Enforcement and Inspection

OSHA Releases Update on Site-Specific Targeting (SST) Policy

On December 14, the Occupational Safety and Health Administration (OSHA) updated its inspection policy for workplaces with the highest reported injury and illness rates. The Site-Specific Targeting (SST) inspection plan does not include construction industry worksites.

Safety Target Hard Hat

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The updated policy creates a new targeting category for workplaces with consistent injury and illness rate increases over a three-year data collection period. It also allows records-only inspections when a compliance safety and health officer (CSHO) determines that incorrect data led to an establishment’s inclusion in the program. According to the agency, this change ensures that inspectors will conduct a full inspection only when an employer actually has elevated injury and illness rates.

The SST directive instructs area offices to select establishments with 20 or more employees based on injury and illness data employers submitted on Form 300A (the annual Summary of Work-Related Injuries and Illnesses) for calendar years (CY) 2017-2019. The directive cancels and replaces SST-16, issued October 16, 2019. However, area offices that have started but not completed their inspections under the SST-16 plan must complete that cycle of inspections before moving on to inspections under the new SST plan.

OSHA will generate inspection lists of workplaces with elevated Days Away, Restricted, or Transferred (DART) rates, both for CY 2019, and sites that experienced upward trending rates for the three-year range of CY 2017-2019. The agency also will identify a random sample of establishments that did not file required 2017, 2018, and 2019 Form
300A data with OSHA.

Under the SST plan, selected workplaces then are sorted into four categories:

  • High-rate establishments with reported injury and illness rates above their industry’s average–OSHA will use different DART rates in their selection criteria for manufacturing and nonmanufacturing industries;
  • Upward trending establishments with rates above their industry’s national average in CY 2017 that have continued to trend upward both in CY 2018 and CY 2019 and continue to remain above their industry’s national average;
  • Low-rate establishments, a random sample of establishments with low DART rates using the CY 2019 data to verify the reliability of the Form 300A data reported to OSHA; and
  • Non-responders, establishments that failed to provide the required Form 300A data to OSHA for CY 2017-2019 to discourage employers from not complying with their injury and illness reporting obligations in an attempt to avoid inspection.

During a records-only inspection, the CSHO must conduct a partial walkthrough of the workplace and interview employees to verify the establishment’s injury and illness experience. However, the agency will investigate any serious violations observed in plain view or brought to the attention of the CSHO.

The SST plan is not intended to include office-only facilities. If a CSHO arrives at an establishment and discovers there only is an office at the site, the CSHO should determine what site or sites are associated with the OSHA Form 300A data.

If the Form 300A data includes information for sites in addition to an office, then an inspection of the site, or one of the sites, with the highest DART rates shall be conducted if those sites are within the area office’s jurisdiction.

The directive expires in two years unless it is replaced by a new directive.