrives is separate, time-boxed work this pack does not do.

Sources

  1. eCFR29 CFR 1904.1 — Partial exemption for employers with 10 or fewer employees (opens in a new tab)
  2. eCFR29 CFR 1904.2 — Partial exemption for establishments in certain industries (opens in a new tab)
  3. California DIRCalifornia Code of Regulations, Title 8, Section 3203. Injury and Illness Prevention Program (opens in a new tab)
  4. eCFR29 CFR 1903.2 — Posting of notice; availability of the Act, regulations and applicable standards (opens in a new tab)

Written by

Chandler Supple

Co-founder & CEO, River

Chandler has spent the last six years working in AI, building tools for millions of users and Fortune 100 companies. In 2025, he co-founded River to build a new kind of operating system for AI agents.

LinkedInGitHubX

Reviewed by

Brian Joseff, Co-founder, River

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Find out what each of your locations actually owes

Download the blank pack as Word and CSV files, or open it in River and have your own locations run through all three tests at once.

Edit with AI