OSHA Updates Targeted Inspection Program for Establishments with the Highest Injury and Illness Rates
The Occupational Safety and Health Administration (OSHA) at the U.S. Department of Labor has updated its Site-Specific Targeting (SST) inspection program. The changes took effect on May 20, 2025. The SST program aims to ensure that employers provide safe and healthful workplaces through inspections to ensure that employers are remediating hazards in the workplace and maintaining OSHA compliance.
The SST inspection program is the main OSHA site-specific programmed inspection initiative for non-construction workplaces with 20 or more employees and is targeted at industries and establishments that are most likely to be experiencing elevated rates and increasing numbers of workplace illnesses and injuries. Under the program, OSHA directs its resources to workplaces with the highest rates of injuries and illnesses based on employer-submitted 300A data for calendar years 2021, 2022, and 2023.
OSHA generates its inspection lists based on elevated Days Away, Restricted, or Transferred (DART) rates; upward trending rates; establishments that failed to submit the required 2023 Form 300A data to OSHA; and establishments with low DART rates in CY 2023 to verify data accuracy and quality control.
OSHA data shows the SST program to be an effective means of using its resources. Out of the 652 inspections between April 7, 2023, and December 12, 2024, there were fewer no-inspections at SST-selected establishments than at other non-construction programmed inspections. There was a higher rate of violations per inspection at SST-selected establishments than at other programmed inspections, and a higher rate of violations per inspection and a higher not-in-compliance rate at SST-selected sites than at other programmed inspections.
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High-rate establishments are selected based on two DART rates based on CY 2023 data, one for manufacturing and one for non-manufacturing, due to the higher average DART rate in manufacturing. Upward-trending establishments are identified based on rates for CY 2021-2023 that are at or above twice the private sector national average for CY 2022. Low-rate establishments are selected at random from establishments with low DART rates, and a random sample is generated of establishments that failed to submit the required Form 300A data in CY 2023.
The new directive makes the following changes:
- For high-rate establishments, the SST inspection program will select individual establishments for inspection using CY 2023 Form 300A data, rather than CY 2021 data per the previous directive.
- The SST plan will select upward-trending establishments for inspections based on Form 300A data from CY 2021 through CY 2023, rather than CY 2019 through CY 2021 data.
- The low-rate establishments list will be generated using CY 2023 Form 300A data, rather than CY 2021 data.
- The non-responders list will be generated from CY 2023 data rather than CY 2021 data.
The new directive, CPL 02-01-067, cancels the previous directive (CPL 02-01-064 – February 7, 2023) and will remain in effect for a period of two years from the effective date unless replaced by a new instruction. Should a new directive not be issued before the termination date, any inspection cycles that are currently underway will be completed.
