California Audit Uncovers Critical Weaknesses in Cal/OSHA’s Workplace Enforcement (Report 2024‑115)
Published July 17, 2025, by the California State Auditor
Executive Summary
The California State Auditor’s latest audit of Cal/OSHA, covering fiscal years 2019‑20 through 2023‑24, reveals process deficiencies and staffing shortages that substantially limit its ability to protect California’s nearly 20 million workers. Reviewing 60 case files, auditors identified inconsistent inspection decisions, weak documentation, improper fine reductions, and a 32% vacancy rate, all of which raise red flags about Cal/OSHA’s enforcement capacity.
Key Findings
1. Inspections Skipped Without Clear Justification
In 30 complaint cases, inspectors opted for letter investigations instead of on-site visits; in 9 cases, the rationale was not supported in the case files.
Even in accident investigations, inspectors frequently opted not to inspect when injuries appeared serious yet failed to document why.
2. Weak Documentation in On-Site Inspections
Inspectors often failed to properly review employers’ Injury and Illness Prevention Programs (IIPP), potentially overlooking serious compliance issues.
Cases cited with violations did not consistently include documentation proving that hazards were addressed.
3. Fine Reductions Lacking Transparency
Fines were frequently reduced during negotiations with employers, sometimes without documented justification.
Average collected penalties fell from over $20 million in FY 2019–20 to under $8 million in FY 2023–24.
4. Staffing Strains Undermine Oversight
Overall vacancy rate hit 32% in FY 2023–24, and some district offices faced even higher rates.
Managers reported that adequate staffing would have allowed more thorough inspections.
Context: Complaint and Accident Trends
Cal/OSHA received 66,345 complaints and 38,461 accidents/referrals over the audit period.
Severity ranged from imminent hazards (658 cases) to serious (8,109), but many were downgraded or unresolved due to process gaps.
Recommendations by the Auditor
Cal/OSHA is given a July 2026 deadline to implement key improvements:
• Streamline Inspection Decisions
Require detailed written justifications when opting against on-site inspections, citing severity, employer history, and resource constraints.
Policies should discourage dismissing complaints simply because the complainant requested anonymity.
• Upgrade Letter Investigations
Mandate submission of employer-provided supporting documents proving hazard remediation before case closure.
Implement systems to verify delivery and receipt of investigation letters, especially when email is unavailable.
What This Means for Legal Practitioners & Employers
As attorneys advising employers or workers, picture this: enforcement decisions often hinge on incomplete documentation, arbitrary fine reductions, and an overburdened workforce. That leaves both parties vulnerable:
Employers may face unexpected or legally questionable citations.
Workers may continue to be exposed to hazards due to weak follow‑through.
Attorneys should anticipate gaps in records and question procedural compliance when evaluating Cal/OSHA cases.
How Noble Attorneys Can Leverage These Findings
Audit Prep & Defense Strategy
Use gaps in Cal/OSHA’s documentation like missing IIPP reviews or unjustified fine reductions, to challenge citations or negotiate reductions effectively.Compliance Advising
Help employers strengthen their internal IIPP programs to preempt weaknesses in Cal/OSHA enforcement and minimize risk.Policy Advocacy & Legislative Engagement
Advocate for better funding, staffing consistency, and modernization, drawing on the audit’s data to support reform proposals or employer stakeholder initiatives.
The 2024‑115 audit paints a stark picture: Cal/OSHA is overwhelmed, understaffed, and inconsistently applying its own rules. All of this jeopardizes California workers' safety and opens room for legal friction.
