Building Your EHS Program Using the OSHA Technical Manual (OTM)

The OSHA Technical Manual is a reference for use by OSHA’s Compliance Safety and Health Officers (CSHOs), also known informally as OSHA inspectors. Updated regularly, it contains information about identifying, evaluating, and minimizing health and safety hazards that CSHOs may see when conducting inspections.

What Do OSHA Compliance Safety and Health Officers Do?

These are workplace safety inspectors whose goal it is to help employers and employees achieve safer workplaces. They’re credentialed safety and industrial hygiene professionals. CSHOs are authorized to make unannounced inspections; however, employers do have the right to request an inspection warrant first.

Inspections may come about due to referrals from other agencies or complaints from inside or outside the organization. They may also originate based on reported workplace accidents and incidents or industry statistics related to injury rates. One of the resources that OSHA CSHOs use to carry out their duties is the OSHA Technical Manual. 

What does the OSHA Technical Manual Include?

The manual is divided into ten sections. The first one highlights what’s been changed since the last update. Sections two through nine cover sampling, measurement methods, and instruments; health hazards; safety hazards; construction operations; healthcare facilities; ergonomics; personal protective equipment; and safety and health management; with the tenth section dedicated to miscellaneous topics. 

How Inspectors Use the OSHA Technical Manual

Inspectors use each section of the OSHA Technical Manual for an overview of the topic as well as a snapshot of the frequency and type of illness or injury related to that topic. Each section also provides guidelines for investigation. These include suggested records review, interview questions for employers and employees, and metrics for evaluation. Highlights of prevention and control measures are included. Additional resources and insight for accurate and detailed analysis are provided. 

For example, a CSHO investigating indoor air quality may refer to that section of the OSHA Technical Manual to learn more about common complaints about indoor air quality, like nausea, dizziness or throat irritation. The manual lets the inspector know that most indoor air quality issues arise from poor ventilation although other causes include contamination or microbes.

Inspectors can refer to a list of common contaminants with associated sources and symptoms. One example is acetic acid which causes eye, nose, and throat irritation. Workers may be exposed to acetic acid via silicone caulking compounds or X-ray development. CSHOs are guided by the technical manual in where to look for the source of the problem, how to take and measure samples to evaluate the severity of the problem, and the best practices employers and employees can take to reduce exposure to the problem.

The Role of the OSHA Technical Manual

While this is a helpful and trusted guide for inspectors, it does not take the place of the formal OSHA Standards. In cases where the OSHA Technical Manual and the OSHA Standards differ, it’s the Standards that take precedent.

The Technical Manual a useful tool for employers and workplace safety professionals and OSHA welcomes their use of it. It’s a valuable resource in thinking about and developing workplace health and safety programs.