OSHA training requirements by standard: complete list for employers

Last updated 2026-07-11

How does OSHA actually require training, and where do the rules live?

There is no master OSHA training regulation. The requirements live inside each hazard-specific standard, and the language shifts a lot from rule to rule. Some standards say employers "shall train" employees on specific topics before they start work. Others demand annual refresher training or retraining the moment a new hazard shows up. The Hazard Communication Standard goes further and requires training on the "specific chemical hazards" present in the employee's work area, more than chemicals in the abstract.

All of it lives in Title 29 of the Code of Federal Regulations. General industry employers work under 29 CFR Part 1910. Construction employers work under 29 CFR Part 1926. Shipyard and maritime employers fall under 29 CFR Parts 1915 through 1919. A handful of standards, including HazCom and Bloodborne Pathogens, apply in both Part 1910 and Part 1926.

OSHA also has the General Duty Clause, Section 5(a)(1) of the OSH Act, which requires employers to keep the workplace free from recognized hazards. Inspectors reach for that clause when no specific training standard applies but a training gap clearly fed an injury. So the CFR list below is the floor, not the ceiling.

For a plain-English overview of what OSHA is and what it covers, see our guide to osha.

What are the most frequently cited OSHA training standards?

OSHA publishes its top 10 cited standards every fiscal year, and training deficiencies turn up inside almost every one of them. In FY 2024, Hazard Communication (29 CFR 1910.1200) drew 2,888 citations, the second most cited standard overall. Fall Protection Training (29 CFR 1926.503) was the single most cited standard in construction, and it is a pure training standard: its entire job is to make employers train workers to spot fall hazards before they go up ^[1].

Lockout/Tagout (29 CFR 1910.147) sits in the top five year after year. Respiratory Protection (29 CFR 1910.134) shows up annually. Personal Protective Equipment (29 CFR 1910.132) and Powered Industrial Trucks (29 CFR 1910.178) fill out the group where training citations pile up.

Here is the pattern that should shape your priorities. OSHA inspectors are not hunting obscure rules. They hit the same short list over and over. Fix those first and you cut your citation risk hard.

For a closer look at osha training generally, that article breaks down the evidence an inspector uses to decide whether training actually happened.

Complete list of OSHA training requirements by CFR standard

The table below covers the major standards with explicit training requirements. "Frequency" reflects what the standard text requires. Where a standard says nothing about refresher cycles, the entry reads "as needed," which means any time conditions change or an employee shows they did not understand the training.

Standard	Topic	Who it covers	Initial training	Refresher	Records required
29 CFR 1910.132	PPE general	All general industry workers using PPE	Before use	When PPE or hazards change	Certification of training (name, date, subjects)
29 CFR 1910.134	Respiratory protection	Any worker required to wear a respirator	Before use	Annually	Fit test records; training records
29 CFR 1910.138	Hand protection	Workers exposed to hand hazards	Before use	As needed	No specific form required
29 CFR 1910.147	Lockout/tagout	Authorized and affected employees	Before performing servicing	When procedures change or deficiencies observed	Certification (name, date, standard)
29 CFR 1910.178(l)	Powered industrial trucks (forklifts)	All forklift operators	Before operating	Every 3 years (or sooner if incident occurs)	Evaluation records
29 CFR 1910.1200	Hazard communication (GHS)	All workers exposed to hazardous chemicals	At hire and before new chemical exposure	When new hazards introduced	No specific form; documentation recommended
29 CFR 1910.1030	Bloodborne pathogens	Workers with occupational exposure	At hire, then annually	Annually	Training records 3 years
29 CFR 1910.1020	Access to employee exposure/medical records	All workers (notification)	Within 1 year of hire or standard effective date	As needed	No specific form
29 CFR 1910.119	Process safety management (PSM)	Employees involved in highly hazardous chemical processes	Before starting work in process	Every 3 years (refresher)	Certification records 3 years
29 CFR 1910.120	HAZWOPER	Emergency responders, hazardous waste workers	40-hour (offsite) or 24-hour (occasional site) or 8-hour (supervisors)	8-hour annual refresher	Completion records
29 CFR 1910.146	Permit-required confined spaces	Authorized entrants, attendants, entry supervisors	Before first entry assignment	As needed; when new hazards arise	No specific form; documented procedures required
29 CFR 1910.151	First aid/emergency response	Designated first aid providers (when no infirmary nearby)	Before assignment	Per certification body (usually 2 years)	No OSHA-specific form
29 CFR 1910.157	Portable fire extinguishers	Workers expected to use extinguishers	Annually (familiarization); hands-on upon initial assignment	Annually	No specific form
29 CFR 1910.269	Electric power generation/transmission	Qualified and unqualified electrical workers	Before beginning work	As needed	Documented qualification records
29 CFR 1910.303 / 1910.332	Electrical safety (general + safety-related work practices)	Qualified electrical workers	Before performing work	As needed	No specific form
29 CFR 1910.1025	Lead (general industry)	Workers with lead exposure above action level	Before initial job assignment; within 60 days of exceeding action level	Annually	No specific form
29 CFR 1910.1001	Asbestos (general industry)	Workers with any asbestos exposure	Before initial exposure	Annually	No specific form; records retained 1 year past employment
29 CFR 1926.21	Construction safety training (general)	All construction workers	Before starting work	As needed	No specific form
29 CFR 1926.503	Fall protection (construction)	Any worker exposed to fall hazards	Before exposure	When fall protection changes or deficiencies observed	Training certification (name, date, trainer)
29 CFR 1926.454	Scaffolding (construction)	Workers who erect, dismantle, move, or work on scaffolds	Before work begins	As needed	No specific form
29 CFR 1926.62	Lead (construction)	Workers with lead exposure above action level	Before initial job assignment	Annually	No specific form
29 CFR 1926.1101	Asbestos (construction)	Workers with potential asbestos exposure	Before starting work	Annually	Training records retained
29 CFR 1926.1127	Cadmium (construction)	Workers with cadmium exposure	Before initial exposure	Annually	No specific form
29 CFR 1926.1153	Silica (construction)	Workers with silica exposure at or above action level	Before starting work on relevant tasks	As needed	No specific form
29 CFR 1910.1053	Silica (general industry)	Workers with silica exposure at or above action level	Before starting work	As needed	No specific form
29 CFR 1910.95	Occupational noise	Workers exposed at or above 85 dBA TWA	Within 6 months of inclusion in HCP	Annually	Training completion records
29 CFR 1910.1450	Lab chemical hygiene	Laboratory workers using hazardous chemicals	At start of assignment; when new hazards are introduced	As needed	No specific form
29 CFR 1915.89	LOTO (shipyard)	Authorized and affected workers	Before performing servicing	When procedures change	Certification records
29 CFR 1926.59	HazCom (construction)	All construction workers using hazardous chemicals	Before exposure	When new hazards introduced	No specific form; records recommended

This table covers the standards small and mid-sized employers hit most. OSHA has more training rules buried inside standards for cranes, diving, telecommunications, and agriculture. If your work involves any of those, read those parts of the CFR directly ^[2].

The three-year forklift evaluation cycle and the post-incident retraining rule catch a lot of employers off guard. Our forklift certification article walks through what that evaluation must include and who can run it.

What records do you have to keep, and for how long?

Training records are where small employers get hurt on inspection. OSHA has no single universal training form, but each standard spells out what the record must contain and how long you hold it. The common ones:

Bloodborne Pathogens (29 CFR 1910.1030): the record must include the date, the content or a summary, the trainer's name and qualifications, and the names and job titles of everyone who attended. Keep it 3 years ^[3].

PSM (29 CFR 1910.119): document that training was completed and that the employee understood it. Records are kept 3 years.

Forklifts (29 CFR 1910.178): certify that each operator was trained and evaluated, with the date and the name of the person who ran the evaluation. No expiration on the format, but the record has to exist.

Fall protection (29 CFR 1926.503): a written certification that each worker was trained, naming the trainer, the date, and the standard being met.

Most other standards do not name a form, but inspectors still expect to see something. A sign-in sheet with the date, topic covered, trainer's name, and each employee's signature clears most audits. Keep it in a binder or a shared folder and you have a defensible record.

One honest note. Several standards do not require training records at all (PPE, confined spaces, fire extinguishers), and inspectors will still ask for them. If you cannot show that training happened, the inspector assumes it did not. A verbal "we trained them" carries almost no weight.

For the broader question of what OSHA paperwork you keep, our incident report article covers the 300 Log recordkeeping side alongside training documentation.

Does OSHA require training to be in English?

No, but the practical rule is that training must be in a language and vocabulary the employee actually understands. OSHA's position, stated in several letters of interpretation, is blunt: training conducted in a language the worker does not understand does not satisfy the standard, even if it technically happened ^[4]. Run an English-only HazCom session for Spanish-speaking workers and it does not count.

For workforces with more than one language, the simplest fix is a bilingual trainer or translated materials next to the English version. Several standards spell this out directly, requiring training "in a manner that employees can understand," including Bloodborne Pathogens and HAZWOPER (29 CFR 1910.120(e)(1)).

Literacy matters too. If employees read at a limited level, written materials alone do not meet the requirement. The training has to include verbal explanation and a real chance to ask questions.

Can online or computer-based training satisfy OSHA requirements?

For many standards, yes. OSHA has said in letters of interpretation that computer-based training can meet a requirement when it covers all required topics and employees can ask questions and get answers ^[5]. The limit: some standards demand a hands-on demonstration, and online-only training cannot deliver that.

Forklifts are the classic example. 29 CFR 1910.178(l)(2)(ii) requires training on workplace-related topics specific to the truck types and conditions at your facility, plus a practical evaluation. Online modules can carry part of the load, but the evaluation has to happen in person on real equipment.

Respiratory protection works the same way. Fit testing under 29 CFR 1910.134(f) cannot be done online. The training portion can; the fit test cannot.

The osha 30 course and the 10-hour course are not substitutes for standard-specific training. They are general awareness programs. Finishing an OSHA 30 does not mean you have met your HazCom, LOTO, or Bloodborne Pathogens training requirements.

How often does OSHA require retraining?

Every standard sets its own refresher cycle, and the gaps between them matter in practice. Some are hard annual dates. Others fire only when something changes.

Standard	Refresher frequency
Bloodborne Pathogens (1910.1030)	Annually
Respirators (1910.134)	Annually
Forklifts (1910.178)	Every 3 years (minimum)
PSM (1910.119)	Every 3 years
HAZWOPER (1910.120)	Annually (8-hour refresher)
Noise / Hearing Conservation (1910.95)	Annually
Lead (1910.1025 / 1926.62)	Annually
Asbestos (1910.1001 / 1926.1101)	Annually
Fall Protection (1926.503)	When deficiencies observed; no set calendar cycle
HazCom (1910.1200)	When new hazards are introduced; no set calendar cycle
LOTO (1910.147)	When procedures change or employee behavior suggests inadequate training
Confined Spaces (1910.146)	When entry supervisor believes retraining is needed

The "as needed" and "when conditions change" standards are where small employers get tripped up. OSHA reads those phrases broadly. Swap a chemical in your process and you have triggered HazCom retraining. Catch an employee bypassing a LOTO step and you owe retraining under 1910.147, even if the three-year clock has not run out.

The annual ones are easy to track with a calendar. The event-driven ones need a trigger process that flags retraining when something changes, more than a fixed reminder date.

What OSHA training do new hires need before they start work?

It depends on the job's hazards, but several standards use "before first exposure" or "before starting work" language that means day-one training or sooner. You cannot wait.

Hazard Communication (29 CFR 1910.1200) requires training "at the time of their initial assignment and whenever a new physical or health hazard is introduced." A new hire cannot touch chemicals until it is done ^[6].

Bloodborne Pathogens (29 CFR 1910.1030) requires training "at the time of initial assignment to tasks where occupational exposure may take place."

Lockout/Tagout (29 CFR 1910.147) requires training before an authorized employee performs servicing or maintenance.

Fall Protection (29 CFR 1926.503) requires training before a worker is exposed to a fall hazard.

So your new hire orientation has to cover, at minimum, HazCom (any workplace with chemicals), the relevant PPE, and the task-specific hazards the employee meets in the first days on the floor. Waiting until the end of a 30-day probationary period breaks these standards.

One trap for new forklift operators: 29 CFR 1910.178 requires the employer to evaluate each operator before they run a truck without supervision. A new hire certified at a previous employer still needs an evaluation on your equipment and in your facility.

Does OSHA require a qualified or certified trainer for these programs?

Most OSHA standards do not require the trainer to hold any specific credential. The usual language is that training comes from a "competent person" or from the employer or a designated employee. What it means in practice: the person running the training has to know the material well enough to answer employee questions accurately.

A few standards go further. HAZWOPER (29 CFR 1910.120(e)(5)) requires training from a person "trained in the topics" being taught. Respiratory protection training (29 CFR 1910.134) names no credential, but the standard expects the trainer to understand the content well enough to handle individual questions about a specific respirator and specific work conditions.

The OSHA 30-hour and 10-hour courses are Outreach Program courses delivered by OSHA-authorized trainers, and they sit apart from standard-specific training. Some states and some federal contract provisions require OSHA 10 or osha 30 training for construction workers, but OSHA itself does not require them across the board.

For most small businesses, an owner, supervisor, or designated safety lead who has studied the relevant standard can legally conduct the training. The harder question is whether the training covers everything the standard requires.

What happens if OSHA cites you for a training violation?

Training violations usually land as "serious" citations, meaning OSHA decided there was a substantial probability that death or serious physical harm could result. Serious citations carry penalties up to $16,550 per violation as of 2024, adjusted annually for inflation ^[7].

Willful violations, where OSHA believes you knew the training requirement existed and chose not to comply, reach up to $165,514 per violation. That is the top of the range. Actual penalties turn on the employer's size, prior history, and good faith.

Small employers catch a real break. Businesses with 25 or fewer employees receive a 60% reduction in proposed penalties under OSHA's Field Operations Manual size-based adjustment ^[13]. That is baked into the process, not something you have to fight for.

Documentation is the strongest defense against a training citation. Produce records covering all required topics, with employees named, the date, and the trainer, and you have grounds to contest or reduce the citation. Without records, contesting is very hard even when the training really happened.

How do state-plan states change these requirements?

Twenty-nine states and two territories run their own OSHA-approved safety and health programs ^[8]. Every state plan must be "at least as effective" as federal OSHA, which means it can be stricter but never weaker. A few states differ in ways worth knowing:

California (Cal/OSHA) has its own Injury and Illness Prevention Program standard (8 CCR 3203) that requires documented, scheduled safety training for all employees, beyond what federal OSHA mandates. Cal/OSHA also requires written IIPP documentation that federal OSHA does not.

Washington (L&I) adds requirements for confined space training and runs its own version of the HazCom standard.

Michigan, Minnesota, and Oregon all operate state plans with extra specificity on documentation.

If you operate in a state-plan state, treat the federal CFR list above as a baseline and check your state's standards separately. OSHA's state plan directory (osha.gov/stateplans) lists every state-plan state with links to the state agency.

How do you build a training program that actually covers all these requirements?

Most small employers do not need a giant training infrastructure. They need a system that does five things:

1. Identifies which standards apply to their operations (a warehouse with forklifts and chemicals carries different requirements than a retail store). 2. Schedules initial training for every new hire before exposure. 3. Sets calendar reminders for annual refreshers (bloodborne pathogens, noise, HAZWOPER, and the rest). 4. Runs a trigger process for event-based retraining (new chemical, changed procedure, incident, near-miss). 5. Keeps documentation that survives an inspection.

Start with a hazard inventory. Walk the facility and list every chemical, piece of equipment, and operation that appears in the CFR table above. That list is your training requirement list. Then attach a standard, a frequency, and a responsible person to each item.

Employers who want a written safety program fast can use SafetyFolio's program generator, which builds the major program documents and training matrices in about 15 minutes. The standards still require you to deliver the actual training, but the written program gives inspectors and employees a clear baseline.

For hazard communication specifically, that article covers what a written HazCom program must include, which is a separate but related requirement from the training itself.

What OSHA training standards apply specifically to construction employers?

Construction employers work mainly under 29 CFR Part 1926, and its training requirements differ from Part 1910 in ways that catch subcontractors off guard.

29 CFR 1926.21(b)(2) states: "The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and in the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury." That is a general training requirement covering every construction worker, and it is broad enough that OSHA can cite it for almost any training gap ^[9].

29 CFR 1926.503, fall protection training, is the most frequently cited construction standard, period. OSHA issued 6,307 citations for it in FY 2024 ^[1]. It requires training before any worker is exposed to a fall hazard, covering how to recognize fall hazards and how to minimize them with the fall protection systems in use at the site.

Scaffolding (29 CFR 1926.454), excavations (29 CFR 1926.650 through 652, which require a competent person on site), cranes and derricks (29 CFR 1926.1430), and steel erection (29 CFR 1926.761) each carry explicit training requirements with their own competency and documentation rules.

For construction employers, the lockout tagout requirements are the ones people underrate. Construction sites run real servicing and maintenance work that triggers LOTO, and plenty of smaller subcontractors have never built a LOTO program at all.

Frequently asked questions

Is there a single OSHA training standard that covers all requirements?

No. OSHA has no master training rule. Training requirements are embedded in more than 100 individual standards across 29 CFR Parts 1910, 1926, and 1915. Each standard sets its own topics, frequency, and documentation rules. The closest thing to a catch-all is the General Duty Clause (Section 5(a)(1) of the OSH Act), which OSHA uses to cite training gaps when no specific standard applies.

How long do OSHA training records need to be kept?

It depends on the standard. Bloodborne pathogens training records must be kept 3 years (29 CFR 1910.1030). PSM training certifications must be kept 3 years (29 CFR 1910.119). Access to employee exposure records (29 CFR 1910.1020) requires medical and exposure records for 30 years. For standards with no stated retention period, keeping records for the length of employment plus three years is a defensible practice that most attorneys recommend.

Does OSHA training have to be in-person?

Not for most standards. OSHA has accepted computer-based and online training in letters of interpretation, as long as all required topics are covered and employees can ask questions and get answers. The exception is training with a hands-on component, like forklift operator evaluation or respirator fit testing. Those portions must happen in person, with real equipment or on the worker's face.

What is the OSHA training requirement for forklift operators?

29 CFR 1910.178(l) requires training before an operator uses a forklift without supervision, covering truck-related topics (controls, stability, capacity) and workplace-related topics (floor surfaces, hazards, pedestrian traffic specific to your facility). A formal evaluation must follow training. Recertification must happen at least every 3 years, and sooner if an operator is in an incident, observed operating unsafely, or assigned a different type of truck.

What training does OSHA require for hazardous chemicals in the workplace?

The Hazard Communication Standard (29 CFR 1910.1200) requires training at initial assignment and whenever a new chemical hazard is introduced. Training must cover how to read SDS sheets, how to interpret GHS labels, and the specific hazards of the chemicals in that employee's work area. A general overview of chemical safety is not enough; the standard requires training on the chemicals actually present.

Does OSHA require annual safety training for all employees?

Only for specific standards. Annual training is explicitly required by Bloodborne Pathogens (1910.1030), Respiratory Protection (1910.134), Hearing Conservation (1910.95), HAZWOPER (1910.120), Lead (1910.1025), and Asbestos (1910.1001 and 1926.1101). Many other standards require training when conditions change rather than on a calendar. No OSHA rule requires generic annual safety training for all workers across all industries.

Who can conduct OSHA-required training?

Most standards require training by a competent person or by the employer or a designated employee, without a formal credential. HAZWOPER requires the trainer to be trained in the topics being taught. A supervisor, safety manager, or owner who understands the standard can legally conduct training at most workplaces. The OSHA 10 or 30 certification is not required to be a trainer; it is an outreach awareness course, not a trainer certification.

What are the OSHA training requirements for lockout tagout?

29 CFR 1910.147 requires training for authorized employees (those who perform servicing) on the energy control procedure for each machine they service, and for affected employees (those who operate machinery that may be serviced) on the purpose and use of LOTO. Training records must certify the employee's name, the date, and which standard was met. Retraining is required when procedures change or when an employee's behavior suggests they did not understand the original training.

How many OSHA training violations happen each year?

OSHA does not publish a count of training-specific violations separate from total citations, but training deficiencies appear in nearly every top-cited standard. Fall protection training (29 CFR 1926.503) drew 6,307 citations in FY 2024, the most cited construction standard. Hazard communication (29 CFR 1910.1200) drew 2,888. Together those two training-heavy standards accounted for roughly 9,200 citations in a single year.

What OSHA training is required before starting a construction job?

29 CFR 1926.21(b)(2) requires employers to instruct every construction worker on recognizing and avoiding unsafe conditions before they begin work. Beyond that general requirement, site-specific training depends on the hazards present: fall protection training before exposure to fall hazards (1926.503), scaffold training before working on scaffolds (1926.454), and applicable chemical and PPE training. Many contracts and general contractors also require OSHA 10-hour completion, though that is a contract requirement, not a federal regulatory one.

Does OSHA require training to be documented in writing?

Not always, but practically yes. Some standards explicitly require written certification (fall protection, forklift, LOTO, bloodborne pathogens). Others are silent on format. Inspectors treat the absence of documentation as evidence that training did not occur. A simple sign-in sheet with the date, topic, trainer's name, and employee signatures is the minimum defensible record for standards that do not specify a format.

Are OSHA training requirements different for small businesses?

The training content and frequency requirements are the same regardless of company size. Small employers do get a penalty reduction if they are cited: businesses with 25 or fewer employees receive a 60% reduction in proposed penalties under OSHA's Field Operations Manual. Some standards have exemptions for very small employers, but those exemptions generally do not touch training requirements, which apply based on workplace hazards, not headcount.

What is the penalty for failing to provide required OSHA training?

Training violations are typically classified as serious violations, carrying penalties up to $16,550 per violation as of 2024 (inflation-adjusted annually). Willful or repeated violations can reach $165,514 per violation. OSHA applies size-based reductions for small employers. The best way to cut penalty exposure is documentation: records showing training happened, what was covered, who attended, and when.

Does completing an OSHA 30-hour course satisfy standard-specific training requirements?

No. The OSHA 30-hour Outreach course is a general awareness program that covers many hazards at an overview level. It does not substitute for the specific training required by individual standards like HazCom, LOTO, Bloodborne Pathogens, or Respirators. Some states and federal contracts require OSHA 10 or 30 completion as a condition of site access, but those are contractual requirements separate from the regulatory training requirements embedded in each CFR standard.

Sources

1. OSHA, Top 10 Most Frequently Cited Standards FY 2024: Fall protection training (29 CFR 1926.503) was cited 6,307 times and Hazard Communication (29 CFR 1910.1200) was cited 2,888 times in FY 2024.
2. OSHA, Standards (29 CFR) full text: OSHA training requirements are embedded in individual standards across 29 CFR Parts 1910, 1926, and 1915.
3. OSHA, Bloodborne Pathogens Standard 29 CFR 1910.1030: Bloodborne pathogens training records must include the date, content, trainer qualifications, and employee names and job titles, retained for 3 years.
4. OSHA, Letter of Interpretation: Training in a language and vocabulary workers understand: OSHA policy requires training to be conducted in a language and vocabulary the employee understands; training in a language the worker does not understand does not satisfy the standard.
5. OSHA, Training Requirements in OSHA Standards (Publication 2254): OSHA has accepted computer-based and online training when all required topics are covered and employees can ask questions and receive answers.
6. OSHA, Hazard Communication Standard 29 CFR 1910.1200: HazCom training is required at the time of initial assignment and whenever a new physical or health hazard is introduced to the workplace.
7. OSHA, Penalties (civil penalty amounts): Serious violations carry penalties up to $16,550 per violation and willful violations up to $165,514 per violation as of 2024, adjusted annually for inflation.
8. OSHA, State Plans: Twenty-nine states and two territories operate OSHA-approved state plans that must be at least as effective as federal OSHA but may be stricter.
9. OSHA, Construction Safety Training 29 CFR 1926.21: 29 CFR 1926.21(b)(2) requires employers to instruct each construction employee in recognition and avoidance of unsafe conditions before beginning work.
10. OSHA, Lockout/Tagout Standard 29 CFR 1910.147: LOTO training must cover energy control procedures for each machine, with certifications recording employee name, date, and standard met; retraining required when procedures change or inadequate training is observed.
11. OSHA, Powered Industrial Trucks Standard 29 CFR 1910.178: Forklift operators must be trained and evaluated before unsupervised operation, with recertification required at least every 3 years or sooner following an incident or observed unsafe operation.
12. OSHA, Respiratory Protection Standard 29 CFR 1910.134: Respiratory protection training is required before use and annually thereafter; fit testing must also be conducted annually and cannot be replaced by online training.
13. OSHA, Field Operations Manual (FOM), CPL 02-00-164: Employers with 25 or fewer employees receive a 60% reduction in proposed OSHA penalties under the Field Operations Manual size-based adjustment.