OSHA Required Documentation for Construction Contractors (2026)

OSHA requires construction contractors to maintain several categories of documentation, including injury and illness records, written safety programs, training records, equipment inspection logs, and hazard communication materials. The specific requirements vary by company size, project scope, and the hazards present on each jobsite.

This guide covers every category of documentation that OSHA may request during an inspection of a construction operation, organized by regulatory requirement. Understanding what is required — and what is strongly recommended — helps contractors build a documentation system that holds up under scrutiny.

Mandatory OSHA Documentation for Construction Contractors

The following records are explicitly required by OSHA standards. Failure to maintain these documents can result in citations independent of any physical hazard observed on site.

1. OSHA Injury and Illness Records (29 CFR 1904)

Employers with more than 10 employees (at any time during the previous calendar year) must maintain three forms:

• OSHA Form 300 — Log of Work-Related Injuries and Illnesses. A running record of each recordable injury or illness that occurs during the calendar year.
• OSHA Form 300A — Summary of Work-Related Injuries and Illnesses. An annual summary that must be posted in a visible location from February 1 through April 30 each year. Must be certified by a company executive.
• OSHA Form 301 — Injury and Illness Incident Report. A detailed report for each recordable case, completed within seven calendar days of learning about the incident.

These records must be retained for five years following the end of the calendar year they cover. They must be available for inspection by OSHA, employees, and former employees upon request.

2. Written Safety and Health Programs

Several OSHA standards require employers to develop and maintain written programs. For construction contractors, the most commonly required written programs include:

• Hazard Communication Program (29 CFR 1926.59) — Must include a list of hazardous chemicals present on site, methods for informing employees of hazards, and procedures for maintaining safety data sheets (SDS). This is one of the most frequently cited standards across all industries.
• Fall Protection Plan (29 CFR 1926.502(k)) — Required when conventional fall protection methods (guardrails, safety nets, personal fall arrest systems) are infeasible or create a greater hazard. Must be site-specific and prepared by a qualified person.
• Respiratory Protection Program (29 CFR 1910.134, applied to construction via 29 CFR 1926.103) — Required when respirators are used. Includes medical evaluations, fit testing, training, and maintenance procedures.
• Excavation Competent Person Program (29 CFR 1926.651) — While not a “written program” per se, the competent person requirements for excavation are best documented through a formal designation and training record.
• Lockout/Tagout Program (29 CFR 1926.417) — Required for construction activities involving the control of hazardous energy during equipment maintenance or servicing.
• Crane and Derrick Program (29 CFR 1926.1400) — Operator qualification and certification requirements, pre-operation inspection procedures, and signal person qualifications.

3. Training Documentation

OSHA does not accept verbal assurances that training occurred. Training must be documented with sufficient detail to prove that specific employees received specific instruction on specific dates.

Each training record should include:

• Date and time of training
• Topic(s) covered
• Name and qualifications of the trainer
• Names and signatures of all attendees
• Duration of the training session
• Any materials or handouts provided

Training is required under numerous construction-specific standards. The most common training documentation that inspectors request:

• Fall protection training (29 CFR 1926.503)
• Scaffold user training (29 CFR 1926.454)
• Excavation hazard training (29 CFR 1926.651)
• Hazard communication training (29 CFR 1926.59)
• Powered industrial truck (forklift) training (29 CFR 1926.602)
• Crane operator certification (29 CFR 1926.1427)
• Confined space entry training (29 CFR 1926.1204)
• Electrical safety training (29 CFR 1926.405)

4. Equipment Inspection Records

Multiple OSHA standards require regular inspection of equipment and documentation of those inspections:

• Scaffold inspections — By a competent person before each work shift and after any event that could affect structural integrity (29 CFR 1926.451(f)(3))
• Excavation inspections — Daily, before work begins, and after any rain, vibration, or other potentially destabilizing event (29 CFR 1926.651(k))
• Crane inspections — Pre-shift visual inspections by the operator, and periodic comprehensive inspections per manufacturer specifications (29 CFR 1926.1412)
• Fire extinguisher inspections — Monthly visual inspections and annual maintenance (29 CFR 1926.150)
• Personal fall arrest system inspections — Before each use, with removal from service after any fall event

5. Incident and Near-Miss Reports

Beyond the OSHA 301 forms for recordable incidents, contractors should maintain documentation for:

• Near-miss reports — While not explicitly required by a single OSHA standard, near-miss documentation demonstrates a proactive safety culture and supports good faith penalty reductions.
• Fatality and severe injury reports — Employers must report any work-related fatality within 8 hours and any in-patient hospitalization, amputation, or loss of an eye within 24 hours (29 CFR 1904.39).
• Corrective action records — Documentation of what actions were taken after an incident, who was responsible, and when the actions were completed.

Documentation Gaps That Contractors Commonly Overlook

Most contractors maintain some form of documentation. The gap is rarely a complete absence of records — it is the inconsistency, incompleteness, or inaccessibility of those records when they matter most.

During an OSHA inspection, the compliance officer expects to review relevant documents within a reasonable timeframe. Delays, partial records, and missing signatures create an impression of disorganized safety management — even if the underlying practices are sound.

The most common documentation gaps that lead to citations:

• Unsigned training records — Training sessions were conducted but attendance sheets were not signed, or signatures were collected on loose paper that was subsequently lost.
• Generic safety programs — Written programs downloaded from the internet that do not reflect the company's actual operations, site conditions, or specific hazards. OSHA inspectors recognize template programs that have not been customized.
• Gaps in daily records — Missing days in daily logs suggest that safety oversight was not occurring consistently. Even a single week of missing entries raises questions.
• No corrective action follow-through — Hazards were identified on inspection forms but there is no documentation that corrective action was taken or verified. This creates a record of known hazards without evidence of response.
• Outdated certifications — Employee certifications (crane operator, first aid, confined space) that expired weeks or months ago with no record of renewal or interim measures.
• Missing subcontractor documentation — As the controlling employer, not having documentation of subcontractor safety qualifications, insurance, or training programs creates liability exposure under OSHA's multi-employer citation policy.

Why Retrievability Matters as Much as Existence

Having documentation is necessary but not sufficient. The documentation must be retrievable — quickly, completely, and in a format that an outside reviewer can follow.

Consider this: your crew conducted fall protection training three months ago. The sign-in sheets are in a binder in the field trailer. But the field trailer is at a different jobsite. The inspector is asking for the records now. Can you produce them within the hour?

Documentation that exists but cannot be retrieved during an inspection provides no protection. The inspector does not schedule a follow-up visit to give you time to collect records. The evaluation happens in real time, based on what you can produce in the moment.

This is why documentation systems matter more than individual documents. A filing cabinet of loose papers is technically “documentation,” but it provides little protection if the specific record needed cannot be located when it counts. An organized, consistent system — whether digital or paper — that allows rapid retrieval is the difference between compliance and citation.

The financial impact is direct. Documentation that earns you the good faith penalty reduction can save 25% on every penalty assessed. But only if you can actually produce it.