Period: October 2024 – September 2025
Executive Summary
During the fiscal period of October 2024 through September 2025, OSHA issued a total of 20 citations following 14 inspections related to Standard 1910.120. The total current penalty for these violations is $167,073, averaging approximately $8,354 per citation.
The data indicate that the Manufacturing sector is the primary target for enforcement of this standard, accounting for 60% of all citations issued during this period.
Citation Data by Economic Sector (2-Digit NAICS)
The table below breaks down the enforcement actions and financial impact across various industry sectors.
| NAICS Sector | Citations | Inspections | Total Penalty | Industry Classification |
| Total | 20 | 14 | $167,073 | All Industries |
| 31–33 | 12 | 8 | $85,517 | Manufacturing (Combined) |
| 49 | 2 | 1 | $33,100 | Transportation and Warehousing |
| 21 | 2 | 2 | $20,522 | Mining, Quarrying, and Oil/Gas |
| 22 | 1 | 1 | $11,585 | Utilities |
| 42 | 2 | 1 | $11,349 | Wholesale Trade |
| 72 | 1 | 1 | $5,000 | Accommodation and Food Services |
Industry Insights & Analysis
1. Manufacturing Dominance
The Manufacturing sector (Sectors 31, 32, and 33) consistently faces the highest volume of scrutiny under 1910.120. This is likely due to the prevalent use of hazardous chemicals in production and the requirement for on-site emergency response teams (HAZMAT) to manage potential spills or releases.
2. High-Penalty Outliers
While the Manufacturing sector had the most citations, the Transportation and Warehousing (NAICS 49) sector shows a significantly higher penalty-to-inspection ratio. With a $33,100 penalty from just a single inspection, this suggests a “Serious” or “Willful” violation, potentially related to large-scale chemical storage or logistics mishaps.
3. Standard Overview: What is 1910.120?
Commonly known as HAZWOPER, this standard covers five distinct groups of employers and their employees, focusing on:
- Cleanup operations at uncontrolled hazardous waste sites.
- Corrective actions involving cleanup at RCRA sites.
- Voluntary cleanup operations.
- Operations at TSD (Treatment, Storage, and Disposal) facilities.
- Emergency response operations for releases of hazardous substances.
Definitions & Notes
- Current Penalty: The amounts shown reflect the penalty after any adjustments or settlements made during the informal conference or contest process, rather than the initial proposed amount.
- Inspection vs. Citation: An inspection can result in multiple citations if several sub-sections of the 1910.120 standard (such as training, PPE, or site control) are found to be non-compliant.
- NAICS: North American Industry Classification System, used by Federal statistical agencies in classifying business establishments.
Source: Gemini Plus was used to analyze the OSHA data to generate this summary