The federal Occupational Safety and Health Administration (OSHA) announced May 20 it updated its Site-Specific Targeting (SST) program of workplace inspections.
The program directive (CPL 02-01-067), signed on April 8 and effective May 20, replaces a directive issued on February 7, 2023.
The process for selecting establishments for inspection uses OSHA Form 300A data from calendar years 2021 to 2023. Establishments may be selected for inspection based on:
- High injury and illness rates in the 2023 data,
- Upwardly trending injury and illness rates based on 2021 to 2023 data at or above twice the 2022 private sector average,
- Injury and illness rates that are markedly below industry averages, and
- Failure to submit an OSHA Form 300A in 2023.
The SST program is OSHA’s main initiative for site-specific programmed inspections at nonconstruction workplaces that have 20 or more employees, according to the agency. By applying industry and establishment-size criteria, OSHA focuses its enforcement resources on workplaces most likely to have experienced elevated rates or increased numbers of occupational injuries and illnesses.
Workplaces that have achieved Safety and Health Achievement Recognition Program (SHARP) status are deferred from federal OSHA or State Plan programmed inspections for up to two years. If a workplace has applied to join OSHA’s voluntary protection program (VPP) and an on-site review has been scheduled, the area office will remove the applicant from any programmed inspection list (including an SST inspection list) for up to 75 days before the scheduled on-site review.
An area office will initiate an SST program inspection as either a comprehensive safety or a health inspection based on the office’s knowledge of the workplace’s potential hazards. However, the scope of an inspection may be expanded under procedures in the agency’s field operations manual.
During an inspection, agency compliance safety and health officers (CSHOs) review the facility’s OSHA 300 logs, 300A summaries, and 301 incident reports for three prior calendar years (2021, 2022, and 2023).
For the facility walk-through, CSHOs are instructed to consider and evaluate potential hazards in all areas of the workplace, with a focus on areas where documented injuries or illnesses have occurred. They’re also instructed to pay particular attention to employee exposures to hazards identified in employee interviews, hazards in plain view, and injuries or illnesses identified on OSHA 300 and 301 forms.
SST program inspections also include an evaluation of the employer’s safety and health management system, focusing on whether the system is adequate to identify and address the elevated rate of injury or illness at the facility.
Some facilities may be selected for SST inspections along with inspections under one or more OSHA national or regional emphasis programs. Inspections for emphasis 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.
Therefore, agency CSHOs may perform SST-only inspections, SST inspections combined with inspections under other emphasis programs, or SST inspections combined with unprogrammed inspections. The directive includes instructions for recording and tracking the different types of inspections.