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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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.
| Location | NAICS Code | Size Test (Company-Wide) | Industry Test (This Location) | Recordkeeping Required? |
|---|---|---|---|---|
| — | — | — | — | — |
| — | — | — | — | — |
| — | — | — | — | — |
Two tests, answered separately, for the same location
| One national checklist | One yes-or-no answer to whether you keep the log, read the same at every location a company has |
| Requirement Register | The 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.
What's in the pack
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.
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.
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.
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.
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.
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
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
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
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
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.
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