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OSHA RESOURCE GUIDE
Not every state follows federal OSHA. Here is what that means for your safety program.

OSHA Safety Program Requirements by State

The United States does not have a single unified OSHA enforcement system. Twenty-two states and several territories operate their own OSHA-approved state plans with their own agencies, rules, and penalties. If you work in one of these states — or move between federal and state-plan states — you need to know which rules apply.

Federal OSHA vs. state plans: the basics

The Occupational Safety and Health Act of 1970 created federal OSHA within the U.S. Department of Labor to set and enforce workplace safety standards across the country. However, Section 18 of the Act allows individual states to develop and operate their own occupational safety and health programs — known as state plans — as long as those programs are "at least as effective" as federal OSHA.

When a state operates an approved state plan, the state agency (not federal OSHA) is the primary enforcement authority for covered workplaces. Federal OSHA monitors state plans for continued effectiveness but does not conduct routine inspections in state-plan states (with limited exceptions).

What "at least as effective" means

State plans must adopt standards that are at least as protective as federal OSHA standards, maintain comparable enforcement procedures, and provide adequate funding and staffing. However, state plans are allowed to go beyond federal requirements — they can adopt stricter standards, set higher penalties, or regulate hazards that federal OSHA does not cover. This is why contractors working across state lines need to understand the differences.

Two types of state plans

  • Complete state plans cover both private-sector and state/local government employees. These states handle all OSHA enforcement within their borders.
  • Public-employee-only state plans cover only state and local government workers. Private-sector enforcement remains under federal OSHA. These states include Connecticut, Illinois, Maine, New Jersey, New York, and the U.S. Virgin Islands.

For contractors, the distinction matters: if you work in a public-employee-only state-plan state, your safety requirements and inspections still come from federal OSHA. The state plan only applies to government employees.

Complete state-plan states (private + public sector)

The following 22 states operate complete OSHA state plans covering both private-sector and public-sector employees. These states handle inspections, citations, and enforcement through their own agencies:

  • Alaska — Alaska Occupational Safety and Health (AKOSH), Department of Labor and Workforce Development. Alaska compliance hub
  • Arizona — Arizona Division of Occupational Safety and Health (ADOSH), Industrial Commission of Arizona. Arizona compliance hub
  • California — California Division of Occupational Safety and Health (Cal/OSHA), Department of Industrial Relations. Known for standards that exceed federal OSHA in many areas, including heat illness prevention, injury and illness prevention programs (IIPP), and aerosol transmissible diseases. California compliance hub
  • Hawaii — Hawaii Occupational Safety and Health (HIOSH), Department of Labor and Industrial Relations. Hawaii compliance hub
  • Indiana — Indiana Occupational Safety and Health Administration (IOSHA), Department of Labor. Indiana compliance hub
  • Iowa — Iowa Division of Labor, Iowa Occupational Safety and Health (IOSH). Iowa compliance hub
  • Kentucky — Kentucky Occupational Safety and Health (Kentucky OSH), Labor Cabinet. Kentucky compliance hub
  • Maryland — Maryland Occupational Safety and Health (MOSH), Department of Labor. Maryland compliance hub
  • Michigan — Michigan Occupational Safety and Health Administration (MIOSHA), Department of Labor and Economic Opportunity. Michigan compliance hub
  • Minnesota — Minnesota Occupational Safety and Health Administration (MNOSHA), Department of Labor and Industry. Minnesota compliance hub
  • Nevada — Nevada Occupational Safety and Health Administration (Nevada OSHA), Department of Business and Industry. Nevada compliance hub
  • New Mexico — New Mexico Occupational Health and Safety Bureau (OHSB), Environment Department. New Mexico compliance hub
  • North Carolina — North Carolina Occupational Safety and Health Division (NC OSH), Department of Labor. North Carolina compliance hub
  • Oregon — Oregon Occupational Safety and Health (Oregon OSHA), Department of Consumer and Business Services. Known for additional fall protection and heat illness prevention standards. Oregon compliance hub
  • South Carolina — South Carolina Occupational Safety and Health (SC OSHA), Department of Labor, Licensing and Regulation. South Carolina compliance hub
  • Tennessee — Tennessee Occupational Safety and Health Administration (TOSHA), Department of Labor and Workforce Development. Tennessee compliance hub
  • Utah — Utah Occupational Safety and Health Division (UOSH), Utah Labor Commission. Utah compliance hub
  • Vermont — Vermont Occupational Safety and Health Administration (VOSHA), Department of Labor. Vermont compliance hub
  • Virginia — Virginia Occupational Safety and Health (VOSH), Department of Labor and Industry. Known for its COVID-era permanent standard and heat illness prevention requirements. Virginia compliance hub
  • Washington — Washington Division of Occupational Safety and Health (DOSH), Department of Labor and Industries. Known for stricter standards on fall protection, heat exposure, wildfire smoke, and ergonomics. Washington compliance hub
  • Wyoming — Wyoming Occupational Health and Safety (WY OSHA), Department of Workforce Services. Wyoming compliance hub

Note: Puerto Rico and the U.S. Virgin Islands also operate state plans. Puerto Rico covers private and public sectors; the U.S. Virgin Islands covers public employees only.

Public-employee-only state plans

The following states operate state plans that cover only state and local government employees. Private-sector employers in these states are covered by federal OSHA:

  • Connecticut — Connecticut Occupational Safety and Health Division (CONN-OSHA)
  • Illinois — Illinois Occupational Safety and Health Division (IL OSHA)
  • Maine — Maine Bureau of Labor Standards
  • New Jersey — New Jersey Public Employees Occupational Safety and Health (PEOSH)
  • New York — New York Public Employee Safety and Health Bureau (PESH)

If you are a private contractor in any of these states, federal OSHA is your enforcement authority. Your safety program should follow federal OSHA standards as the baseline.

Federal OSHA states

All remaining states — including Texas, Florida, Georgia, Pennsylvania, Ohio, and others — do not operate their own OSHA programs. In these states, federal OSHA is the sole enforcement authority for private-sector employers. Federal standards under 29 CFR Parts 1910 (general industry) and 1926 (construction) apply directly.

What this means for contractors

Working in a single state

If you work exclusively in one state, determine whether it is a federal-OSHA state or a state-plan state. In a state-plan state, identify the state agency and check whether it has adopted any standards that exceed federal OSHA. Your written safety program should reference the applicable state standards, not just federal OSHA.

Key areas where state plans commonly differ from federal OSHA:

  • Injury and illness prevention programs (IIPP). California requires all employers to maintain a written IIPP under Cal/OSHA Title 8, Section 3203. Several other state-plan states encourage or require similar programs, even though federal OSHA does not currently mandate a comprehensive IIPP for all employers.
  • Heat illness prevention. California (Title 8, Section 3395), Washington (WAC 296-62-095), Oregon (OAR 437-002-0156), and Virginia have adopted specific heat illness prevention standards. Federal OSHA has proposed but not yet finalized a heat standard as of 2026.
  • Fall protection trigger heights. Most state plans follow the federal 6-foot trigger height for construction (29 CFR 1926.501), but some states have different thresholds for specific activities or industries.
  • Reporting requirements. Some state plans have additional reporting requirements beyond the federal 8-hour fatality and 24-hour hospitalization rule.
  • Penalty amounts. State plans must set penalties at least as high as federal OSHA, but some states impose higher penalties. For current federal penalty amounts, see our 2026 OSHA fines and penalties guide.

Working across state lines

Contractors who work in multiple states face an additional challenge: the safety program that meets requirements in one state may not meet requirements in another. For example, a roofing contractor based in Texas (federal OSHA state) who takes a job in California (Cal/OSHA state-plan state) needs to comply with California's IIPP, heat illness prevention, and potentially other Cal/OSHA-specific requirements that do not exist under federal OSHA.

Best practice for multi-state contractors:

  • Build your baseline safety program around federal OSHA standards.
  • Add state-specific supplements for each state-plan state where you work.
  • Review state-plan requirements before mobilizing to a new state — not after arriving on site.
  • Keep training records that document compliance with both federal and state-specific requirements.

Multi-employer construction sites

On construction sites with multiple employers, the OSHA multi-employer citation policy (CPL 02-00-124) applies in both federal and state-plan states. General contractors, subcontractors, creating employers, exposing employers, correcting employers, and controlling employers can all be cited. For details on how this works during an inspection, see our contractor guide to OSHA inspections.

How CrewCompliance handles state differences

CrewCompliance safety documentation is tailored to your state. When you go through the questionnaire, we ask for your state and build your written safety program around the applicable requirements — whether that is federal OSHA or a state-plan agency. For state-plan states like California, Washington, and Oregon, the documentation includes state-specific sections addressing requirements that go beyond federal OSHA.

We do not claim that any safety documentation product guarantees compliance with OSHA or state-plan requirements. Contractors remain responsible for verifying that their documentation accurately reflects their actual work, hazards, and applicable regulations. For complex or high-hazard work, a qualified safety professional should review site-specific plans.

State-specific safety documentation, built for your state.

Tell us your state, trade, and crew size — we build the written safety program around what applies to you. Flat $149, no subscription.

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