The new instruction manual cancels and replaces OSHA Instruction CPL 02-00-103, Field Inspection Reference Manual (FIRM), issued September 26, 1994, and two of the three remaining parts of the prior Field Operations Manual, CPL 02-00-045, which are still in effect. The one remaining part of the prior Field Operations Manual, the chapter on Disclosure, will be added at a later date.

Significant Changes for November 2009 Edition

* Clarifies “critical inspections” for consultation visits in progress. * Clarifies a compliance officer's responsibility to present credentials. * Clarifies the amount of hours employers have to provide recordkeeping records, and when walkaround inspections can begin. * Clarifies final order dates for repeated violations. * Clarifies the amount that a proposed penalty for a posting violation must be if it amounts to less than $100. * Clarifies penalty reduction factor when proposing penalties for any §1903.19 violations. * Clarifies the definitions of formal and non-formal complaints, and referrals. * Clarifies that a formal complaint alleging a recordkeeping deficiency indicating the existence of a serious safety or health violation is a criterion warranting an inspection.

To read the CPL 02-00-148 OSHA's Field Operations Manual (FOM), visit jjkeller.com at www.jjkeller.com/referencematerials/oshacomp.html

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