Electrical contractors: what an audit looks like
For licensed commercial and industrial electrical contractors with 10 to 100 employees facing an OSHA inspection, a state licensing board review or a hiring client's prequalification check. This page covers what each reviewer asks to see and which findings recur in OSHA's own citation data, with California's CSLB as the worked licensing example.
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Who comes, and how often
OSHA compliance officers (federal OSHA or a State Plan agency)
Inspections run in priority order: imminent danger, fatalities and catastrophes, complaints and referrals, then programmed inspections, which on construction sites are drawn from a random list of active projects. In the 22 State Plans that cover private employers, including California, the state agency inspects.
State contractor licensing board (California CSLB as the worked example)
CSLB investigates complaints, sweeps active construction sites and checks that the license, $25,000 bond, workers' compensation certificate or exemption and qualifier stay in place. A C-10 qualifier needs four years of journey-level experience within the last 10 years.
Hiring-client prequalification reviewers (ISNetworld and Avetta)
A hiring client makes an account a condition of work, and the platform's reviewers check written programs, training proof, insurance, license status and injury data against the client's requirements.
What they ask to see
Injury and illness records
OSHA Forms 300, 300A and 301 for the three prior calendar years, total hours worked and average employees for each year, and a roster of current employees with job classification, hours and work area. Copies are due within four business hours of the request.
OSHA Field Operations Manual Chapter 3; 29 CFR 1904.40(a)Source ↗
Written hazard communication program
A program covering labels, safety data sheets and employee training, with a list of the hazardous chemicals on site. Officers review it alongside the lockout, emergency evacuation and personal protective equipment programs.
29 CFR 1926.59; 1910.1200(e)(1)Source ↗
Assured equipment grounding conductor program
Where the contractor uses this program instead of ground-fault circuit interrupters, a written description kept at the jobsite, the designated competent persons and test records showing each cord set, receptacle and tool with its last test date or interval.
29 CFR 1926.404(b)(1)(iii)Source ↗
Fall protection training records
A written record naming each trained employee, the training dates and the signature of the trainer or employer, with the latest record kept. Retraining is required when workplace or equipment changes make earlier training obsolete.
29 CFR 1926.503(b), (c)Source ↗
Lockout and tagging procedures
Tags on deenergized circuits and controls that identify the equipment being worked on. Where general industry electrical rules apply, the employer keeps a written copy of the lockout and tagging procedures available for inspection.
29 CFR 1926.417; 1910.333(b)(2)(i)Source ↗
License standing file (California example)
The active C-10 license, the $25,000 contractor bond, a current workers' compensation insurance certificate or a signed no-employee exemption, and the qualifying individual's experience record.
CSLB Get Licensed to Build guide; Cal. Bus. & Prof. Code 7125Source ↗
Prequalification document set
Written programs, training proof with course name, employee signature, date and instructor, insurance policies, license status, experience modifier, and injury, work-hour and NAICS data that RAVS matches to OSHA recordkeeping documents.
ISNetworld RAVS disclaimers, Part II and Part IIISource ↗
What they pick on the day
Employees interviewed privately
OSHA may question any employee privately during working hours about conditions, how long they have existed and what management did about them.
Three years of injury records
Officers use the 300 logs, 300A summaries and 301 reports to calculate the days away, restricted or transferred rate and spot trends. A partial inspection can widen based on those records, interviews and what the officer sees in plain view, though not on the 300 data alone.
Programs read against the jobsite walkaround
Hazard communication, lockout, emergency evacuation and protective equipment programs are compared with conditions on the walkaround. On a multi-employer site, more than one employer can be cited for the same condition.
Documents and people in a prequalification review
RAVS checks documents against the hiring client's own items, such as company name, completion date, employee signature and instructor. A hiring client can add RAVS 360, which brings in training records, supporting documents and interviews of contractor representatives.
What gets cited, with counts where they are published
Fall protection training and competent-person inspections
1,386 serious citations under 1926.503(a)(1); 673 under 1926.20(b)(2) FY2025
In OSHA's construction-wide chart of serious citations, training for employees exposed to fall hazards ranks fourth and inspections by a competent person ranks sixth. Residential fall protection leads at 5,276.
Working near live circuits and worn cords
148 under 1926.416(a)(1); 76 under 1926.416(e)(1); 69 under 1926.403(b)(1) FY2025
In Subpart K, the electrical subpart, no protection when working close to an energized circuit led the serious citations, followed by worn or frayed cords and cables and equipment not free of recognized hazards.
Safety instruction and accident prevention programs
370 under 1926.21(b)(2); 195 under 1926.20(b)(1) FY2025
Instruction in recognizing and avoiding unsafe conditions and the employer's duty to maintain accident prevention programs both appear in OSHA's Subpart C serious-citation chart.
Licensee citations at the California contractors board
985 (7109(a)); 853 (7117); 847 (7125.4); 579 (7110) FY2019/20 to FY2022/23
CSLB's own ranking of citations to licensees over four fiscal years includes willful departure from trade standards, acting under a name or personnel inconsistent with CSLB records, a false workers' compensation exemption and willful violation of building laws. Home improvement contract violations (7159.5) lead the list at 8,986 and concern consumer home improvement contracts.
What is not published
OSHA's most-cited list for electrical contractors (NAICS 238210) sits behind a verification page, so the counts are for construction as a whole and count serious citations only. ISNetworld and Avetta publish no failure or scoring statistics. The California licensing board publishes statewide complaint counts, not counts for one license class.
Where written policies come in
Hazard communication program kept current
The written program is required at each workplace, and may be kept at the primary facility when employees travel between sites. OSHA's 2026 rule moved employer deadlines to update the program, labeling and training for newly identified hazards to November 20, 2026 for substances and May 19, 2028 for mixtures.
Fall protection training: who, when and which signature
The training record names the employee, the date or dates and the trainer or employer who signed, and only the latest record has to be kept.
Grounding program with a named competent person
The written description stays at the jobsite, the employer designates one or more competent persons and the test record is maintained until a newer one replaces it.
Programs compared with each client's own list
ISNetworld reviews written programs against regulatory requirements and the hiring client's requirements. A hiring client can ask for RAVS 360, which assesses how a program is carried out through training records, supporting documents and interviews.
Dates that matter
| Date | What happens | Status |
|---|---|---|
| November 20, 2026 | Employer deadline to update hazard communication program, alternative labeling and training for newly identified hazards of substances Source ↗ | Scheduled |
| March 2, 2027 | Form 300A electronic submission for calendar year 2026 (establishments with 20 to 249 employees in construction, and 250 or more) Source ↗ | Scheduled |
| May 19, 2028 | Employer deadline to update hazard communication program, alternative labeling and training for newly identified hazards of mixtures Source ↗ | Scheduled |
Questions people ask
Does OSHA's lockout/tagout standard 1910.147 apply to construction work?
1910.147 does not cover construction employment or exposure to electrical hazards from work on electric utilization installations, which Subpart S covers. Tagging of circuits on construction sites falls under 1926.417, and 1910.333(b)(2) requires a written copy of the lockout and tagging procedures where general industry electrical rules apply.
How quickly must injury and illness records be produced?
Within four business hours of a request from an authorized government representative under 1904.40(a). The officer may start the walkaround before the copies arrive.
Which electrical contractors file Form 300A electronically?
Establishments with 20 to 249 employees in construction and establishments with 250 or more employees submit by March 2 of the following year. A company with 10 or fewer employees at all times during the last calendar year is partially exempt from keeping routine injury records under 1904.1.
In California, does OSHA or the contractors board inspect safety?
California is one of 22 State Plans that cover private employers, so Cal/OSHA inspects. CSLB licenses contractors and investigates licensing complaints, which is a separate review.
Does a prequalification written program review confirm the program is carried out?
ISNetworld describes RAVS written program review as a comparison of documents with regulatory and hiring client requirements. Implementation is the subject of RAVS 360, which a hiring client requests.
Sources
- osha.gov /fom/chapter-2
- osha.gov /fom/chapter-3
- osha.gov /fom/chapter-4
- osha.gov /data/commonstats
- osha.gov /stateplans
- osha.gov /top10citedstandards
- osha.gov /sites/default/files/MFC_Construction_FY25.pdf
- osha.gov /electrical-contractors/standards
- ecfr.gov /current/title-29/section-1904.1
- ecfr.gov /current/title-29/section-1904.40
- ecfr.gov /current/title-29/section-1904.41
- ecfr.gov /current/title-29/section-1910.147
- ecfr.gov /current/title-29/section-1910.333
- ecfr.gov /current/title-29/section-1910.1200
- ecfr.gov /current/title-29/section-1926.404
- ecfr.gov /current/title-29/section-1926.417
- ecfr.gov /current/title-29/section-1926.503
- federalregister.gov /documents/2026/01/15/2026-00653/hazard-communication-standard
- isnetworld.com /en/ravs-disclaimers
- isnetworld.com /en/contractor-prequalification-and-ongoing-monitoring
- avetta.com /clients/solutions/health-and-safety/safety-audits
- avetta.com /suppliers-contractors/products/company-prequalification
- cslb.ca.gov /Resources/Reports/Enforcement/CSLB_FY_2024-25_Enforcement_Repor…
- cslb.ca.gov /Resources/Reports/Sunset/CSLB_2023_Sunset_Report.pdf
- cslb.ca.gov /Resources/GuidesAndPublications/GetLicensedToBuild.pdf
- cslb.ca.gov /about_us/library/licensing_classifications/Licensing_Classifica…
- cslb.ca.gov /Contractors/Maintain_License/Workers_Compensation.aspx
- cslb.ca.gov /contractors/maintain_license/Business_and_Professions_7125.aspx
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