On July 14, 2025, the Occupational Safety and Health Administration (OSHA) released a major update to Chapter 6 of its July 2025 Field Operations Manual (FOM) Revision, which governs how the agency assesses penalties and pursues unpaid fines. These changes aim to improve consistency, reward proactive compliance, and enhance OSHA’s ability to collect outstanding debts through clearer procedures and stronger enforcement tools.
One of the most significant updates is the introduction of a 20% penalty reduction for employers with a clean safety history.
Key Revisions to Chapter 6
1. Expanded Penalty Reductions for Compliant Employers
One of the most significant updates is the introduction of a 20% penalty reduction for employers with a clean safety history. This replaces the former 10% “history” discount and better rewards those who consistently maintain safe and compliant workplaces.
Employers may qualify if they:
- Have never been inspected by OSHA or a State Plan, or
- Have been inspected in the last five years and received no serious, willful, repeat, or failure-to-abate violations.
Effective Date: This new reduction applies to citations issued on or after July 14, 2025.
2. Penalty Reduction for Size
The Size Reduction acknowledges that smaller businesses may have fewer resources and should not be disproportionately burdened by penalties. OSHA bases this reduction on the employer’s total number of employees, not just those at the inspected site.
OSHA may reduce or deny this discount if the employer is part of a larger enterprise, affiliated company, or franchise network that exceeds the size thresholds.
3. Clarified Debt Collection Procedures
The revised FOM also clarifies OSHA’s processes for collecting unpaid penalties. This improves transparency and ensures more consistent enforcement of overdue debts.
Key Elements of the New Procedures
The July 2025 Field Operations Manual's new procedures include:
- Clear Notification: Every citation must now explain that interest, delinquency charges, and administrative costs may be added to unpaid balances.
- Standard Payment Deadlines: 30 days after settlement approval 60 days after a case is docketed 90 days after an OSHRC decision 120 days after a final court judgment
- Interest Accrual: Begins 30 days after the due date and compounds monthly.
- Delinquency Charges: A monthly fee is applied beginning 90 days after the due date.
- Administrative Costs: OSHA may add flat-rate fees for each formal collection letter issued.
- Escalation Options: Unresolved debts may be referred to: The U.S. Department of the Treasury Legal action under Section 17(l) of the OSH Act OSHA’s internal Debt Collection Advisory Team (DCAT)
Summary of OSHA Penalty Reductions
OSHA offers multiple penalty reduction options in the July 2025 Field Operations Manual, each designed to reflect the employer’s size, inspection history, attitude toward compliance, and responsiveness to hazards. Below is a detailed summary of each available reduction:
Good Faith Reduction
The Good Faith Reduction rewards employers who show a genuine commitment to workplace safety. To qualify, employers should:
- Maintain a written and implemented safety and health program that includes hazard recognition, training, and preventive measures.
- Exhibit cooperative behavior during the OSHA inspection, including timely responses to document requests and hazard correction.
- Encourage employee involvement in safety and regularly review and update safety procedures.
However, OSHA will not grant this reduction if:
- The case involves willful, repeat, or failure-to-abate violations.
- There is evidence of intentional disregard for OSHA requirements or obstruction of the inspection process.
- The employer has a history of non-compliance or a poor safety culture.
What Employers Should Do Now
To take full advantage of the July 2025 Field Operations Manual penalty reductions and avoid unnecessary costs, employers should:
- Review their inspection history to confirm eligibility for the 20% history reduction.
- Assess their size category and ensure accurate employee counts are documented.
- Maintain a robust written safety program to qualify for the Good Faith Reduction.
- Correct hazards promptly during inspections to seek the Quick Fix Reduction.
- Pay citations on time to avoid compounding interest and fees.
- Engage legal or compliance experts to navigate OSHA settlements effectively.
Get Rewarded for Safety Leadership
OSHA is making it clear: proactive, well-documented safety efforts don’t just protect your people—they can protect your bottom line. At Cardinal Compliance Consultants, we help employers build the kind of safety programs that earn recognition, reduce penalties, and stand up to OSHA scrutiny.
Whether you need help strengthening your written programs, training your team, or preparing for an inspection, we’ll meet you where you are and help you get ahead of compliance challenges. Contact us for a consultation today. To access the full guidance on OSHA's Field Operations Manual - Chapter 6, click here.