HR Compliance Checklist

Cross-check each active employee against the I-9 binder or E-Verify case log. Common gaps on a manufacturing roster: missing Section 2 signatures on rehires, expired List A documents (e.g., EAD or passport) without re-verification, and Section 1 dates that don't match the first day of work for pay. Flag any deficiencies for remediation in the next step.

Use the USCIS I-9 correction guidance: line through, initial, and date — never white-out or backdate. Re-verify any List A or List C documents within 90 days of expiration. Document the corrective action in the employee file.

Pull signed offer letters, at-will acknowledgments, arbitration agreements (where applicable), and the latest handbook receipt. Production hires often sign on the floor; signatures get missed. Reissue and collect anything outstanding before quarter close.

Job descriptions for production, maintenance, and material-handling roles must reflect actual physical demands, lifting limits, hearing-protection zones, and respirator use. ADA accommodation requests are evaluated against the written description — vague descriptions create exposure.

29 CFR 1910.147 requires retraining for authorized and affected employees when procedures change, when an inspection reveals deviations, or annually as part of the periodic inspection. Pull CMMS or LMS records showing training date, trainer, and signature. Missing LOTO training is a top-10 OSHA citation.

1910.178 requires equipment-specific training: counterbalance, reach truck, order picker, and pallet jack are separate certifications. Recertify every 3 years or after an incident, near-miss, or evaluation deficiency. Pull the operator matrix and confirm no one is operating equipment they aren't certified on.

Verify each employee has been trained on chemicals introduced since the last review and knows where the SDS binder or digital portal lives. Chemical change-control should trigger targeted training — confirm the change log matches training records.

1910.95 requires audiograms, training, and hearing protection for employees exposed at or above the 85 dBA action level on an 8-hour TWA. Cross-check the most recent dosimetry survey against the enrolled roster — new cells or shift changes can pull employees above the threshold without anyone updating the program.

Enter each recordable case within 7 days of awareness. Confirm 301 incident reports are filed for each entry. Watch for late reclassification — a strain that initially looked first-aid-only becomes recordable when the employee returns to a doctor on day 8.

Use 5-why or fishbone with the supervisor and EHS coordinator. The goal is corrective action that prevents recurrence — guard added, JSA updated, training delivered. Effectiveness check at 30 and 90 days; close the corrective action only after defect-free interval is verified.

Post the prior calendar year summary in a conspicuous location — break room, time-clock area — by February 1, and leave it up through April 30. Establishments with 10 or fewer employees and certain low-hazard NAICS codes are partially exempt; confirm your status before assuming you're off the hook.

Establishments with 250+ employees, or 20–249 employees in a covered NAICS (most manufacturing falls in here), must submit 300A data via the Injury Tracking Application by March 2. Larger establishments now also submit 300 and 301 data. Verify your establishment's NAICS and headcount.

Production supervisors, working leads, and quality engineers are common misclassification traps. Apply the duties test alongside the salary threshold — a working lead who spends 70% of time running a machine is non-exempt regardless of title or salary.

Reclassify the role, recompute back overtime exposure (typically 2 years, 3 if willful), and consult counsel on remediation strategy. Communicate the change to affected employees in writing with effective date and any back-pay calculation.

State and city minimum wages adjust on January 1 (most states) or July 1 (CA, OR, DC, others). Multi-plant manufacturers get caught when one location's posted rate lags. Confirm the rate in payroll matches the current state and locality figure for each facility.

Regular rate of pay must include non-discretionary bonuses (attendance, production, safety) and shift differentials before computing the 1.5× OT premium. A common error: paying OT on base rate only and treating the production bonus as a flat add-on. Spot-check 5 random non-exempt timecards.

Second and third shifts get missed when training is scheduled during day hours. Several states (CA, NY, IL, CT, ME, DE, WA) mandate sexual harassment training on a fixed cadence with state-specific content. Confirm shift coverage and state-specific elements.

Pull complaints from the hotline, HR intake, and supervisor escalations. Confirm each is logged with date received, reporter, allegation summary, and current status. EEOC charges and state agency complaints are tracked separately with their own response deadlines.

Each complaint gets a written investigation file: interviews with reporter, accused, and witnesses; documents reviewed; findings; corrective action; and follow-up check at 30 and 90 days. Retaliation prevention reminders to the reporter's chain of command are standard practice.

Private employers with 100+ employees, and federal contractors with 50+ employees and a contract of $50,000 or more, file EEO-1 Component 1 annually. Use a workforce snapshot from a payroll period in October–December of the reporting year. Filing window is announced annually by the EEOC.