The Occupational Safety and Health Administration (OSHA) has released its annually updated Site-Specific Targeting (SST) program designed to focus agency inspection resources on workplaces that experience the highest injury and illness rates. The information on these rates is derived from the OSHA Data Initiative (ODI) survey of approximately 80,000 establishments in selected high-hazard industries. The latest SST program (SST-12) is effective as of January 4, 2013, and applies only to high-hazard, non-construction employers with 20 or more employees.

The OSHA directive (pdf) setting forth the terms of the SST-12 describes the various inspection lists OSHA compliance safety and health officers (CSHOs) will use and the worksites to which they apply; outlines the agency’s scheduling and inspection procedures; defines key terms; and discusses OSHA industry coding. The appendices to the document provide information on the industry groups included in the 2011 ODI; sets forth a checklist for CSHOs; and explains how OSHA areas offices will use the agency’s Inspection Targeting website. According to the SST-12’s executive summary, the following are significant changes from the prior year’s program:

• OSHA is working with the Office of the Assistant Secretary for Policy (ASP) on a study to measure recidivism rates of establishments that have been inspected. To this end, OSHA’s Office of Statistical Analysis has randomly selected 2,250 worksites from primary and secondary inspection lists for participation in this study. (A secondary inspection list sets forth the worksites an OSHA area office will inspect if it completes all inspections of establishments on its primary list.) The SST-12 states that 1,260 establishments selected from the “primary” list will be part of the study. All federal jurisdiction primary list establishments will be inspected under SST-12.
• The updated SST uses calendar year (CY) 2010 injury and illness data to compile the inspection targeting lists for the secondary list establishments.
• OSHA’s Nursing and Personal Care Facilities National Emphasis Program (pdf) will conduct programmed inspections of nursing and personal care establishments.
• The SST-12 incorporates policy changes to OSHA’s Strategic Partnership Program for Worker Safety that were included in the Office of Strategic Partnership Program’s Policy Memorandum #1: Removal and Clarification of OSPP Benefits that Impact the Agency’s Enforcement Program dated July 27, 2012. 

The injury and illness rates compiled by the ODI survey are gleaned from the OSHA Work-Related Injury and Illness Data Collection Form employers provide to the agency. According to the SST-12, employers that did not provide this information have been added to the Secondary Inspection list by OSHA’s Office of Statistical Analysis in Washington, D.C.

If an employer on the Primary Inspection list has applied to participate in OSHA’s Voluntary Protection Program (VPP), the applicant will be removed from any programmed inspection list for a period of up to 75 days prior to the scheduled VPP on-site review. In addition, “the Applicant workplace will be removed from any programmed inspection list for the duration of VPP participation, unless the site chooses otherwise.” Similarly, if the employer is in the process of qualifying for participation in OSHA’s On-site Consultation Program’s Safety and Health Achievement Recognition Program (SHARP), the inspection may be deferred for up to 18 months.

In addition to the SST program, OSHA carries out both national and local “emphasis” inspection programs to target specific high-risk hazards and industries. The agency is currently enforcing 11 National Emphasis Programs (NEPs) and 140 Regional/Local Emphasis Programs (REPs/LEPs).

Photo credit: MBPHOTO, INC.