OSHA & DOSH Compliance Checklist for Washington Construction Sites
Washington State does not rely on federal OSHA alone. The Division of Occupational Safety and Health (DOSH) under L&I enforces its own workplace safety standards -- and in many cases, they are stricter than the federal rules. If you operate a construction site in the Tacoma-Seattle corridor or anywhere in Washington, here is the compliance checklist you need.
Quick Facts
Washington's Own OSHA: Understanding DOSH
Most contractors know about federal OSHA, but many underestimate the significance of Washington's own enforcement arm. The Division of Occupational Safety and Health (DOSH) operates under the Department of Labor & Industries (L&I) and functions as Washington's state-level OSHA program.
Washington is one of approximately 22 states (plus several territories) that maintain an OSHA-approved state plan. This means DOSH has its own set of rules, its own inspection teams, and its own penalty structure. Federal OSHA does not directly enforce workplace safety in Washington -- DOSH does.
Key Distinction
Under federal law, state plans must be "at least as effective" as federal OSHA standards. In practice, Washington's DOSH standards are often stricter. The most notable example: Washington's fall protection trigger height for construction is 4 feet, compared to federal OSHA's 6-foot standard. If you are following federal OSHA minimums on a Washington construction site, you may already be out of compliance.
DOSH at a Glance
- Governing body: Washington Department of Labor & Industries (L&I)
- Website: lni.wa.gov/safety-health
- Primary construction standard: WAC 296-155 (Safety Standards for Construction Work)
- Inspection authority: Can enter any worksite without advance notice
- Complaint process: Workers can file anonymous complaints through L&I
- Reporting requirement: Fatalities and in-patient hospitalizations must be reported within 8 hours
DOSH Inspection Readiness Checklist
DOSH compliance officers can arrive at your construction site without warning. Being prepared for an inspection is not optional -- it is the baseline expectation. Here is what inspectors evaluate and the documentation you need to have ready.
What DOSH Inspectors Look For
- Fall protection systems: Guardrails, safety nets, personal fall arrest systems at 4+ feet
- Scaffolding compliance: Proper planking, guardrails, access points per WAC 296-874
- Excavation safety: Shoring, sloping, or trench boxes for excavations 4+ feet deep
- Crane operations: Operator certification, pre-shift inspections, load charts
- Electrical safety: GFCI protection, lockout/tagout procedures, proper grounding
- PPE usage: Hard hats, high-visibility vests, eye protection, hearing protection
- Hazard communication: SDS sheets accessible, containers labeled, workers trained
- Site access control: Perimeter security, unauthorized entry prevention, signage
Required Documentation
DOSH inspectors will ask to see these documents. Having them organized and immediately accessible can make the difference between a clean inspection and a citation:
- Written Accident Prevention Program (APP): Required for all WA employers under WAC 296-800-140
- Safety meeting records: Weekly tailgate/toolbox meeting logs with attendance
- Training documentation: Fall protection, scaffolding, crane operations, hazcom
- Equipment inspection logs: Cranes, scaffolds, excavation supports, rigging
- Incident investigation reports: For any workplace injuries or near-misses
- First aid logs and OSHA 300 records: Injury and illness tracking
- Site security plan: Access control, monitoring, emergency procedures
- Crane operator certifications: Washington requires certification per WAC 296-155-53100
Common Triggers for DOSH Inspections
Understanding what triggers inspections helps you prioritize compliance efforts:
- Worker complaints: Filed anonymously through L&I -- the most common trigger
- Severe injuries or fatalities: Automatic investigation within 24 hours
- Referrals: From other agencies, hospital emergency rooms, or media reports
- Follow-up inspections: Checking that previously cited violations have been corrected
- Programmed inspections: Targeted sweeps of high-hazard industries (construction is always on the list)
- Drive-by observations: Compliance officers who spot visible hazards from public areas
Pro Tip: Drive-By Visibility
DOSH compliance officers regularly drive through areas with active construction. If they can see workers without fall protection, missing hard hats, or unsecured scaffolding from the road, they have grounds to initiate an inspection. A mobile surveillance trailer with visible cameras serves as a signal that your site takes compliance seriously -- and gives you video proof of PPE usage to counter any allegations.
Common OSHA/DOSH Violations at Washington Construction Sites
Every year, DOSH publishes data on the most-cited violations in Washington. Construction consistently leads all industries in citation volume. Here are the violations Washington construction employers are most commonly cited for, along with current penalty ranges:
| Rank | Violation Category | WA Standard | Penalty Range |
|---|---|---|---|
| 1 | Fall protection (general) | WAC 296-155-24510 | $1,000-$7,000 |
| 2 | Scaffolding deficiencies | WAC 296-874 | $1,000-$7,000 |
| 3 | Ladder safety violations | WAC 296-876 | $1,000-$7,000 |
| 4 | Excavation/trenching | WAC 296-155-657 | $1,000-$7,000 |
| 5 | Hazard communication | WAC 296-901 | $500-$7,000 |
| 6 | Crane safety | WAC 296-155-53100 | $1,000-$7,000 |
| 7 | Electrical (wiring/GFCI) | WAC 296-155-426 | $500-$7,000 |
| 8 | PPE violations | WAC 296-155-200 | $500-$7,000 |
| 9 | Struck-by hazards | WAC 296-155-305 | $500-$7,000 |
| 10 | Accident prevention program gaps | WAC 296-800-140 | $500-$7,000 |
DOSH Penalty Structure
Serious violations: Up to $7,000 per violation. These involve hazards that could cause death or serious physical harm.
Willful violations: Up to $70,000 per violation. Applied when the employer knowingly ignores safety requirements.
Repeat violations: Up to $70,000 per violation. For employers cited for the same or similar hazard within 3 years.
Failure to abate: Up to $7,000 per day beyond the abatement deadline.
Imminent danger: DOSH can issue an immediate restraint order, shutting down all work until the hazard is corrected.
Penalties are adjusted based on employer size, good faith efforts (including documented safety programs), and violation history.
In 2024, L&I reported multiple significant construction penalties in the Puget Sound region, including a Tacoma-area contractor fined over $45,000 for repeated fall protection violations across two project sites, and a King County general contractor cited $28,000 for excavation safety and crane operation deficiencies.
How Mobile Surveillance Documents OSHA/DOSH Compliance
Meeting DOSH requirements is not a one-time event -- it requires continuous, documented compliance. This is where mobile surveillance provides a unique advantage that goes beyond traditional security. Time-stamped, high-definition video footage creates an objective compliance record that no amount of paperwork can match.
PPE Usage Documentation
DOSH citations for PPE violations are common and difficult to contest without evidence. A 360-degree surveillance system operating 24/7 captures footage of workers across the entire site, creating a continuous record of hard hat usage, high-visibility vest compliance, eye protection, and hearing protection in designated zones. If a DOSH inspector alleges PPE non-compliance, time-stamped video provides objective proof of your crew's actual practices.
Fall Protection Compliance Verification
With fall protection as DOSH's number-one cited violation, documenting compliance is critical. Elevated surveillance cameras capture footage of workers at height, showing guardrail integrity, personal fall arrest system usage, and proper scaffold access. This footage serves as evidence that your 4-foot fall protection threshold (the Washington standard) is being met consistently -- not just during safety walkthroughs.
Hazard Communication Monitoring
DOSH requires that SDS sheets be accessible, containers be labeled, and workers receive training. Surveillance footage can document that hazardous material storage areas maintain proper signage, that restricted zones remain properly barricaded, and that unauthorized personnel do not access hazmat areas. For sites with ongoing chemical deliveries, camera footage provides a log of who accessed what and when.
Emergency Response Documentation
When incidents occur, DOSH investigates the employer's response. Video footage documents exact response times, evacuation procedures followed, first aid administered, and whether emergency protocols were executed properly. This evidence is invaluable during post-incident investigations and can demonstrate good-faith compliance even when an accident occurs.
Site Access Control and Security
Unauthorized access to construction sites creates both safety and liability risks. Mobile surveillance records all site access, including after-hours entry attempts, contractor arrivals, and delivery traffic. This access log satisfies DOSH requirements for controlled site access and provides evidence for insurance compliance requirements as well. For comprehensive construction site security information, see our construction security solutions page.
Compliance Benefit
DOSH considers "good faith" when calculating penalties. Employers who demonstrate proactive compliance efforts -- including investment in monitoring and documentation systems -- may receive penalty reductions of up to 25%. A mobile surveillance system operating as a continuous compliance documentation tool is strong evidence of good faith.
Washington-Specific Construction Safety Requirements
Beyond the general DOSH framework, Washington has several construction-specific standards that are stricter or more detailed than their federal counterparts. Contractors working in the Tacoma-Seattle area need to understand these differences.
WAC 296-155: Safety Standards for Construction Work
This is the primary chapter governing all construction safety in Washington State. It covers everything from site preparation to demolition. Key sections include:
- WAC 296-155-24510 (Fall Protection): 4-foot trigger height, compared to federal OSHA's 6 feet. This single difference accounts for hundreds of additional citations in Washington each year.
- WAC 296-155-657 (Excavation): Detailed requirements for protective systems, daily inspections, and atmospheric testing.
- WAC 296-155-305 (Personal Protective Equipment): Specific requirements for head, eye, face, and high-visibility protection on construction sites.
- WAC 296-155-53100 (Crane Safety): Washington has some of the nation's strictest crane operator certification requirements, including mandatory certification through an accredited program.
Washington Fall Protection: The 4-Foot Standard
The 4-foot fall protection trigger height is the most commonly misunderstood difference between federal and Washington standards. Contractors who operate across state lines or who rely on federal OSHA training materials often default to the 6-foot standard -- and get cited for it. In Washington, if a worker is exposed to a fall hazard of 4 feet or more, fall protection must be in place. Period.
This applies to leading edges, holes, formwork, rebar assembly, precast concrete, residential construction, and roofing. The only exceptions are limited situations where conventional fall protection is infeasible and a written fall protection work plan has been developed and approved.
Washington Crane Safety Requirements
Washington's crane safety program under WAC 296-155-53100 is among the most rigorous in the country. Requirements include:
- All crane operators must hold certification from an accredited certifying entity
- Annual crane inspections by a Washington-accredited inspector
- Pre-shift inspections documented daily
- Assembly/disassembly must be directed by a qualified person
- Proximity to power lines requires specific clearance distances and procedures
Outdoor Heat Exposure Rules
Washington was one of the first states to adopt permanent outdoor heat exposure rules, now codified under WAC 296-307-097. While the Pacific Northwest climate makes extreme heat less frequent than in southern states, summer months in the Tacoma-Seattle area regularly see temperatures that trigger these requirements:
- At 80 degrees F: Employers must provide drinking water, shade, and encourage preventive rest breaks
- At 90 degrees F and above: Mandatory 10-minute cool-down rest periods every 2 hours
- At 100 degrees F and above: Additional observation and buddy-system requirements
- Year-round obligation: Employers must have a written outdoor heat exposure prevention plan
Mobile surveillance can document that shade structures are in place, that water stations are accessible and stocked, and that mandatory rest breaks are being observed -- all of which become relevant if a heat-related illness leads to a DOSH investigation.
Setup Matters for Compliance
Proper camera placement is critical for compliance documentation. Surveillance units should be positioned to capture fall-hazard zones, site entry points, hazmat storage areas, and high-traffic work zones. For guidance on optimal positioning, see our security trailer setup guide.
Compliance Costs vs. Non-Compliance Consequences
The financial case for proactive compliance is straightforward when you consider the full cost of DOSH violations:
What Non-Compliance Actually Costs
Direct DOSH Penalties
- Single serious violation: up to $7,000
- Multiple citations (typical): $15,000-$50,000+
- Willful violation: up to $70,000 each
- Failure to abate: $7,000/day
Indirect Costs
- Work stoppage (immediate restraint): $5,000-$25,000/day
- Legal counsel for contested citations: $10,000-$50,000
- Increased L&I premiums: 10-30% annually
- Project delays and liquidated damages
Mobile surveillance for compliance documentation: $8,000-$10,000/month
A single willful violation penalty can exceed 7 months of surveillance costs. For detailed insurance savings analysis, see our insurance security requirements guide.
Frequently Asked Questions: DOSH Compliance in Washington
What is DOSH and how does it differ from federal OSHA in Washington?
DOSH (Division of Occupational Safety and Health) operates under Washington's Department of Labor & Industries (L&I). Washington is one of approximately 22 states with an OSHA-approved state plan, meaning DOSH enforces its own standards that must be at least as effective as federal OSHA but can be stricter. For example, Washington's fall protection trigger height for construction is 4 feet, compared to federal OSHA's 6 feet.
What are DOSH penalty amounts for construction violations in Washington?
DOSH penalties include up to $7,000 per serious violation and up to $70,000 per willful or repeat violation. Failure-to-abate penalties can reach $7,000 per day. Penalty amounts are adjusted based on employer size, good faith efforts, and violation history. DOSH can also issue immediate restraint orders to shut down work that poses imminent danger.
What does WAC 296-155 cover for Washington construction safety?
WAC 296-155 is Washington's Safety Standards for Construction Work. It covers fall protection (stricter than federal at a 4-foot trigger height), scaffolding, excavation, crane safety (including the nation's strictest crane operator certification under WAC 296-155-53100), electrical safety, hazard communication, personal protective equipment, and site security requirements. All Washington construction employers must comply with these standards.
Can video surveillance help during a DOSH inspection in Washington?
Yes. Time-stamped video footage from mobile surveillance systems can document ongoing compliance with safety standards including PPE usage, fall protection deployment, hazard communication signage, and emergency response procedures. During a DOSH inspection, this footage serves as objective evidence that safety protocols are consistently followed, not just when inspectors are present. For setup details, see our security trailer setup guide.
What triggers a DOSH construction site inspection in Washington?
DOSH inspections can be triggered by worker complaints (which can be filed anonymously through L&I), referrals from other agencies, severe injuries or fatalities (must be reported within 8 hours), follow-up on previous violations, or programmed inspections targeting high-hazard industries. Construction is consistently one of the most-inspected industries in Washington State.
What are Washington's outdoor heat exposure rules for construction workers?
Washington adopted permanent outdoor heat exposure rules under WAC 296-307-097 that require employers to provide access to drinking water, shade, and rest breaks when temperatures reach 80 degrees Fahrenheit. At 90 degrees and above, mandatory 10-minute cool-down rest periods are required every 2 hours. These rules apply year-round and are stricter than any federal OSHA heat standard. For comprehensive compliance guidance, see our construction compliance guide.
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