Enforcement and Inspection

OSHA’s SST Inspection Plan for 2008: Inspectors Swooping In

The agency has announced that nearly 4,000 companies will be subject to unannounced comprehensive inspections in its 2008 Site Specific Targeting (SST) plan. Here’s how they decide on whom to honor with a visit.


A few years back, those letters stood for supersonic transport. Then the airlines discovered that flying bigger, slower planes beat smaller and faster every time.

Now SST has a new meaning. But if you’re a company safety professional, it’s still one that can descend on you from out of the blue and leave your ears ringing before it departs.

That’s because the abbreviation now stands for Site Specific Targeting, which is OSHA’s plan for dropping in unexpectedly on thousands of workplaces, without any specific complaint being filed, and conducting a comprehensive (their description) inspection.

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The SST program, which has been around for a decade, recently announced its plan for 2008. The agency declared that it will focus on some 3,800 high hazard workplaces, with high hazard defined by two measures:

One is the DART rate, which uses OSHA injury and illness data from the previous year, to count the number of employees with days away from work, days on restricted work, or job transfers due to workplace-caused injury or illness. Score 11 such workers per 100 full time employees and congratulations! You’ve made OSHA’s SST hit list. Make it within a range of  7 to 11 and you’re on a secondary list if OSHA has enough inspection personnel to visit you as well as the primary targets.

The other major way to get into the “3800 Club” is via the DAFWII rate, which stands for Days Away From Work Injury and Illness, again per 100 workers. Score 9 on this metric and you join those who’ve DARTed through as a candidate for STT.   

As a perspective on how high these entry rates are, OSHA says that looked at nationally, private business has a DART rate of 2.3 and a DAFWII rate of 1.3. So it does seem that the targeted industries are significantly higher in incident rates.

Random Audits, Too

There’s yet another way to draw an inspection. Just as the IRS randomly chooses a number of seemingly compliant taxpayers for audits, OSHA does the same with SST.
Some 175 workplaces with 100 or more employees from high score industries, but normal individual incident rates, will be inspected anyway, just to see if their behavior and reporting are what they seem.  

The SST program draws praise from OSHA director Edwin G. Foulke, Jr. “We make effective use of our inspection resources,” he says, adding that, “this program emphasizes the importance of our enforcement efforts in ensuring safe working conditions for employees.”

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OSHA hasn’t announced the SST target industries for 2008. But here’s a list the agency published in the SST plan of those with the highest DART rates in the 2007 survey. That means these are the ones on which inspection decisions are made for this year’s plan:

SST target industries with highest DART rates in 2007 survey

Tomorrow, we’ll offer you a tool to get more news about this program, (along with nearly everything else that happens in safety training and compliance,) to see whether OSHA’s SST looks likely to land on your doorstep.