You are right. Most smaller employers only come into contact with OSHA when there is a reason to investigate - either because of an injury or a complaint - just as you stated. I have personally witnessed several instances where fired employees put in a call to OSHA to complain about the boss that just fired them. I really can't blame employers. There is only one thing they fear more than OSHA crawling up their a** with a microscope, and it's the IRS.