Iowa OSHA state plan — coverage, jurisdiction, and federal OSHA exceptions
Iowa operates an OSHA-approved state plan covering most private-sector employers and employees, as well as all state and local government workers. The plan received initial approval on July 20, 1973, and final approval on July 2, 1985. Iowa OSHA (administered by the Department of Inspections, Appeals, & Licensing) enforces workplace safety and health standards, conducts inspections, and issues citations for violations.
Federal OSHA jurisdictional exceptions — what Iowa OSHA does not cover Federal OSHA, not Iowa OSHA, has authority over several types of employment and workplace safety enforcement in Iowa:
- Maritime employment (private-sector shipyard employment, marine terminals, and longshoring; see 29 C.F.R. 1915, 1917, 1918)
- United States Postal Service operations (including contract workers or contractor-operated mail facilities)
- Federal government–owned and contractor-operated military or munitions facilities
- Bridge construction projects spanning the Mississippi or Missouri Rivers between Iowa and another state
- Agricultural field sanitation (29 C.F.R. 1928.110) and temporary labor camps (29 C.F.R. 1910.142) where workers are engaged in “agricultural employment” under the Migrant and Seasonal Agricultural Worker Protection Act (29 U.S.C. 1802(3)), except Iowa retains jurisdiction for egg, poultry, red meat production, or post-harvest agricultural processing camps
- Any hazard, industry, geographic area, operation, or facility over which Iowa cannot effectively exercise jurisdiction for reasons unrelated to state plan performance or structure
Federal OSHA also retains:
- Authority to enforce retaliation/whistleblower protection under Section 11(c) (29 U.S.C. 660(c)) in the private sector, even where Iowa OSHA otherwise covers the employer
- Standard-setting and oversight authority under Sections 6 and 18(f) of the OSH Act, including the right to resume enforcement if the state plan lapses
Employers should identify whether their worksite or type of operation falls under these exceptions to determine the correct compliance and reporting authority.
Source: Iowa State Plan — OSHA Coverage; 29 C.F.R. Part 1952
Injury and fatality reporting deadlines to Iowa OSHA
Employers must report any work-related employee fatality to Iowa OSHA within eight hours. Work-related in-patient hospitalizations, amputations, or eye losses must be reported within 24 hours. Reports may be made by calling 877-242-6742 or by submitting the incident report form available at the Iowa OSHA enforcement page. Iowa's state plan adopts the federal reporting requirements under 29 C.F.R. § 1904.39, which apply to all employers regardless of whether they are otherwise exempt from routine injury and illness recordkeeping.
Source: Iowa OSHA Enforcement & Compliance & 29 C.F.R. § 1904.39
Iowa OSHA injury and illness recordkeeping requirements (Forms 300/300A) and retention period
Which Iowa employers must keep OSHA injury and illness records?
Iowa, as an OSHA-approved state plan, has adopted the federal injury and illness recordkeeping requirements found in 29 C.F.R. Part 1904. Most private-sector employers in Iowa with 11 or more employees must prepare and maintain records of serious work-related occupational injuries and illnesses using OSHA Forms 300 (Log of Work-Related Injuries and Illnesses), 300A (Summary), and 301 (Injury and Illness Incident Report). Certain low-risk industry employers, as defined by federal regulation (see OSHA's list of Partially Exempt Industries in Appendix A to Subpart B of 29 C.F.R. § 1904), are exempt from these recordkeeping requirements unless specifically required by Iowa OSHA or the Bureau of Labor Statistics to keep records.
Small employer and industry-specific exemptions
- Employers with 10 or fewer employees at all times during the previous calendar year are exempt from routine OSHA injury and illness recordkeeping, unless specifically requested in writing by Iowa OSHA or the Bureau of Labor Statistics (see 29 C.F.R. § 1904.1).
- Employers in industries classified as "partially exempt" (such as certain retail, service, finance, and insurance businesses) may be exempt from maintaining OSHA logs, unless otherwise notified (see 29 C.F.R. § 1904.2).
Retention period for records Iowa employers who are required to keep OSHA Forms 300, 300A, and 301 must retain these records for at least five years following the end of the calendar year that the records cover (29 C.F.R. § 1904.33(a)). During the retention period, records must be updated to reflect any changes and be made available for inspection by Iowa OSHA, employees, and employee representatives.
State-specific variation As of this writing, Iowa follows the federal recordkeeping and retention standards. If Iowa OSHA imposes stricter requirements or publishes updates, employers must comply with those directives.
Source: Iowa OSHA - Enforcement & Compliance and 29 C.F.R. §§ 1904.1, 1904.2, 1904.33
Iowa OSHA civil penalty amounts for serious, willful, repeat, and other-than-serious violations
Iowa OSHA, operating under an approved State Plan, is required by Iowa Admin. Code r. 875—3.11(88) to adopt civil penalty levels for workplace safety violations that are at least as effective as those set by federal OSHA. The current schedule became effective June 1, 2025, and establishes the following maximum (and, where applicable, minimum) penalties:
- Willful or Repeat Violations: The maximum penalty for each willful or repeat violation is $156,259, and the minimum penalty for a willful violation is $11,162.
- Serious Violations: The maximum penalty for each serious violation is $15,625.
- Other-than-Serious Violations: The maximum penalty for each other-than-serious violation is $15,625.
- Failure to Correct (Abatement) Violations: The maximum is $15,625 per day for each day the violation continues beyond the abatement date.
- Posting, Reporting, and Recordkeeping Violations: The maximum penalty for each violation of posting, reporting, or recordkeeping requirements is $15,625.
These amounts are specified in Iowa Admin. Code r. 875—3.11(88) and match the federal OSHA penalty levels effective as of June 1, 2025; future changes to federal OSHA penalties may prompt further updates to the Iowa schedule, but employers should rely on the regulation for the current values.
Source: Iowa Admin. Code r. 875—3.11(88)
Procedure and deadline to contest an Iowa OSHA citation or proposed penalty
Deadline to Contest Employers who wish to contest a citation, proposed penalty, or abatement period issued by Iowa OSHA must file a notice of contest within 15 working days after receiving the citation or notification of penalty. This 15-day window is strictly enforced—if the employer does not file within the timeframe, the citation and proposed penalties become a final order of the Iowa labor commissioner and are not subject to further review or appeal under state law. (See Iowa Code § 88.8(1); Iowa Admin. Code r. 875-3.15(88)).
Method and Contents of Notice The notice of contest must be submitted in writing to the Iowa labor commissioner. The contest can challenge:
- the citation (existence/seriousness of the violation),
- the proposed penalty, and/or
- the required abatement period.
The notice should clearly identify which aspects are being contested. While there is no state-mandated form, the submission must specify the citation and be received or postmarked by the deadline. (Iowa Admin. Code r. 875-3.15(88); Iowa Code § 88.8(1)).
After Contest is Filed When a timely notice of contest is filed, the labor commissioner must immediately notify the OSHA Employment Appeal Board, and an evidentiary hearing will be scheduled, where both the employer and the state may present arguments and evidence. (Iowa Code § 88.8(1)).
Practical pointer: the 15 working days excludes weekends and legal holidays, but the window is strictly construed—delays frequently forfeit contest rights.
Source: Iowa Code § 88.8(1) and Iowa Admin. Code r. 875-3.15(88)
Iowa OSHA recordkeeping exemptions for small employers (10 or fewer employees)
Iowa OSHA follows the federal OSHA injury and illness recordkeeping exemptions for small employers. Under 29 C.F.R. § 1904.1, employers with 10 or fewer employees at all times during the previous calendar year are exempt from the federal requirement to routinely prepare and maintain OSHA injury and illness records (Forms 300, 300A, and 301), unless specifically requested in writing to keep records by Iowa OSHA, the U.S. Department of Labor, or the Bureau of Labor Statistics.
This headcount threshold applies to the total number of employees (full-time, part-time, temporary, and seasonal) across all of the employer’s establishments combined, not just at a single location. If the employer exceeded 10 employees at any time during the previous calendar year, the exemption does not apply for the current year.
This small-employer exemption does not apply to the separate requirement that all employers, regardless of size, must report any work-related fatality, in-patient hospitalization, amputation, or eye loss to Iowa OSHA within the required timeframe (see 29 C.F.R. § 1904.39).
Iowa’s OSHA-approved state plan adopts these federal size-based exemptions for routine injury and illness recordkeeping. There is no state-specific rule overriding or expanding this size threshold; any changes to the federal standard would apply to Iowa unless Iowa OSHA enacts a more stringent rule through the administrative process.
Source: 29 C.F.R. § 1904.1 & Iowa OSHA Recordkeeping—Enforcement & Compliance