The Occupational Safety and Health Administration (OSHA) is updating its inspection program that targets its enforcement resources to establishments with the highest rates of injuries and illnesses.
The Site-Specific Targeting (SST) Directive is OSHA’s primary targeting program for non-construction establishments with 20 or more employees. The agency selects establishments based on injury and illness data employers submitted on Form 300A for calendar years 2017-2019. Business use Form 300A to report a yearly summary of illnesses and injuries.
The new directive, effective Dec. 14, 2020, replaces one from 2016, and includes the following:
- High-Rate Establishments: The SST plan selects individual establishments for inspection based on CY 2019 Form 300A data. Because average DART rates vary widely among industries, OSHA will set one DART rate for manufacturing and a different DART rate for non-manufacturing as objective selection criteria. OSHA says this allows it to equally target manufacturing and non-manufacturing establishments.
- Upward Trending Establishments: For this new category, OSHA will identify establishments with rates above their industry’s national average in CY 2017 that have continued to trend upward in both CY 2018 and CY 2019 and continue to remain above their industry’s national average.
- Low-Rate Establishments: To verify the reliability of the Form 300A data reported to OSHA, the agency will generate a random sample of establishments with low DART rates using the CY 2019 data.
- Non-responders: To verify data quality and accuracy reported on the Form 300A, OSHA intends to also include a random sample of low-rate establishments from the CY 2019 data. This is intended to discourage employers from not complying with their reporting obligation.
In a change, the new directive allows records-only inspections to occur when a compliance safety and health officer determines incorrect data led to an establishment’s inclusion in the program. This means OSHA will conduct a full inspection only when the employer has an actual elevated injury and illness experience.
Inspection programs based on specific hazards (such as combustible dust or lead) or specific industries (such as logging, scrapyards, shipbreaking, or petroleum refineries) may run concurrently with the SST program.
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