A compliance officer walks a building your crew cleans, writes up four items, and hands you a citation. For most owner-operators in contract cleaning, that is where the story ends in practice. The citation gets mailed to the office, somebody signs for it, it goes in a drawer, and the crew leader at the site never hears about it.
OSHA's rules assume the opposite. What OSHA requires after a citation divides into four clocks, and all four are short. Miss the first and you have given up your right to contest. Miss the second and the penalty can start accruing daily. Miss the third and the next inspection has a repeat.
None of this is exotic. It is 29 CFR Parts 1903 and 1904, printed plainly, and it lands on a 20-person janitorial firm the same way it lands on a refinery.
The first 15 working days decide whether you have a case
Under 29 CFR 1903.17(a), an employer who contests must notify the Area Director in writing, and that notice must be postmarked within 15 working days of receiving the notice of proposed penalty. The notice must specify whether it is aimed at the citation, the penalty, or both. The same section gives employees and their representatives 15 working days to object to the abatement date.
Abatement needs a certificate, not just a repair
Fixing the hazard is the easy part. Proving it is a separate requirement, and it is the one small contractors miss.
29 CFR 1903.19(c)(1) requires the employer to certify to OSHA that each cited violation has been abated, within 10 calendar days after the abatement date. There is one narrow exception in 1903.19(c)(2): no certification is needed if the compliance officer saw during the on-site portion of the inspection that abatement had already happened within 24 hours of the violation being identified, and noted it in the citation.
The certificate, per 1903.19(c)(3), must give the date and method of abatement for each cited item and state that affected employees and their representatives have been told. Where the citation says so, 1903.19(d) requires proof the fix is complete, and accepts purchase or repair records, photographs or video, or other written records.
If the time allowed runs past 90 calendar days, 1903.19(e)(1) lets OSHA require an abatement plan, due within 25 calendar days of the final order date.
Posting is its own citation item
29 CFR 1903.16(a) requires the employer to post the citation, unedited, immediately on receipt, at or near each place the alleged violation occurred, or in a prominent place readily observable by all affected employees where the first is not practicable. For dispersed work, the regulation points to where employees report each day or where they operate from.
Subsection (b) is the multi-site trap. The citation stays posted until the violation is abated or for 3 working days, whichever is later, and filing an intent to contest does not relieve the employer unless the Review Commission vacates the citation. For a contractor whose crews rotate through six buildings, somebody has to post it at the right building and take it down on the right day. Failing to post is itself citable, and 1903.15(d)(6) caps that penalty at $16,550.
The penalty numbers
29 CFR 1903.15(d) sets the penalties proposed after January 15, 2025. A willful violation runs from $11,823 to $165,514. Repeated violations cap at $165,514. Serious and other-than-serious violations both cap at $16,550, and a failure to correct runs up to $16,550 per day.
A serious citation is not a rounding error against a mid-size janitorial contract, and a repeat is a different order of magnitude. 1903.15(b) is the part worth using: the Area Director must weigh the size of the business, the gravity of the violation, the employer's good faith, and the history of previous violations, so a record of prompt, documented abatement earns something back.
The OSHA 300 Log is the other half
Abatement certification is a promise to the agency. The injury records are the evidence of what happened. Under 29 CFR 1904.29(b)(3), each recordable injury or illness goes on the OSHA 300 Log and the 301 Incident Report within seven calendar days of receiving the information.
What counts as recordable is where experience modifier arguments start. 1904.7(a) lists the triggers: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. It also captures a significant injury or illness diagnosed by a physician or other licensed health care professional even when none of those applies.
Two dates are easy to forget once the year turns. The annual summary has to be posted no later than February 1 of the following year and stay up until April 30, in each establishment where notices to employees are customarily posted, certified by an owner, a corporate officer, or the highest-ranking official at the establishment or that official's immediate supervisor. And 1904.33(a) requires keeping the 300 Log, the privacy case list, the annual summary and the 301 forms for five years after the end of the calendar year they cover.
Meanwhile the citation file exists for a different reason. The day a client's risk manager or a broker asks for three years of logs, it becomes the file that decides whether the bid goes in.
The folder to build before you need it
The practical version fits in one folder per establishment: the citation as received, with the date of receipt written on it; a note on whether it was contested and by when the notice had to be postmarked; the abatement date for each item; the certificate with its photographs, invoices or repair records; the date it was posted and the date it came down; and the current year's 300 Log and 301 forms with last year's 300-A summary.
Two of those documents are due within 15 working days and 10 calendar days. The rest depend on a person remembering. Building the folder is the cheapest insurance in the business, and it is the one piece of compliance work the next inspection will read as good faith.
Primary sources: 29 CFR 1903.15, 1903.16, 1903.17, 1903.19, 1904.7, 1904.29 and 1904.33, as published on eCFR and current as of October 30, 2026. Check the deadlines against your state plan; several states run their own rules.
