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OSHA Announces Revised Site-Specific Targeting Directive

Food & Agribusiness, Healthcare, Manufacturing & Distribution, Property & Casualty, Senior Living & Social Services, Transportation

Though businesses continue to face many challenges with COVID- 19, Occupational Safety and Health Administration (OSHA) has released the new Site-Specific Targeting (SST) directive. The new SST directive, (SSTARG171819) took effect on December 14, 2020, which replaces SST-16.

The Site-Specific Targeting (SST) Directive is OSHA’s primary program for non-construction establishments with 20 or more employees. The directive targets its enforcement resources to establishments with the highest rates of injuries and illnesses. The agency selects establishments using employer-submitted Form 300A data from CY 2017 through 2019. OSHA will generate inspection lists of establishments with elevated Days Away, Restricted, or Transferred (DART) rates, both for CY 2019 and sites with upward trending rates for the tree-year range of CY 2017-2019. OSHA will also identify a random sample of establishments that did not provide the required 2017, 2018, and 2019 Form 300A to OSHA and low rate establishments.

The new directive, effective Dec. 14, 2020, replaces one from 2018, and includes the following changes:

  • 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 stated that this change will equally target manufacturing and non-manufacturing establishments. OSHA has not released those average DART rates yet.
  • Upward Trending Establishments (NEW): 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: OSHA will generate a random sample of establishments that failed to provide required Form 300A data to OSHA for CY 2017-2019.

The Office of Statistical Analysis will provide each OSHA Area Office (AO) with access to software and databases that include the establishments on the Inspection List. (Only OSHA and State Plan states will have access to this information). A 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. Employers should be prepared that the compliance officer is required to conduct a partial walkthrough of the workplace and interview employees to verify the establishment injury and illness experience. Any violations observed in plain view during walkthrough or brought up during interviews will be investigated.

This directive also directs the AO to delete an establishment from the inspection list if the establishment has received comprehensive safety or inspection programs within 36 months of the creation of the current inspection cycle. 

Key Takeaway

OSHA Area Offices will begin running SST lists, even with limitations caused by the pandemic. Organizations would be well served to review company OSHA investigation, procedures, and controls to ensure they are in line with required OSHA standards in the event of a site visit. Organizations should also review the new SST directive.

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