HVAC OSHA Violations: The Most-Cited Standards and Penalties at Plumbing and HVAC Contractors, FY2015 to FY2026

Trench rules, not fall protection, top the list of HVAC OSHA violations at plumbing and HVAC contractors

In federal OSHA inspections opened FY2021 to FY2025, the two excavation standards were cited 513 times at NAICS 238220 contractors. Fall protection, the all-industry leader, ranked second as a single standard.

Plumbing and HVAC contractors (NAICS 238220): The Census Bureau's NAICS 238220 covers establishments that install and service plumbing, heating and air-conditioning equipment, including HVAC, mechanical, refrigeration, fire sprinkler and lawn sprinkler contractors (Census NAICS 2022). OSHA records cannot separate HVAC-only shops from plumbers inside this code.

This desk ranked every non-deleted federal citation in the DOL OSHA violation file (extract of 2026-11-01) by the 29 CFR section it cites. Of 2,485 federal citations coded to a 29 CFR standard at NAICS 238220 in FY2021 to FY2025, 1926.651 (specific excavation requirements) had 306, 1926.501 (duty to have fall protection) had 287 and 1926.652 (cave-in protective systems) had 207.

Penalty totals rank differently from citation counts. Fall protection carried the most current penalties, $1,315,565, followed by cave-in protection at $1,289,775. Per citation, 1926.652 averaged $6,231 and 1910.147 (lockout/tagout) $5,423, against $1,345 for hazard communication.

The paragraph view shows what inspectors actually wrote up. Cave-in protection, 1926.652(a)(1), leads with 169 citations, then unprotected edges 6 feet or higher, 1926.501(b)(1), with 122. Three more of the top ten paragraphs are excavation rules: egress ladders in trenches 4 feet or deeper, spoil piles kept 2 feet back from the edge, and daily competent-person inspections (1926.651).

For an owner, the list points at field work rather than the shop: digging for sewer, water and gas lines, ladders and roof edges. A paperwork item also ranks high: 29 CFR 1904.39(a)(2) requires a report to OSHA within 24 hours of an in-patient hospitalization, amputation or eye loss, and it was cited 69 times.

Cave-in citations run at 9.8 times their all-industry share

Trench and excavation rules were 20.6% of federal 29 CFR citations at plumbing and HVAC contractors in FY2021 to FY2025 and 2.1% across all industries in FY2025. Most of OSHA's all-industry top 10 still appears on the trade's list.

OSHA's FY2025 top 10 lists ranks but no counts, so this desk counted all-industry federal citations for inspections opened in FY2025 from the same DOL file: 48,073 citations coded to 29 CFR, of which 1,009 were under 1926.651 or 1926.652. At NAICS 238220 the figure was 513 of 2,485 over five years.

Nine of OSHA's ten all-industry standards rank within the top 20 for plumbing and HVAC contractors. Machine guarding (1910.212) is the outlier: 14 federal citations at NAICS 238220 in five years. Respiratory protection (1910.134) ranks fifth for all industries and 14th for this trade. The trade-specific entries that OSHA's list misses are excavation, head protection (1926.100), safety training (1926.21) and injury reporting (1904.39).

OSHA opened 1,266 inspections of plumbing and HVAC contractors in FY2025, most of them planned site visits

Inspection counts fell from 1,582 in FY2015 to 858 in FY2021 and recovered to 1,266 in FY2025. Programmed inspections, the visits OSHA schedules itself, were 56.0% of the FY2025 total.

The DOL OSHA inspection file records why each inspection was opened. Field definitions come from the DOL dataset metadata: H (planned), I (programmed related) and K (programmed other) are grouped here as programmed; A (accident) and M (fatality/catastrophe) as accident or fatality; G is OSHA's unprogrammed related code.

In FY2025 the 1,266 inspections split into 709 programmed, 210 referrals, 127 complaints, 90 accident or fatality inspections and 100 unprogrammed related inspections. Federal OSHA offices opened 531 and State Plan offices 735. Plumbing and HVAC contractors were 1.84% of all 68,702 OSHA inspections that year.

Most inspected shops are small. The median establishment size recorded at inspection was 6 employees in FY2021 to FY2025, and 64.6% of inspections were at establishments with 10 or fewer. For an owner, a small headcount does not keep OSHA away: most inspections in the file were at shops of 10 or fewer people.

The typical cited inspection costs a few thousand dollars; 4 cases topped $100,000

Across FY2021 to FY2025 the median current penalty per inspection with a violation was $2,391 and the mean $4,942. Settlements and contests reduced the initial amounts by 30.2%.

Current penalty: The penalty on the record after informal settlement, contest or other adjustment, as of the extract date. The initial penalty is the amount proposed when the citation was issued. This report uses current penalties unless it says initial.

Penalties here are the sum of current penalties on every non-deleted citation item in one inspection, for inspections with at least one violation. In FY2021 to FY2025, 3,056 NAICS 238220 inspections had a violation. Initial penalties totaled $21,640,404 and current penalties $15,101,532.

The distribution is lopsided. 35.2% of cited inspections landed between $1,000 and $4,999, while the largest 1% of inspections carried 15.0% of all current penalties. The largest single-inspection total was $264,820. This report does not name the employers behind individual cases.

Federal and State Plan penalties diverge. Federal OSHA's median rose from $2,160 in FY2015 to $5,206 in FY2025, while the State Plan median was $918 in FY2025. The period spans the 2016 catch-up adjustment and the annual inflation increases to the maximums described in the 2026 DOL notice. FY2026 figures are preliminary because citations and settlements are still being entered.

Contractors in State Plan states are inspected about twice as often per shop

Measured against 2023 County Business Patterns establishment counts, State Plan states averaged 14.3 plumbing and HVAC inspections per 1,000 establishments a year in FY2021 to FY2025, and federal OSHA states 7.57.

29 CFR Part 1952 lists 22 jurisdictions with State Plans covering private employers, including Puerto Rico. In those states a state agency, not federal OSHA, inspects private contractors. Inspections are counted by site state; establishments come from the Census CBP 2023 state file, which counts 111,207 NAICS 238220 employer establishments in the 50 states and DC.

Michigan led the states at 39.53 inspections per 1,000 establishments a year, followed by Hawaii (31.76) and West Virginia (30.05). Large federal-OSHA states were low: Texas 5.91, Florida 2.89. The District of Columbia (156.76) is an artifact of the method: contractors based in Maryland and Virginia work on DC sites, but only 37 plumbing and HVAC establishments are located there.

State Plans also record citations differently. Only 46.3% of State Plan citations at NAICS 238220 in FY2021 to FY2025 carry a 29 CFR number; states such as California, Washington, Oregon and Michigan cite their own rule numbers. That is why the standards ranking above uses federal OSHA citations only.

Maximum OSHA fines stayed at 2025 levels for 2026 because October CPI data were never published

The maximum federal penalty is $16,550 per serious violation and $165,514 per willful or repeated violation. DOL made no 2026 adjustment.

29 CFR 1903.15(d) sets the amounts for penalties proposed after January 15, 2025, under the 2025 adjustment rule (90 FR 1854). The May 27, 2026 notice says the statute ties each year's adjustment to October CPI-U, which BLS did not publish for October 2025 during the funding lapse, so the 2025 amounts continue.

Actual penalties sit far below the ceilings. The federal median per cited plumbing and HVAC inspection, $5,000, equals 30.2% of one serious-violation maximum. 29 CFR 1903.15(b) directs the Area Director to weigh the size of the business, the gravity of the violation, good faith and history of previous violations.

State-by-state findings

1. Federal OSHA cited 29 CFR 1926.651 (specific excavation requirements) 306 times at plumbing and HVAC contractors in FY2021 to FY2025, more than any other standard.^[2][13]
2. 29 CFR 1926.652(a)(1), the cave-in protection requirement, was the single most-cited paragraph for NAICS 238220 in FY2021 to FY2025, with 169 federal citations.^[2][14]
3. Trench and excavation citations carried $2,259,573 in current penalties, 25.9% of the $8,718,630 federal OSHA assessed on NAICS 238220 inspections opened in FY2021 to FY2025.^[2]
4. Fall protection standards 1926.501 to 1926.503 made up 15.8% of federal 29 CFR citations at plumbing and HVAC contractors in FY2021 to FY2025, below the 19.3% all-industry share in FY2025.^[2][15]
5. The top 15 standards accounted for 68.5% of federal 29 CFR citations at NAICS 238220 in FY2021 to FY2025.^[2]
6. Failure to report a hospitalization, amputation or eye loss within 24 hours (29 CFR 1904.39(a)(2)) was cited 69 times at plumbing and HVAC contractors in FY2021 to FY2025.^[2][18]
7. OSHA opened 1,266 inspections of NAICS 238220 contractors in FY2025: 709 programmed, 210 referrals, 127 complaints and 90 accident or fatality inspections.^[1][3]
8. Plumbing and HVAC contractors were 1.84% of all 68,702 OSHA inspections opened in FY2025, federal and State Plan combined.^[1]
9. Across FY2021 to FY2025, 53.1% of 5,755 NAICS 238220 inspections produced at least one violation: 43.1% under federal OSHA and 61.9% under State Plans.^[1][2]
10. The median current penalty per NAICS 238220 inspection with a violation was $2,391 in FY2021 to FY2025, the mean $4,942 and the 90th percentile $12,000.^[2]
11. Only 4 of 3,056 plumbing and HVAC inspections with a violation in FY2021 to FY2025 reached $100,000 in current penalties; 488 (16.0%) ended with $0.^[2]
12. The federal OSHA median penalty per plumbing and HVAC inspection with a violation rose from $2,160 in FY2015 to $5,206 in FY2025 (nominal dollars).^[2]
13. State Plan states inspected NAICS 238220 contractors at 14.3 per 1,000 establishments a year in FY2021 to FY2025, against 7.57 in federal OSHA states.^[1][5][8]
14. Michigan had the highest state rate, 39.53 inspections per 1,000 plumbing and HVAC establishments a year in FY2021 to FY2025; Florida had 2.89 and Texas 5.91.^[1][5]

Rankings and ratios we derived

Download the calculations (CSV)

Executive summary

• Trench and excavation standards (29 CFR 1926.651 and 1926.652) drew 513 of 2,485 federal 29 CFR citations at plumbing and HVAC contractors in FY2021 to FY2025 (20.6%), against 2.1% across all industries in FY2025.
• Fall protection (1926.501) is the single most-cited standard for all industries but ranks second for this trade, with 287 federal citations in FY2021 to FY2025 and the largest penalty total, $1,315,565.
• OSHA opened 1,266 inspections of NAICS 238220 contractors in FY2025, down 20.0% from 1,582 in FY2015; 56.0% were programmed (planned) inspections.
• In FY2021 to FY2025, 53.1% of inspections ended with at least one violation, averaging 2.44 violations each.
• The median current penalty per inspection with a violation was $2,391 and the mean was $4,942; settlements and contests cut initial penalties by 30.2%.
• Federal OSHA's median penalty ($5,000) was 5.6 times the State Plan median ($900), yet State Plan states inspected these contractors 1.9 times as often per 1,000 establishments.
• Maximum federal penalties stay at the 2025 amounts in 2026 ($16,550 serious, $165,514 willful or repeated) because the October 2025 CPI-U needed for the annual adjustment was never published.

Frequently asked questions

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Reproduce this analysis

Every figure comes from the files below. The scripts that pulled and computed them are kept with the report and can be re-run.

Data quality and exclusions

• 416 NAICS 238220 records with scope D (no inspection conducted) in FY2015 to FY2026 were excluded.
• 66 NAICS 238220 inspections opened in FY2027 (October 2026) were excluded as a partial year.
• 1,243 violation rows flagged deleted were excluded.
• 20 federal citations in FY2021 to FY2025 not coded to a 29 CFR section (for example the General Duty Clause) were left out of the standards ranking.
• 4,937 State Plan citations in FY2021 to FY2025 were left out of the standards ranking because only 46.3% carry 29 CFR numbers; they remain in penalty and inspection counts.
• 84 inspections in FY2021 to FY2025 with a site in a territory were left out of the state rate table.
• Establishment names, addresses and mailing fields were dropped at extraction; no employer is named.

Methodology

Sources. Inspection and violation records come from the US Department of Labor's complete OSHA downloads on its Open Data Portal (files dated 2026-11-01, HTTP Last-Modified 1 Nov 2026), streamed and filtered by scripts/01_stream_extract.py without an API key. Field definitions come from the portal's dataset metadata. Establishment counts come from Census County Business Patterns 2023, the latest release posted at www2.census.gov on 2026-11-02. Regulations were read on eCFR (Title 29 current to 2026-10-29) and in the Federal Register.

Inclusion. An inspection is in scope if its NAICS code is 238220 and its open date falls in FY2015 to FY2026 (October 1, 2014 to September 30, 2026). Records with scope D (no inspection conducted) and FY2027 openings are excluded. A violation is one non-deleted citation item; grouped items count separately, as in OSHA's own frequently cited standards counts. Inspections are assigned to the fiscal year they opened, not the year a citation was issued.

Jurisdiction. An inspection is federal or State Plan by its reporting office (third digit 5 of the reporting ID marks a State Plan office). Checked against 29 CFR 1952: in every listed State Plan state at least 85% of NAICS 238220 inspections came from State Plan offices, and in every other state at least 98% came from federal offices. For the state table, a state is a State Plan state if 29 CFR 1952 Subpart A lists a plan covering private employers. The standards ranking uses federal citations only, because State Plans often cite their own rule numbers.

Penalties. Current penalty is used throughout unless a figure says initial. Per-inspection totals sum all non-deleted items; medians and means are taken across inspections with at least one violation. Dollars are nominal. Conflicting numbers: OSHA's official FY2025 top 10 publishes ranks only; this desk's own FY2025 count orders ladders and hazard communication the other way round (2,731 vs 2,707 citations), likely because OSHA's list and this count use different date rules. Both are shown.

Limits and updates. FY2026 is preliminary. Recent penalties can change through contest. The data do not separate HVAC from plumbing work. Last updated 2026-11-02; the DOL files refresh daily and this report will be rerun when FY2026 cases close. The research desk is part of HVAC Business Brokers.

This report presents published data with its limitations. It is not legal, financial or investment advice.

Sources, ranked by quality

Tier 1: primary and official sources (27)

• [1] US Department of Labor, Open Data Portal. OSHA Inspection dataset, complete download (extract of 2026-11-01). inspections opened FY2015 to FY2026. Accessed 2026-11-02.
• [2] US Department of Labor, Open Data Portal. OSHA Violation dataset, complete download (extract of 2026-11-01). citations for inspections opened FY2015 to FY2026. Accessed 2026-11-02.
• [3] US Department of Labor, Open Data Portal. OSHA Inspection dataset metadata and field definitions (dataset 10334). 2026. Accessed 2026-11-02.
• [4] US Department of Labor, Open Data Portal. OSHA Violation dataset metadata and field definitions (dataset 10338). 2026. Accessed 2026-11-02.
• [5] US Census Bureau. County Business Patterns 2023, state file (cbp23st). 2023. Accessed 2026-11-02.
• [6] US Census Bureau. 2022 NAICS descriptions file. NAICS 2022. Accessed 2026-11-02.
• [7] eCFR, Office of the Federal Register. 29 CFR 1903.15, Proposed penalties (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [8] eCFR, Office of the Federal Register. 29 CFR Part 1952, Approved State Plans for Enforcement of State Standards (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [9] Federal Register, US Department of Labor. Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2025 (90 FR 1854, FR Doc. 2024-31602). 2025. Accessed 2026-11-02.
• [10] Federal Register, US Department of Labor. Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2026 (91 FR 31358, FR Doc. 2026-10456). 2026. Accessed 2026-11-02.
• [11] OSHA, US Department of Labor. Top 10 Most Frequently Cited Standards, FY2025 (Internet Archive copy of osha.gov, 2026-09-12). FY2025. Accessed 2026-11-02.
• [12] GovInfo, US Government Publishing Office. 29 U.S.C. 666, Civil and criminal penalties (US Code 2023 edition). 2023 edition. Accessed 2026-11-02.
• [13] eCFR, Office of the Federal Register. 29 CFR 1926.651, Specific excavation requirements (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [14] eCFR, Office of the Federal Register. 29 CFR 1926.652, Requirements for protective systems (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [15] eCFR, Office of the Federal Register. 29 CFR 1926.501, Duty to have fall protection (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [16] eCFR, Office of the Federal Register. 29 CFR 1926.1053, Ladders (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [17] eCFR, Office of the Federal Register. 29 CFR 1910.1200, Hazard communication (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [18] eCFR, Office of the Federal Register. 29 CFR 1904.39, Reporting fatalities, hospitalizations, amputations, and losses of an eye (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [19] eCFR, Office of the Federal Register. 29 CFR 1926.21, Safety training and education (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [20] eCFR, Office of the Federal Register. 29 CFR 1926.100, Head protection (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [24] eCFR, Office of the Federal Register. 29 CFR 1926.503, Training requirements (fall protection) (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [25] eCFR, Office of the Federal Register. 29 CFR 1926.20, General safety and health provisions (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [26] eCFR, Office of the Federal Register. 29 CFR 1910.28, Duty to have fall protection and falling object protection (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [27] eCFR, Office of the Federal Register. 29 CFR 1910.147, The control of hazardous energy (lockout/tagout) (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [28] eCFR, Office of the Federal Register. 29 CFR 1926.451, General requirements (scaffolds) (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [29] eCFR, Office of the Federal Register. 29 CFR 1910.134, Respiratory protection (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.
• [30] eCFR, Office of the Federal Register. 29 CFR 1926.1052, Stairways (eCFR, current to 2026-10-29). current to 2026-10-29. Accessed 2026-11-02.

Tier 3: journalism and expert commentary (3)

• [21] FieldBoss. Top 10 OSHA Violations for Elevator and HVAC Contractors in 2021. 2021. Accessed 2026-11-02.
• [22] ACHR News. An HVAC Contractors' Guide to Passing an OSHA Inspection. 2023. Accessed 2026-11-02.
• [23] ACCA HVAC Blog. Have You Reviewed the OSHA Top 10 Recently?. 2024. Accessed 2026-11-02.