The start of 2026 means fresh budgets, updated safety priorities, and renewed focus on workplace operations. But it also marks a period when certain OSHA requirements routinely catch employers off-guard. Between recordkeeping tasks, reporting expectations, and shifting enforcement priorities, Q1 can quickly become a high-risk compliance window for organizations that aren’t prepared.
This playbook outlines the OSHA requirements employers most frequently overlook early in the year and how safety and HR teams can stay ahead.
1. Injury & Illness Recordkeeping Requirements
Recordkeeping is one of the most common sources of Q1 compliance gaps. Many employers enter the new year with incomplete logs, outdated information, or misclassified injuries from the prior year.
Common challenges include:
- Forgetting to update OSHA 300, 300A, or 301 forms
- Incorrect or inconsistent total hours worked
- Misclassification of injuries or illnesses
- Not reviewing logs regularly throughout the year
Recordkeeping failures often lead to avoidable citations, especially during inspections triggered by incidents or employee complaints.
2. Reporting of Serious Workplace Incidents
Timely reporting of severe injuries is an area where employers frequently make mistakes. Confusion often arises around what qualifies as reportable and how quickly OSHA must be notified.
Common issues:
- Misunderstanding what constitutes a “reportable” incident
- Delays when incidents occur after hours or on weekends
- New managers or seasonal staff unfamiliar with reporting rules
- Uncertainty about who is responsible for contacting OSHA
Even when the incident is handled quickly onsite, reporting delays can result in increased scrutiny.
3. National Emphasis Programs and Evolving Enforcement Focus
OSHA’s National Emphasis Programs (NEPs) highlight specific hazards or industries that will receive heightened inspection attention. While NEPs change over time, employers are often surprised to learn they fall within a targeted category.
Industries or hazards that frequently appear in NEPs include:
- Heat illness prevention
- Warehousing and logistics operations
- Respirable crystalline silica
- Fall hazards in construction
- High injury-rate workplaces
Because NEPs can trigger unannounced inspections, employers may not realize they’re covered until inspectors arrive.
4. Respiratory Protection & Fit Testing Requirements
Respiratory protection remains one of OSHA’s most frequently cited standards. Early each year, organizations often uncover gaps related to:
- Missed annual fit tests
- Outdated or incomplete written respiratory programs
- Insufficient medical evaluations
- Lack of documentation for voluntary-use respirators
These issues often persist unnoticed until an inspection or internal audit surfaces them.
5. Training Requirements That Reset Annually
Although not every OSHA standard requires annual training, many workplaces follow recurring training cycles based on best practices, industry expectations, or company policy.
Training that commonly slips in Q1 includes:
- Lockout/tagout (LOTO) evaluations
- Hazard Communication (HazCom) refreshers
- Bloodborne pathogens training
- Powered industrial truck training
- Emergency response and evacuation reviews
Delaying required or expected training early in the year can create gaps that persist into peak work seasons.
6. Hazard Communication Updates & SDS Management
HazCom compliance issues frequently emerge in Q1, especially as employers update safety data sheets (SDSs), labels, and written programs to reflect any new chemicals or processes introduced over the past year.
Common pitfalls:
- Incomplete or outdated SDS libraries
- Missing or inconsistent labeling
- Employees not trained on newly introduced materials
- Written HazCom programs not updated after workplace changes
These issues frequently appear during inspections or internal reviews.
7. Heat, Ergonomics & Workplace Violence Prevention
Even though not all of these areas have standalone standards, OSHA often cites them through the General Duty Clause. Q1 is a key time to assess these risks because issues often linger unnoticed until workloads increase later in the year.
Frequent concerns include:
- Ergonomic risks in warehousing, manufacturing, and distribution
- Behavioral health and workplace violence vulnerabilities
- Early planning for heat illness prevention programs
Employers often underestimate OSHA’s willingness to cite these issues when they pose clear hazards.
How Employers Can Strengthen Q1 Compliance
A proactive approach early in the year can significantly reduce risk. Consider focusing on:
- Reviewing injury and illness logs for accuracy
- Refreshing training schedules and identifying overdue topics
- Updating written safety programs and procedures
- Confirming responsibility for incident reporting
- Auditing documentation across safety program areas
Q1 sets the tone for the entire compliance year. Organizations that front-load their safety and compliance efforts often experience fewer surprises and stronger inspection outcomes. A good start would be joining host Nurse Holly Foxworth for Your 2026 OSHA Playbook: Turning Compliance Into Competitive Advantage, featuring Chief Medical Officer Dr. Scott Cherry, Chief Marketing Officer Dara Wheeler, and special guest Tom West, Vice President & Global Practice Leader at MakuSafe, who will share firsthand knowledge about what to watch our for when it comes to OSHA compliance.