Federal OSHA Penalties Fell 47% in 2025. Here Is What Still Getting Workers Killed.
According to ISHN, National COSH released its 2026 “Dirty Dozen” list of companies with the most egregious OSHA violations just as federal workplace safety enforcement is in sharp decline, with penalties dropping 47% in 2025. The combination of weakened enforcement and persistent, often fatal violations at named companies sends a clear signal to field operations professionals: the regulatory safety net is thinning, and the burden of maintaining safe jobsites is shifting further onto employers and subcontractors themselves.
Background
Each spring, the National Council for Occupational Safety and Health publishes its Dirty Dozen report, identifying companies it considers to have the worst safety records and most hazardous working conditions in the country. The 2026 list, reported by ISHN, was released alongside data showing that federal OSHA penalties dropped 47% in 2025, a steep decline that raises serious questions about the state of workplace safety enforcement nationwide.
The 2026 Dirty Dozen, listed alphabetically, includes Alliance Ground International, Cambria Company LLC, CommonSpirit Health, Consolidated Catfish Producers LLC, D.R. Horton Inc., the Hyundai-Kia U.S. supply chain, Jeny Sod and Nursery, LSG Sky Chefs, Maker’s Pride LLC (formerly Hearthside LLC), Revoli Construction Co. Inc., and Subway IP LLC, among others. The violations span a wide range of hazards: amputations, silica disease, child labor, heat exposure, trenching collapses, and wage theft.
At a media press conference, Jessica E. Martinez, executive director of National COSH, framed the problem in direct terms. “When large corporations say the system is working, we have to really ask, working for whom,” Martinez said, according to ISHN. She pointed specifically to subcontracting structures as part of the problem, arguing that “subcontracting chains are designed so nobody takes responsibility when workers are harmed.”
Analysis
The 47% drop in federal OSHA penalties is not an abstraction. It changes the calculus on the ground for every company operating in field services, construction, and energy. When enforcement drops, the deterrent effect weakens. Companies that were previously motivated to invest in safety programs partly to avoid costly penalties now face a lower financial risk for cutting corners.
But the Dirty Dozen list illustrates something that enforcement statistics alone don’t capture: the violations haven’t gone away. They’ve just become less likely to result in a penalty. Revoli Construction Co. appears on the list for what ISHN describes as decades of trenching violations ending in a fatal collapse. Trenching and excavation hazards are among the most persistent and preventable causes of construction fatalities, and the fact that a company can accumulate that record over decades says something about the limits of enforcement as a primary safety mechanism.
The silica disease issue at Cambria Company LLC is another example that resonates directly with oilfield and construction subcontractors. Silica exposure from engineered stone, as well as from drilling, cutting, and grinding operations, is one of the more insidious hazards in field work because the damage accumulates slowly and symptoms appear years later. It doesn’t generate the immediate, visible incident that trenching collapses do, but the body count is real.
The inclusion of D.R. Horton, one of the largest homebuilders in the country, for repeated safety violations and hazardous construction jobsite conditions is also notable. Large general contractors set the tone on jobsite safety culture. When the GC at the top of a project hierarchy is cutting corners, that pressure filters down through every subcontractor and crew on site.
Martinez’s comment about subcontracting chains deserves attention from anyone running a field service company. The structure she describes, where accountability is diffused across layers of contracts until “nobody takes responsibility,” is a well-documented feature of how large projects are organized in oil and gas, construction, and infrastructure. It often benefits the prime contractor or asset owner. It rarely benefits the subcontractor when something goes wrong.
What It Means for Subcontractors
- Document everything. With federal enforcement weakened, subcontractors are more exposed to being the party that absorbs liability when an incident occurs on a multi-tier project. Thorough safety records and sign-off procedures are your best protection.
- Don’t rely on GC programs alone. Several companies on the Dirty Dozen list are large, well-resourced organizations. Size and brand name do not equal a strong safety culture. Run your own pre-task planning and hazard assessments regardless of what the prime contractor’s program looks like.
- Silica and heat are enforcement targets even in a low-penalty environment. Both appear repeatedly on the 2026 list. OSHA’s silica standard and ongoing heat-related rulemaking remain active areas of scrutiny. Subcontractors in drilling, cutting, or outdoor operations should treat these as live compliance risks.
- Watch trenching closely. Revoli Construction’s appearance on the list for decades of trenching violations that ended fatally is a reminder that this hazard is unforgiving. Competent person requirements, daily inspections, and proper shoring or sloping are non-negotiable.
- Understand your exposure in temp and subcontract structures. Martinez’s warning about accountability gaps in subcontracting chains applies directly to how many field service arrangements are structured. Know your contract language and what safety obligations you are accepting.
- A drop in penalties is not a drop in risk. The 47% decline in federal OSHA penalties changes what might happen after an incident, but it doesn’t change what causes one. Workers are still getting hurt in the same ways, at the same types of sites. Compliance posture should be driven by actual hazard exposure, not by the current enforcement climate.
