VOSHA coverage — private sector, state, and local government employers
Vermont administers workplace safety and health standards through the Vermont Occupational Safety and Health Administration (VOSHA), a state plan operating under agreement with federal OSHA. VOSHA covers private-sector employers and state and local government workers. Federal employees (including USPS) remain under federal OSHA jurisdiction. The Vermont State Plan excludes offshore maritime employment (including offshore shipyard employment and longshoring), contract workers and contractor-operated facilities engaged in USPS mail operations, and aircraft cabin crewmembers onboard aircraft in operation. Farms with 10 or fewer non-family employees are exempt from VOSHA coverage.
Source: 21 V.S.A. § 201, Vermont State Plan overview (OSHA.gov), VOSHA employee rights (Vermont Dept. of Labor)
VOSHA unique standards diverging from federal OSHA
Vermont, as an OSHA State Plan state, largely adopts federal occupational safety and health standards by reference through VOSHA, so most workplace safety requirements mirror those federal rules. However, as of June 2026, federal OSHA identifies two Vermont-specific standards that diverge from the federal baseline:
- Permissible Exposure Limits (PELs): Vermont maintains state-specific permissible exposure limits for certain airborne contaminants and hazardous substances. These limits can differ from federal OSHA PELs and, in some cases, are stricter. Despite repeated review, Vermont does not appear to publish a consolidated PEL summary table or state rulebook on a .gov domain where an employer could easily check these in effect as of today.
- Lineworker Safety Standard: VOSHA enforces a Vermont-specific safety standard for electrical utility lineworkers, addressing hazards unique to utility line work, such as pole climbing and work on energized lines. Federal OSHA recognizes this as a Vermont-only overlay. However, the full regulatory text is not directly accessible via the Vermont Code of Rules or Department of Labor website as of June 2026.
Primary source accessibility: Federal OSHA’s State Plan documentation confirms that these are the only two current Vermont-specific standards. However, primary-source regulatory details for the Vermont-specific PELs and Lineworker Safety Standard are not published online on a Vermont .gov site as of today. Employers may need to contact the Vermont Department of Labor for further detail, though the rule text is not available for direct public review.
Source: OSHA — Vermont State Plan page
Vermont-specific OSHA standards
Vermont administers workplace safety through the Vermont Occupational Safety and Health Administration (VOSHA), a federally approved state plan. While most VOSHA standards track the federal OSHA code via adoption by reference (29 C.F.R. Parts 1910, 1926, etc.), there are two Vermont-specific standards that differ from federal OSHA requirements:
1. Permissible Exposure Limits (PELs): VOSHA maintains state-specific permissible exposure limits for certain airborne contaminants and hazardous substances. While the precise text is codified in state rule rather than the general federal reference, OSHA recognizes Vermont PELs as a unique overlay differing in some respects (and sometimes being stricter) than the corresponding federal PELs.
2. Lineworker Safety Standard: VOSHA enforces a Vermont-specific safety standard for electrical utility lineworkers addressing hazards unique to utility line work—such as pole climbing, special protective equipment, and procedures for working on or near energized lines. This standard goes beyond the federal OSHA electrical safety rules and is tailored to Vermont’s utility work environment.
As of June 2026, these are the only Vermont-specific OSHA standards recognized by the State Plan documentation; all other occupational safety requirements in Vermont mirror the federal standards by reference.
Vermont incident-reporting requirements — work-related fatalities, hospitalizations, amputations, eye losses
Vermont is a State-Plan jurisdiction under OSHA, so employers must report serious workplace events to VOSHA (Vermont Occupational Safety and Health), not via OSHA’s federal online system—but the timing requirements mirror federal OSHA’s floor.
Reporting deadlines (federal floor, adopted by Vermont)
- A work-related fatality must be reported within 8 hours of the employer or its agent learning of the death, provided the fatality occurs within 30 days of the work-related incident.
- A work-related in-patient hospitalization, amputation, or loss of an eye must be reported within 24 hours of the incident (or of employer learning), provided the event occurs within 24 hours of the work-related incident.
Definitions & timing nuance
- In-patient hospitalization means formal admission for care or treatment—not an ER visit or observation.
- Amputation includes complete or partial loss of a limb or external body part, fingertip amputations, and those later reattached; excludes avulsions, deglovings, broken teeth, or severed ears.
How Vermont employers report
- Employers under VOSHA must not use OSHA’s centralized online system; instead, they must report such incidents directly to VOSHA.
Summary table | Type of Event | Timing for Report | Event Occurs Within | |----------------------------|-------------------|----------------------| | Fatality | 8 hours | 30 days of incident | | Hospitalization, amputation, eye loss | 24 hours | 24 hours of incident |
This ensures Vermont’s reporting deadlines are at least as protective as federal OSHA’s. Missing deadlines can expose an employer to enforcement action under 29 C.F.R. § 1904.39, including citations. Although Vermont may choose its own fine structure, the timing remains mandatory.
Source: 29 C.F.R. § 1904.39 Source: OSHA Serious Event Reporting Form — Vermont
VOSHA recordkeeping requirements — OSHA 300 logs and Vermont-specific exemptions
Which Vermont employers must keep injury and illness records? All Vermont employers subject to the Vermont Occupational Safety and Health Administration (VOSHA) must comply with the federal OSHA recordkeeping rule—codified at 29 C.F.R. Part 1904 and adopted by VOSHA by reference in Vermont Code of Rules 24-050-016, Section 1904.1. Under this regime, most employers with more than 10 employees at any point in the calendar year are required to keep the following injury and illness records:
- OSHA Form 300 (Log of Work-Related Injuries and Illnesses),
- Form 300A (Summary of Work-Related Injuries and Illnesses), and
- Form 301 (Injury and Illness Incident Report).
Exemptions:
- Employers with 10 or fewer employees at all times during the year are partially exempt from standard OSHA recordkeeping (but must still report any serious events per VOSHA’s incident-reporting rule).
- Employers in certain low-hazard industries are also partially exempt; these are set forth in federal OSHA’s Appendix A to Subpart B of 29 C.F.R. 1904 (listed by NAICS code).
State vs. federal carve-outs:
- Vermont does not have any unique or expanded exemptions relative to federal OSHA. The Vermont recordkeeping obligation is coextensive with the federal standard—the partial small-employer and low-hazard industry exemptions apply in Vermont exactly as under federal law.
- The five-year retention, employee access, and annual electronic submission rules from 29 C.F.R. 1904 apply equally in Vermont.
Electronic submission and retention:
- Employers required by federal law to submit Form 300A data electronically must do so—even though record submission is routed to OSHA federally, not VOSHA locally.
Summary:
- If you have more than 10 employees (or are not in an exempt industry), you must maintain OSHA Forms 300, 300A, and 301. Vermont does not supplement or override these federal carve-outs. See also the Vermont adoption-by-reference rule at 24-050-016(VOSHA), Section 1904.1, which incorporates 29 C.F.R. Part 1904.
Source: 29 C.F.R. Part 1904 Source: Vermont Code of Rules 24-050-016, Section 1904.1 (VOSHA)
VOSHA citation contest deadline and Review Board appeals process
Under Vermont law, when the Vermont Occupational Safety and Health Administration (VOSHA) issues a citation to an employer, the employer has 20 calendar days from receipt of the citation to notify the Commissioner in writing if it intends to contest the citation, the proposed penalty, or the abatement period. This deadline is set by 21 V.S.A. § 226(a)(1)-(2), which states:
> "If the employer or employee fails to notify the Commissioner within 20 days from the receipt of the notice that he or she intends to contest the citation or proposed assessment of penalty, and no notice is filed by any employee or representative of employees under subsection (b) of this section within such time, the citation and the assessment, as proposed, shall be deemed a final order of the Review Board and not subject to review by any court or agency."
If the employer files a timely contest, the case is referred to the VOSHA Review Board for a hearing. The Review Board will:
- hold a hearing (with notice to all parties, including affected employees or their representatives),
- issue a written decision, and
- may affirm, modify, or vacate the citation or penalty, or direct other appropriate relief. (21 V.S.A. § 226(a)-(c))
Once the Review Board renders its decision, any party aggrieved by the final order may seek judicial review by appeal to the Vermont Superior Court (specifically, the Washington Superior Court), but must do so within 30 days of the Review Board’s order. The court reviews the record, and if no appeal is taken within the 30 days, the Review Board’s determination becomes conclusive. (21 V.S.A. § 227)
Summary:
- Employers have 20 days to contest a VOSHA citation or penalty in writing, or the citation becomes a final order not subject to review.
- If contested, the case is heard by the VOSHA Review Board.
- Final Review Board orders may be appealed to Vermont Superior Court within 30 days.
This process is unique to Vermont as a state-plan OSHA jurisdiction, with the VOSHA Review Board as the initial appeals tribunal prior to any recourse to the courts.
Source: 21 V.S.A. § 226 Source: 21 V.S.A. § 227