OSHA 2025 Penalty Update: Maximum penalties effective January 15, 2025 are $16,550 per serious violation, $16,550 per day for failure to abate, and $165,514 per willful or repeat violation. Facilities on OSHA's Severe Violator Enforcement Program (SVEP) face enhanced oversight and mandatory follow-up inspections. Aggie Safety has a documented track record of reducing and eliminating OSHA fines through representation at informal conferences and OSHA Review Commission proceedings.
Received an OSHA notice or EPA citation? Call (713) 613-2830 now for immediate assistance.
Federal OSHA (enforced by the U.S. Department of Labor) governs workplace safety in Texas. Texas does not operate a State Plan OSHA program, meaning federal OSHA has direct jurisdiction over private employers in Texas. OSHA's Houston-area offices cover Harris County and surrounding counties under the Houston North Area Office and the Houston South Area Office.
OSHA inspections are initiated under four triggers, listed in OSHA's priority order:
When an OSHA Compliance Safety and Health Officer (CSHO) arrives, the inspection has three phases: an opening conference (where the scope is defined and your rights are explained), a walkaround inspection (where the CSHO observes conditions, takes samples, photographs, and interviews employees), and a closing conference (where preliminary findings are discussed). Aggie Safety's on-site support is most critical during the opening conference -- where scope can be appropriately defined -- and during the walkaround, where our consultants accompany the inspector and document everything observed.
EPA enforcement in Texas operates through EPA Region 6 (Dallas) and is coordinated with the Texas Commission on Environmental Quality (TCEQ), which is the primary environmental enforcement agency for Texas. EPA can inspect independently under federal statutes or conduct joint inspections with TCEQ. For facilities with OSHA-regulated chemical processes, EPA and OSHA coordinate inspections under interagency MOUs -- meaning a single incident or complaint can trigger both agencies simultaneously.
EPA inspections in Texas are most commonly conducted under these statutes and programs:
Aggie Safety provides inspection support across all of these programs, with particular depth in CAA/RMP, RCRA, and EPCRA compliance -- the three programs most frequently triggered by multi-agency inspections of chemical and industrial facilities in the Houston area.
OSHA and EPA operate under formal interagency Memoranda of Understanding (MOUs) that require cross-referral of relevant findings. When an EPA inspector identifies workplace safety hazards during an environmental inspection, those observations are referred to OSHA. When an OSHA inspector identifies environmental concerns -- chemical releases, improper waste storage, stormwater discharge -- those are referred to EPA. For facilities regulated under both PSM (OSHA) and RMP (EPA), joint inspections are common, particularly following incidents or near-misses involving releases of regulated substances.
This cross-referral dynamic means that a facility that is managing OSHA compliance in isolation -- without awareness of its EPA exposure -- can be blindsided when a routine OSHA walkaround surfaces an RMP deficiency, or vice versa. Aggie Safety's integrated OSHA-EPA approach evaluates both regulatory frameworks simultaneously, so there are no blind spots.
Our inspection assistance is organized around the full regulatory lifecycle -- before, during, and after an inspection or citation. Most facilities only engage a consultant after a citation arrives. The facilities that achieve the best outcomes start before the inspector shows up.
The most cost-effective form of OSHA and EPA assistance is identifying violations before an inspector does. Aggie Safety conducts independent evidence-based audits of your facility against applicable OSHA standards and EPA regulations, using the same inspection protocols that federal CSHOs follow.
Pre-inspection gap analysis covers:
Output: a prioritized findings report with each deficiency mapped to the specific standard, the likely citation classification (Other-than-Serious, Serious, Willful, Repeat), estimated penalty exposure, and recommended corrective action. Facilities receive a defensible paper trail demonstrating good-faith compliance effort -- which is a direct input to penalty reduction at informal conference.
Aggie Safety provides on-site representation during OSHA inspections. Our consultants accompany the CSHO throughout the inspection, ensure that the scope is appropriately defined during the opening conference, document all observations made by the inspector, monitor employee interviews (employees have the right to speak privately with the inspector -- our role is to ensure the employer's rights are protected simultaneously), and prepare for the closing conference.
Critical actions during on-site inspection representation:
After an OSHA inspection, citations are issued by letter -- typically within six months of the inspection. You have 15 working days from receipt to contest a citation. This window is absolute; missing it eliminates your right to challenge. Aggie Safety helps clients:
Aggie Safety's informal conference track record includes complete penalty waivers and reductions exceeding 80% of the cited amount. Documented corrective actions taken before the conference, combined with evidence of good-faith compliance effort, are the two strongest factors in penalty reduction. Our pre-inspection work directly supports this outcome.
EPA enforcement actions in Texas are initiated through Notice of Violation (NOV), Compliance Order, or Consent Agreement and Final Order (CAFO) depending on the severity and the agency involved (EPA Region 6 or TCEQ). Aggie Safety assists facilities in:
Citations closed without adequate corrective action become repeat violations within five years -- and repeat violations carry maximum penalties of $165,514 per instance. Aggie Safety designs corrective actions that actually eliminate the cited hazard, not just satisfy the letter of the citation, and that are documented in a way that demonstrates systemic correction rather than point-in-time fixes.
Corrective action support includes:
OSHA and EPA enforcement intensity in Texas has increased consistently over the past decade. Texas has $40 million in total OSHA penalties on record, with 430 documented repeat violations. The OSHA Severe Violator Enforcement Program (SVEP) places facilities with certain willful or repeat violations on a public list with mandatory enhanced oversight -- of SVEP-enrolled employers, documented data shows 49 closed worksites, 23 dissolved entirely, and 46 discontinued the cited process. Aggie Safety provides ongoing compliance programs to keep facilities out of this enforcement tier:
| Violation Type | Maximum Penalty (2025) | Trigger | Aggie Safety Response |
|---|---|---|---|
| OSHA Other-than-Serious | $16,550 per violation | Condition not likely to cause death or serious physical harm | Document in corrective action; typically low penalty justifies quick remediation over contest |
| OSHA Serious | $16,550 per violation | Condition likely to cause death or serious physical harm and employer knew or should have known | Evaluate for reclassification to OTS; prepare corrective action documentation and good-faith evidence for informal conference |
| OSHA Willful | $165,514 per violation | Employer intentionally and knowingly violated the standard or was indifferent to employee safety | Contest and prepare full defense package; reclassification to Serious is primary goal; informal conference critical |
| OSHA Repeat | $165,514 per violation | Same or substantially similar violation within 5 years of a final prior citation | Evaluate prior citation history; challenge similarity argument; ensure corrective actions are documented to prevent recurrence |
| OSHA Failure to Abate | $16,550 per day beyond abatement date | Cited condition not corrected by abatement deadline in citation | Request abatement date extension before deadline; document progress; avoid this classification entirely |
| EPCRA Tier II (EPCRA Section 312) | Up to $174,985 per day per violation | Failure to submit annual Tier II report by March 1 or incomplete/inaccurate submission | File correct or amended submission immediately; prepare response with penalty mitigation factors including good faith and history of compliance |
| RCRA Hazardous Waste | Up to $93,058 per violation per day | Generator violations: improper storage, labeling, manifesting, training, recordkeeping | Correct deficiencies; prepare EPA penalty policy matrix response; document economic good faith |
| EPA CAA / RMP | Up to $70,117 per day per violation | 40 CFR Part 68 RMP non-compliance — missing or inadequate plan, failed PHA, unreported accident | Update RMP; conduct or update PHA; prepare written response to EPA NOV with corrective documentation |
| Clean Water Act / SWPPP | Up to $67,544 per day per violation | NPDES permit violation, inadequate SWPPP, lack of permit coverage for regulated discharge | Obtain permit coverage; update SWPPP; correct BMPs; document corrective actions for TCEQ response |
| Industry | Primary OSHA Exposure | Primary EPA Exposure | Aggie Safety Services |
|---|---|---|---|
| Chemical / Petrochemical | PSM covered process, HazCom, PPE, confined space | RMP (40 CFR 68), EPCRA Tier II, RCRA, CAA Title V, TCEQ air permits | Joint OSHA-EPA audit, PSM/RMP gap analysis, informal conference representation, RMP update |
| Oil & Gas Production and Processing | PSM, confined space, H2S/toxic gas, hot work, electrical | RMP, EPCRA Tier II, produced water discharge, stormwater | Pre-inspection mock walkaround, incident investigation, corrective action planning |
| General Manufacturing | Machine guarding, LOTO, ergonomics, noise, HazCom, recordkeeping | RCRA waste management, air permit compliance, Tier II, TRI reporting | Gap analysis, LOTO program development, noise conservation, Tier II and TRI reporting support |
| Construction | Falls (1926.501), excavation, electrical, struck-by, heavy equipment, silica | SWPPP/stormwater (construction sites 1+ acre), asbestos, lead | Pre-inspection audit, on-site OSHA representation, SWPPP development, subcontractor safety compliance |
| Food Processing | Machine guarding, LOTO, ergonomics, ammonia refrigeration (PSM), noise | EPCRA Tier II (ammonia), RCRA, wastewater (CWA) | PSM compliance for ammonia refrigeration, LOTO programs, noise conservation, Tier II reporting |
| Metals / Industrial | Machine guarding, LOTO, combustible dust (NEP), confined space, crane | RCRA metals waste, TRI reporting, stormwater | Dust hazard analysis, pre-OSHA NEP audit, corrective action implementation, RCRA compliance |
| Warehousing / Distribution | Forklift safety, racking, emergency exits, recordkeeping, fire protection | EPCRA Tier II if chemicals stored above thresholds | Pre-inspection walkaround, forklift program, HazCom program, 300 log compliance |
Discuss your situation: inspection trigger, citation received, compliance gap concern, or proactive audit request. We identify which OSHA standards and EPA programs apply to your facility, map your regulatory exposure, and recommend the appropriate engagement type and urgency level. If you have received a citation, this call happens immediately — the 15-working-day contest window does not wait.
Before any site visit, Aggie Safety reviews your existing compliance documentation: OSHA 300 logs, written programs, training records, PSM program elements, EPA permits, Tier II submissions, RCRA waste manifests, SWPPP, and any prior inspection or citation history. Documentation gaps found here are corrected before we are on-site.
We conduct a structured on-site walkthrough using OSHA and EPA inspection protocols. Our team inspects physical conditions, interviews supervisory staff, evaluates written programs against field implementation, and identifies the gaps that would be cited in an actual inspection. For clients facing an imminent inspection, this walkthrough is conducted as urgently as the situation requires — often within 24 to 48 hours.
You receive a written findings report with each deficiency mapped to the specific standard, classified by likely citation severity, estimated maximum penalty exposure, and recommended corrective action with implementation priority (immediate, 30-day, 90-day). The report serves two purposes: a corrective action roadmap for operations, and an evidence document demonstrating good-faith compliance effort if a citation is issued while corrections are in progress.
Aggie Safety supports implementation of corrective actions at whatever level the engagement requires: written program development, training delivery (English and Spanish), engineering control specification, equipment inspection, and documentation. We move at the pace your deadline requires.
If an inspection occurs, Aggie Safety provides on-site representation from the opening conference through the closing conference. If citations are issued, we prepare the informal conference defense package, represent you at the informal conference with OSHA's Area Director, and negotiate citation amendments and penalty reductions. For EPA NOVs and enforcement actions, we prepare written responses with technical rebuttal, corrective action evidence, and penalty mitigation arguments.
Post-citation corrective actions are documented and validated. We schedule follow-up audits to verify that corrective measures are in place and effective. For clients who want to avoid this process in the future, Aggie Safety offers annual compliance audits, regulatory monitoring alerts, and VPP/OSHCON engagement support to build and sustain a compliance program that keeps the inspector's clipboard empty.
Sumit Anand, PE, leads Aggie Safety's inspection assistance practice with more than 20 years of experience in oil and gas, petrochemicals, and gas processing -- industries with the most complex OSHA and EPA exposure in the Houston area. When an OSHA CSHO or EPA inspector is walking through a process unit, having a licensed process engineer who understands the equipment, the chemistry, and the regulatory standard they are evaluating is categorically different from having a generic safety consultant. That depth is what allows Aggie Safety to mount technically credible informal conference defenses, not just paperwork arguments.
Aggie Safety has represented clients at OSHA informal conferences with documented outcomes including complete penalty waivers and reductions exceeding 80% of cited amounts. These outcomes are not accidents -- they result from systematic pre-conference preparation: complete corrective action documentation, evidence of good-faith compliance effort, and technically accurate challenge of citation elements where the standard was misapplied. This track record is what sets Aggie Safety apart from general safety consultants who advise clients to accept citations and pay.
Most facilities manage OSHA compliance through their EHS department and EPA compliance through a separate environmental consultant. The consequence is blind spots: an OSHA program that does not account for RMP documentation requirements, or an EPA Tier II filing that does not reflect the current chemical inventory because operations did not communicate the change to the environmental team. Aggie Safety evaluates both frameworks simultaneously -- because the regulatory agencies that inspect you are coordinated with each other, and your compliance program needs to be too.
Our team is based in Houston and is bilingual in English and Spanish -- critical for facilities with Spanish-speaking workforces where OSHA's "in a language they understand" training requirement is a common citation vector. We are available on short notice for urgent inspection situations. An OSHA inspector arriving unannounced at 8:00 AM does not wait for your consultant to book a flight from Dallas. Aggie Safety is Houston-based and responds to urgent situations accordingly.
The best outcome in OSHA and EPA compliance is an inspection that finds nothing citable. Aggie Safety helps clients build the programs, documentation, and training that make that outcome achievable -- pre-inspection, not post-citation. And for clients who are already in the citation process, we are the team that achieves the best possible resolution and then helps build the program that prevents a repeat. Visit our About Us page for full team credentials.
