Annual OSHA Requirements for Contractors (Safety Guide) 2026

Contractors are required to follow both federal OSHA rules and, in NYC, additional local training and safety requirements, and many of these obligations repeat every year.

Who This Applies To

Most construction employers with at least 1 employee must comply with OSHA construction standards in 29 CFR 1926, and many must also follow OSHA recordkeeping rules in 29 CFR 1904.osha+1
NYC contractors also have to comply with NYC Department of Buildings (DOB) safety and worker training rules, including Local Law 196 Site Safety Training (SST) for certain job sites.pdhstar+1

Annual OSHA Recordkeeping Duties

Under OSHA’s injury and illness recordkeeping rule (29 CFR Part 1904), many construction companies must complete and maintain OSHA injury logs each year.ogletree+1
Key annual tasks include:

• Complete OSHA Form 300 Log and Form 301 Incident Reports for each recordable work-related injury or illness during the year, if your business is not exempt from recordkeeping.osha+1

• Prepare OSHA Form 300A Annual Summary of work-related injuries and illnesses for the previous calendar year.ogletree+1

• Have a company executive certify the accuracy of the 300A summary each year.[ogletree]​

• Post the OSHA 300A Annual Summary in a conspicuous location at each establishment from February 1 through April 30, even if you had zero recordable incidents.osha+2

• Keep OSHA Forms 300, 300A, and 301 for at least 5 years and update the 300 log if case outcomes change during that period.osha+1

• Submit injury and illness data electronically to OSHA by March 2 each year if you meet the size and industry thresholds described in OSHA’s electronic reporting rule.[osha]​

Official OSHA recordkeeping information and forms: https://www.osha.gov/recordkeeping[osha]​

Required Written Safety Programs

OSHA requires construction employers to “initiate and maintain” safety and health programs needed to comply with the construction standards, including written programs for specific hazards.labor.nc+1
Typical written programs that a construction contractor may need include:

• Hazard Communication (HAZCOM) Program (29 CFR 1910.1200 / 1926.59): Written program describing how you label containers, maintain Safety Data Sheets (SDS), and train employees about chemical hazards.[osha]​

• Respirable Crystalline Silica Exposure Control Plan (29 CFR 1926.1153): Written plan that identifies tasks involving silica, engineering controls, work practices, and respiratory protection.labor.nc+1

• Fall Protection Program (29 CFR 1926 Subpart M): Written program describing how you identify fall hazards, select fall protection systems, train workers, and inspect fall protection equipment.army+1

• Personal Protective Equipment (PPE) Hazard Assessment and Program (29 CFR 1926 Subpart E and 1910.132): Documentation of hazard assessments, selected PPE, and employee training.osha+1

• Emergency Action Plan (29 CFR 1910.38, often applied to construction offices and some sites): Written plan for reporting emergencies, evacuation routes, and employee accounting, maintained in the workplace and available for review.[osha]​

• Fire Prevention Plan (29 CFR 1910.39, where applicable): Written plan describing major fire hazards, handling and storage of flammable materials, and control procedures.[labor.nc]​

• Scaffold and Ladder Safety Procedures (29 CFR 1926 Subparts L and X): Written procedures and rules for erecting, using, and dismantling scaffolds and ladders, and for inspections by a competent person.osha+1

• Lockout/Tagout (LOTO) Procedures (for servicing equipment) (29 CFR 1926.417 and 1910.147, where applicable): Written procedures for controlling hazardous energy during servicing and maintenance.army+1

• Hearing Conservation Program (if noise exposures are at or above 85 dBA TWA) (29 CFR 1910.95, referenced for construction): Written program covering noise monitoring, audiometric testing, hearing protection, and training.osha+1

• Respiratory Protection Program (if respirators are required) (29 CFR 1910.134, applied to construction): Written program describing respirator selection, medical evaluations, fit testing, use, and maintenance.[labor.nc]​

OSHA provides sample written programs and templates here: https://www.osha.gov/complianceassistance/sampleprograms[osha]​

Required Safety Training (Including Annual)

OSHA standards require employers to provide safety and health training for hazards that workers can reasonably encounter on the job.[osha]​
Common construction training requirements include:

• Hazard Communication training: Employees who may be exposed to hazardous chemicals must receive training on labels, SDS, and protective measures when they are initially assigned to work with chemicals and whenever a new chemical hazard is introduced; many employers refresh this at least annually to keep workers current.osha+1

• Fall protection training: Workers exposed to fall hazards must be trained to recognize fall hazards and use fall protection systems properly; retraining is required when workplace changes or inadequacies in an employee’s knowledge are observed.osha+1

• Scaffold and ladder training: Workers involved in scaffold erection, dismantling, or use and those using ladders must be trained by a qualified person in safe use, load capacities, and hazard recognition.[osha]​

• Silica training: Employees covered by the construction silica standard must be trained on the health hazards of silica, specific tasks that involve exposure, and control measures.[osha]​

• PPE training: Workers must be trained on when PPE is necessary, what PPE is required, how to properly don, doff, adjust, and wear it, as well as limitations and care.osha+1

• Hearing conservation training: Where a hearing conservation program is required, employers must provide annual training on the effects of noise, selection and use of hearing protectors, and the purpose of audiometric testing.labor.nc+1

• Lockout/Tagout training: Authorized and affected employees must be trained in energy control procedures where LOTO applies.army+1

While “OSHA 10” and “OSHA 30” are not themselves federal legal requirements, many owners, GCs, and state/local agencies require them as a condition of working on their projects.[osha]​
In NYC, workers on construction and demolition projects that require a Construction Superintendent, Site Safety Coordinator, or Site Safety Manager must complete 40 hours of Site Safety Training under Local Law 196, typically achieved with OSHA 30 plus additional SST courses.360training+2

NYC DOB information on Site Safety Training and Local Law 196: https://www.nyc.gov/site/buildings/safety/site-safety-training.page[pdhstar]​

What Needs Attention Every Year

For a practical yearly checklist, a construction contractor should plan to:

• Review and update written safety programs (HAZCOM, silica, fall protection, PPE, emergency action, fire prevention, scaffolds/ladders, LOTO, hearing conservation, respiratory protection) to reflect current job tasks and equipment.labor.nc+1

• Review safety training records, provide refresher training where standards require it (such as hearing conservation), and re-train employees when new hazards, equipment, or procedures are introduced.osha+1

• Complete the OSHA Form 300A Annual Summary for the prior year, certify it, and post it from February 1 to April 30 at each covered establishment.osha+2

• Confirm that OSHA Form 300, 300A, and 301 records for the past 5 years are complete, retained, and updated as needed.ogletree+1

• Determine whether you are required to electronically submit OSHA injury and illness data to OSHA by March 2 and submit forms 300A (and, if applicable, 300 and 301) for the prior year.[osha]​

• Verify that NYC workers and supervisors on covered job sites hold valid SST cards and that any expiring training has been renewed in line with DOB rules.360training+1

For readers of your blog, what type of contractor are you mainly targeting (small specialty subs under 20 employees, or larger GCs and subs with multiple crews)?