29 CFR 1910.134 requires a written respiratory protection program with medical evaluations, fit testing, and training whenever respirators are required. Each of those creates a record OSHA will ask to see.
A written program administered by a suitably trained program administrator, medical evaluation before fit testing or use, annual fit testing for tight-fitting respirators, training on proper use and limitations, and procedures for maintenance and cartridge change schedules.
No written program, fit testing never performed or expired, medical evaluations missing, employees wearing respirators voluntarily without receiving Appendix D information, and facial hair interfering with the seal.
You have 15 working days from receipt to file a Notice of Contest. Miss it and the citation becomes a final order that cannot be appealed.
Most response packages need training and briefing records showing that the exposed workers were instructed on this specific hazard before the inspection. This is where employers stall. A paper sign-in sheet establishes that somebody signed a page; it does not establish who was present, where, or when. If your records are sign-in sheets, gather them now and identify the gaps before OSHA does.
If a trained employee violated a known rule, OSHA recognizes an unpreventable employee misconduct defense. It requires four elements: an established work rule designed to prevent the violation, adequate communication of that rule to employees, steps to discover violations, and effective enforcement when violations are found. Employers routinely satisfy elements one, three, and four and fail on element two, because they cannot prove the exposed worker received the briefing.
Not a full program, but if employees voluntarily use filtering facepiece respirators you must provide the information in Appendix D. Voluntary use of other respirator types requires medical evaluation and cleaning provisions.
15 working days from the date you receive the citation. Within that window you can file a Notice of Contest, request an informal conference with the OSHA Area Director, or accept the citation and certify abatement. After 15 working days an uncontested citation becomes a final order of the Occupational Safety and Health Review Commission and is no longer appealable.
Accepting is usually appropriate when the violation clearly occurred and the penalty is proportionate. An informal conference is often the better middle path: it costs nothing, it is scheduled quickly, and Area Directors have authority to reclassify violations, adjust penalties, and extend abatement dates. Contesting makes sense when you dispute the facts, the classification, or you can establish an affirmative defense. Consult an attorney for willful or repeat citations, or where an injury occurred.
See the plain-English summary above. The citation itself lists the specific subsection cited, which narrows what OSHA is alleging you failed to do. Read that subsection before drafting anything, because your response should address that subsection and not the standard in general.
For each violation you accept, you must certify in writing that the hazard was corrected, including the date and a description of the correction. Serious, willful, and repeat violations generally require supporting documentation such as photographs, receipts, or training records. OSHA may also require abatement to be posted where affected employees can see it.
For 2025 the federal maximum is $16,550 per serious violation and $165,514 per willful or repeat violation. Penalties are proposed per violation, so multiple instances multiply quickly. OSHA considers employer size, good faith, and citation history when setting the final amount, and state-plan states may apply different schedules.
Arkvos offers a free OSHA citation response generator. Upload the citation and get a formal response letter, a corrective action plan with dates, and a checklist of evidence to attach. Employers have 15 working days from receipt of a citation to contest it. Open the free citation responder.