Methodology

How CitationPack builds federal OSHA deadline calculations, public comparable cohorts, and penalty-rule worksheets.

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Data source

Comparable-case stats come from public OSHA/DOL enforcement records loaded into CitationPack’s analytics database. State-plan private-sector citations are excluded from the v1 product path.

Penalty medians

Median proposed and current penalties are computed over items with a nonzero penalty. Items issued with no penalty and items that ended at zero dollars are shown separately as zeroing rates.

Cohort construction

Standard pages prefer exact standards and standard-family rollups. State pages prioritize federal OSHA records for that state code. Every display discloses total records and penalized-record counts.

Typical range

The typical range is a rule of thumb, not a statistic. For each citation item the low end is the recalculated penalty or 45% of the proposed penalty, whichever is lower, and the high end is 75% of the proposed penalty; neither goes below OSHA’s minimum or above its maximum for the classification. The report total adds the items together, then caps the low end at 85% and the high end at 115% of the amount the median reduction in the comparable public cases would give. The 45% and 75% figures are fixed CitationPack assumptions, not values measured from public data. Items that are not recalculated (willful, other-than-serious, posting, and failure-to-abate items, and repeat items that are other-than-serious or whose type is not stated and whose penalty is too small for a serious repeat) have no typical range: the report shows OSHA’s proposed penalty for them as issued.

Penalty rules

The penalty worksheet uses the adjustment factors and order of OSHA Field Operations Manual Chapter 6 in force on the citation’s issuance date: the chapter as revised effective July 14, 2025 for citations issued on or after that date, and the chapter as it read before that revision for citations issued from January 16, 2025 through July 13, 2025. Maximums, minimums, and gravity-based penalties come from the OSHA annual civil-penalty memorandum in force on the issuance date: the May 21, 2026 memorandum for citations issued after January 15, 2026, and the January 7, 2025 memorandum’s amounts before that. Citations issued on or before January 15, 2025 are not recalculated.