This is your quarterly enforcement intelligence briefing. It tells you where the regulators are looking, what they are looking for, and what the consequences look like when they find it. Read it. Adjust your priorities accordingly.
If you wait for the inspector to tell you what the current priorities are, you are receiving your intelligence briefing in the form of a citation. That is an expensive way to learn.
Federal OSHA Enforcement Priorities — Q2 2026
Penalty Escalation Continues
Federal OSHA penalties have been adjusted for inflation annually since the passage of the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The current maximum penalties as of January 2026:
- **Serious violation:** $16,550 per violation
- **Other-than-serious violation:** $16,550 per violation
- **Willful or repeated violation:** $165,514 per violation
- **Failure to abate:** $16,550 per day
These numbers are per violation, not per inspection. An inspection that identifies ten serious violations generates ten penalties. A facility with the same violation at multiple locations or on multiple machines faces per-instance penalties that compound rapidly.
**The multiplier effect:** When OSHA identifies a willful violation, they review the last five years of inspection history. If the same standard was cited previously, the violation is reclassified as willful-repeat, which carries the maximum penalty with no reduction for good faith, size, or history. One historical citation transforms a current violation from a $16,550 problem into a $165,514 problem.
Current National Emphasis Programs (NEPs)
NEPs direct OSHA's resources toward specific hazards or industries. Active NEPs relevant to California employers in Q2 2026:
**Heat Illness.** The federal heat NEP remains active and is expanding in scope. OSHA is conducting heat-related inspections in any industry where workers are exposed to high heat — not just traditional outdoor industries. Indoor manufacturing, warehousing, and commercial kitchens are all inspection targets. The proposed federal heat standard remains in rulemaking, but enforcement under the General Duty Clause continues aggressively in the interim.
**Falls.** The fall protection NEP targets construction and general industry operations where fall hazards exist. Falls remain the number one cause of workplace fatalities, and OSHA allocates more inspection resources to fall protection than to any other single hazard. Any complaint, referral, or observation related to fall hazards triggers an inspection.
**Trenching and Excavation.** Following multiple trench collapse fatalities in 2024-2025, OSHA expanded its trenching and excavation NEP with additional compliance officers specifically trained in excavation hazards. Any open trench on any construction site is subject to inspection without prior complaint.
**Process Safety Management (PSM).** The PSM NEP targets facilities covered by the PSM standard — petroleum refineries, chemical plants, and manufacturing operations that use highly hazardous chemicals. PSM inspections are the most resource-intensive inspections OSHA conducts, often lasting weeks and resulting in six-figure penalty totals.
**Primary Metal Industries.** Foundries, smelters, and metal fabrication facilities are targeted for exposure to metal fumes, silica, noise, and ergonomic hazards.
Severe Violator Enforcement Program (SVEP)
The SVEP identifies employers who have demonstrated indifference to their obligations. Criteria for SVEP entry include willful violations, repeated violations, failure to abate violations, and fatality/catastrophe-related violations. SVEP employers are subject to:
- Enhanced follow-up inspections
- Mandatory corporate-wide settlement agreements (not just the cited establishment)
- Increased publicity of violations (press releases, public databases)
- Referral to the EPA, state agencies, and other federal agencies for coordinated enforcement
Once on the SVEP list, removal requires sustained compliance over multiple inspections. The reputational damage is permanent — customers, insurers, and business partners monitor the SVEP list.
Cal/OSHA Enforcement Priorities — Q2 2026
Active California Local Emphasis Programs (LEPs)
Cal/OSHA operates its own emphasis programs that supplement and often exceed federal priorities:
**Heat Illness Prevention.** California's heat illness LEP has been continuous since 2005 and intensifies every summer. Starting in April, Cal/OSHA deploys compliance officers to outdoor worksites — particularly agriculture, construction, and landscaping — to verify heat illness prevention program implementation. High-heat days trigger surge inspections. Any outdoor employer without a current heat illness prevention plan is an enforcement target from April through October.
**Warehousing and Distribution.** Cal/OSHA has identified warehousing as a priority enforcement target in response to rising injury rates in fulfillment and distribution operations. Inspections focus on powered industrial truck safety, ergonomic hazards from manual lifting, indoor heat illness, and workplace violence prevention. If you operate a warehouse or distribution center in California, expect increased inspection activity in 2026.
**Refinery Safety.** Petroleum refining operations in California face continuous emphasis inspections focusing on PSM compliance, mechanical integrity, and emergency preparedness. The 2015 Torrance refinery explosion continues to drive policy — Cal/OSHA's refinery enforcement posture has not relaxed.
**Tree Work and Landscaping.** Tree trimming fatalities drive a persistent emphasis program targeting arborists and landscaping companies. Fall protection, chipper safety, and electrical proximity are the primary focus areas.
SB 553 Workplace Violence Prevention — Enforcement Maturation
SB 553 took effect on July 1, 2024. The first year of enforcement featured primarily educational inspections — inspectors assessed compliance but emphasized guidance over citations. That grace period is over.
In Q2 2026, Cal/OSHA is enforcing SB 553 as a mature standard:
- **Full citations** for missing or inadequate WVPPs
- **Serious citations** for employers who have experienced workplace violence incidents without a compliant program
- **Per-instance citations** for employers with multiple locations and no WVPP at any of them
- **Training verification** — inspectors are interviewing employees to confirm training was actually delivered, not just documented
The most common SB 553 citations in Q1 2026 were: (1) no WVPP at all, (2) WVPP that was a template with no site-specific content, (3) no violent incident log, (4) no employee training, and (5) no documentation of employee involvement in program development.
If your WVPP is a template you downloaded and filed without customization, you are carrying every one of these citation risks.
Indoor Heat Illness
California's indoor heat standard continues to mature in enforcement. Cal/OSHA is conducting indoor heat inspections in manufacturing, warehousing, commercial kitchens, laundry facilities, and any indoor environment where temperatures exceed 82 degrees.
**Key enforcement points:**
- Employers must have a written indoor heat illness prevention plan separate from (or explicitly incorporated into) their outdoor heat illness plan
- Temperature monitoring documentation is required
- Cool-down areas must be available and employees must be allowed to use them without reprisal
- Acclimatization procedures must be implemented for new employees and employees returning from absence
Notable Enforcement Actions — Recent
The following recent enforcement actions illustrate current priorities and penalty levels:
**Multi-site employer, warehousing (California, Q4 2025).** Cited for ergonomic hazards, indoor heat illness program deficiencies, and powered industrial truck violations across three facilities. Total proposed penalties exceeded $400,000. The per-instance calculation — same violations at multiple locations — drove the penalty multiplication.
**Construction contractor (California, Q1 2026).** Willful citation for fall protection violation that resulted in a fatality. The same standard had been cited at a different project two years prior. Willful-repeat classification. Proposed penalty: $165,514 for the single violation, plus additional serious citations totaling $82,000.
**Restaurant group (California, Q1 2026).** Cited under SB 553 for failure to maintain a WVPP after an employee was assaulted by a patron. Investigation revealed no WVPP, no training, no incident log. Serious citation classified. Total proposed penalties: $25,000. The real cost — workers' compensation claim, legal fees, operational disruption, and reputational damage — exceeded $200,000.
Q2 2026 Action Items for Employers
Based on current enforcement priorities, every California employer should verify the following before summer 2026:
**All industries:**
1. WVPP is current, site-specific, and your employees have been trained. Not documented as trained — actually trained.
2. Heat illness prevention program is activated and supplies are staged — water, shade structures, and cooling equipment are in place before the first heat wave, not in response to it.
3. IIPP annual review has been completed in the last 12 months.
**Construction:**
4. Fall protection plans are current for every active project.
5. Trenching and excavation procedures include competent person designation and daily inspections.
**Manufacturing:**
6. LOTO program has been inspected within the last 12 months.
7. Indoor heat illness plan addresses every work area that reaches 82 degrees.
**Warehousing:**
8. Forklift operator certifications are current — no expired certifications, no operators who were "going to get recertified next month."
9. Pallet rack inspections are documented and damage-flagged racks have been addressed.
**Hospitality:**
10. Late-night violence prevention protocols are documented and staff are trained.
11. Kitchen safety inspections are current.
The Intelligence Advantage
Enforcement intelligence is not academic. It is operational.
When you know where the regulators are looking, you can look there first. When you know what they are citing, you can fix it before they find it. When you know the penalty levels, you can calculate the ROI of compliance versus the cost of violation — and the math always favors compliance.
Protekon delivers enforcement intelligence as part of continuous compliance management. You do not read briefings and wonder whether they apply to you. The system maps enforcement priorities to your specific programs and flags the gaps that match current inspection targets.
The inspector does not announce their priorities. They demonstrate them with citations. This briefing gives you advance notice. Use it.