OSHA Directives & the Field Operations Manual

OSHA doesn’t just enforce the standards. It also issues directives, which are internal instructions that tell compliance officers how to carry out inspections and enforce the rules. The biggest is the Field Operations Manual (FOM). Employers and workers can read the same directives that inspectors use, which makes them a useful way to understand what to expect.

• Employers
• Safety Managers
• Workers

What a directive is

• A directive is an official OSHA document that sets agency policy, procedures or enforcement priorities for its staff, including compliance officers, area offices and state plans.
• Directives are not laws or regulations. They aren’t published through the formal rulemaking process, and they don’t create new legal duties for employers. They explain how OSHA will apply the law and the standards.
• Still, they matter. They show how an inspector is likely to act, which hazards OSHA is targeting, and how citations and penalties are decided. A citation must be based on a standard or the General Duty Clause, not on a directive alone.
• Directives are public. OSHA posts them online, searchable by number, subject and date. See How OSHA Makes New Rules for the difference between rules and guidance.

Types of directives

Directive numbers include the series, a year or topic code and a sequence number. For example, CPL 02-00-164 is the Field Operations Manual. Directives are revised or canceled over time, so always check that you have the current version.

The Field Operations Manual

• The FOM (CPL 02-00-164, effective April 14, 2020, with later updates to some chapters) is the main instruction manual for OSHA compliance officers, and a good guide for employers on what happens during an inspection and after it. The current version is on OSHA’s website.
• It is organized in chapters. Examples of what chapters cover:
  • Pre-inspection procedures and how inspections are scheduled.
  • Inspection procedures: opening conference, walkaround, closing conference, records and interviews.
  • Inspection documentation and evidence.
  • Violations: how to classify hazards and violations.
  • Penalties and debt collection (with changes updated for inflation).
  • Post-citation procedures, abatement, informal conferences and settlements.
  • Special topics: construction, multi-employer worksites, whistleblower issues, agriculture and maritime.
• It is a long manual, but reading the chapters on inspections and violations can help employers prepare. See OSHA Inspections.

How inspections are chosen

The FOM lists priorities, in this general order:

1. Imminent danger: situations that could cause death or serious harm right away. See Imminent Danger.
2. Fatalities and catastrophes: deaths, and incidents with multiple hospitalizations. See How OSHA Investigates Fatalities.
3. Worker complaints and referrals from workers, other agencies and the public.
4. Targeted (programmed) inspections such as emphasis programs on specific hazards and high-hazard industries. See OSHA Emphasis Programs.
5. Follow-up inspections to check that violations have been fixed.

How an inspection runs, according to the FOM

• Credentials and opening conference: the compliance officer shows credentials, explains why they’re there and what will be inspected, and asks for employer and employee representatives.
• Walkaround: the officer inspects the workplace, takes photos and measurements, and talks to workers privately. An employee representative may accompany them. See Walkaround Representatives.
• Records review: injury and illness logs, written programs, training records, exposure data. See Recordkeeping & Reporting and Written Programs.
• Closing conference: the officer reviews findings, possible violations and abatement, and explains rights and next steps.
• Citations: OSHA has up to six months after a violation occurs to issue a citation, and the employer then has 15 working days to contest. See Citation Types and Contesting Citations.
• Abatement: the employer must correct the hazard by the date in the citation and certify it.

Classifying violations and penalties

• The FOM explains how officers classify violations as serious, other-than-serious, willful, repeat or failure-to-abate, and how they decide on the gravity of a violation, which affects penalties.
• Penalty amounts are adjusted each year for inflation and are set in OSHA’s penalty directives and the regulations. Reductions can apply for small employers, good faith and history. Check the current amounts.
• Willful and repeat violations and employers who fail to correct hazards face the highest penalties. See Severe Violator Enforcement Program.

Using directives as a worker or employer

• Read the directive for your hazard. If OSHA has an emphasis program or inspection procedure for something you do, such as falls, trenching, heat, amputations or combustible dust, it shows what inspectors check and what good practice looks like.
• Prepare for an inspection: know your rights and responsibilities, keep records organized, assign someone to accompany the inspector, and fix hazards before they are found. See Employer Responsibilities.
• Use directives in a contest: an employer can argue that an inspector didn’t follow OSHA’s own procedures, though this doesn’t automatically void a citation.
• Workers: know that you can file a complaint, talk to an inspector and request an inspection. See Worker Rights and Whistleblower Protection.
• Check the date and status. Directives are revised and canceled, so use the current version. Also check Letters of Interpretation for how OSHA reads a standard.

State plans and directives

Federal OSHA’s directives apply to federal OSHA. State plan states run their own enforcement with their own manuals, but they must be at least as effective as federal OSHA, and they often adopt or adapt federal directives. See State Plans Overview.

Where to find directives

• OSHA’s website has a directives page listing all current directives by series and number, with a search tool, and a list of recently issued or revised directives.
• The construction industry page also lists directives of special interest to builders. Many state plan sites also post their versions.

Directives checklist

• I know directives are agency instructions, not laws or standards
• I looked up the Field Operations Manual and the directives for my main hazards
• I know how inspections are chosen, run and followed up
• Our records, written programs and abatement process are ready
• I check that I’m reading the current version of a directive
• I know that state plan states may have their own versions

Last updated: October 4, 2026