By Mark Spring, CSP, CRIS, AGC Safety Management Consultant
Every year, Oregon OSHA (Occupational Safety and Health Division) publishes its Top 25 violations given for each industry. The construction industry report gives a clear look at the issues OSHA inspectors find on construction sites across Oregon. The 2025 report covers everything from fall protection and ladders to safety meetings, heat illness prevention, excavation safety, and fire extinguisher inspections.
You can view the complete report here: Oregon OSHA’s Top 25
Oregon OSHA Penalties Have Increased
Oregon OSHA penalties changed significantly following Senate Bill 592. The new penalty structure took effect for inspections opened on or after January 1, 2024, and many of the amounts are adjusted annually for inflation. For inspections opened in 2026, a serious violation can carry a penalty of up to $17,004. Repeat and willful violations can reach $170,046 per violation, and repeat and willful violations that cause or contribute to a fatality can be as high as $272,058.
Not every citation will receive the maximum penalty. Still, the change makes one thing clear: correcting safety problems before they become citations, and ensuring previously identified problems stay corrected, matters more than ever.
Fall Protection Continues to Stand Out
Fall protection is the most obvious theme in the 2025 report.
General fall protection is the number one violation, but fall protection also appears in several other ways throughout the Top 25. The list includes personal fall-arrest systems, fall-protection training, certification of that training, protection around holes and wall openings, guardrail systems, scaffold fall protection, and another walking-working-surface fall standard.
It may look like Oregon OSHA cites the same issue repeatedly, but these standards address different parts of fall protection.
The general fall-protection rule deals primarily with whether workers exposed to a fall hazard are protected. Personal fall-arrest requirements address how systems such as harnesses, lanyards, lifelines, connectors, and anchor points are designed and used. Other rules address specific hazards such as floor or roof holes, wall openings, guardrails, and scaffolding.
Then there is the training side. Workers need to understand the fall hazards they face and how to use the provided systems properly. Employers also need to maintain the required documentation showing that the training occurred.
The biggest takeaway from seeing fall protection so often on the list is that it’s more than putting someone in a harness. It starts with recognizing the hazard, selecting the proper protection, ensuring it is installed and used correctly, training the worker, and documenting that training.
Not Every Citation Is Something You See During a Site Walk
Another thing that stands out from the report is the mix of physical jobsite hazards and paperwork or program issues.
Some of the Top 25 involve conditions an inspector may immediately see while walking a project. Other citations can result from what is or is not in the company’s policies or records. Safety meeting documentation, fall-protection training certification, the written Hazard Communication program, and the heat illness prevention plan are all on the top 25 list.
A company can do many things correctly in the field and still have documentation gaps. For example, you may hold regular safety meetings, but if you don’t document them properly, that can create a compliance issue. The same applies to employee training: good training matters, but you also need to keep the required records.
Repeat Citations Are Especially Important
The 2025 report also explains why companies need to pay close attention to issues they have previously been cited for.
General fall protection had 268 serious violations, equaling $714,363 in initial penalties. It had 106 repeat violations, equaling $4.1 million in initial penalties. That averages $39,056 per repeat violation. Ladder use had 122 serious violations, totaling $263,971 in initial penalties, and 17 repeat violations totaling $535,500 in initial penalties. That averages $31,500 per repeat violation.
Under Oregon OSHA’s current rules, a repeat violation generally involves a substantially similar violation cited within the previous three years. Repeat penalties increase significantly as violations recur.
When a citation occurs, correcting what the inspector saw that day is only part of the solution. Companies should also determine why the problem occurred and whether the same condition could exist somewhere else.
For example, if an employee was exposed to a fall hazard, correcting that one location may solve the immediate problem. But it is also worth reviewing other projects, training, supervisor expectations, and inspection practices to ensure the same issue doesn’t recur.
Use the Report as a Safety Tool
Oregon OSHA’s Top 25 should not just be viewed as a list of violations or fines. It can be a useful way to take another look at your own safety program.
Review the report with supervisors, project managers, safety committees, or crews. Look at the items Oregon OSHA is finding most often and ask a simple question:
Could the same issues be happening on one of our job sites?
If the answer is yes, finding it yourself lets you correct it before Oregon OSHA finds it—and, more importantly, before someone gets hurt.
Written with an assist from AI.