OSHA Releases Inspection Plan Under Site-Specific Targeting Program

The Occupational Safety and Health Administration (OSHA) will continue to target high-hazard workplaces for inspections under its 2010 Site-Specific Targeting (SST) program. (pdf)  As discussed in a news release, the SST program “is OSHA's main programmed inspection plan for non-construction workplaces that have 40 or more workers.” The plan is based on information gathered from OSHA’s 2009 Data Initiative (ODI) survey, which collected injury and illness data from approximately 80,000 private sector establishments in high-hazard industries during 2008. OSHA uses this information to calculate establishment-specific injury/illness rates, and in combination with other data sources, to target enforcement and compliance assistance activities. According to the agency, this year OSHA is also collecting work-related injury and illness data from approximately 20,000 establishments in the construction industry, in addition to non-construction establishments. The 2010 SST, however, does not include data on construction worksites. The ODI’s information is similar to that gathered by the Bureau of Labor Statistics (BLS). The BLS, however, collects data from only a sample of all private-sector establishment in generating its annual injury and illness report.

In essence, the SST report “defines key terms, describes the three inspection lists, provides scheduling and inspection procedures, and gives information on IMIS coding.” The document also includes three appendices that provide information on the industry groups included in the 2009 ODI, include a checklist for compliance safety and health officers (CSHOs), and instruct Area Offices on how to use the Inspection Targeting website. The targeted employers are culled from various manufacturing, non-manufacturing, and nursing home establishments.

The 2010 SST is not significantly different from the prior year’s SST.  According to the plan, the primary changes are that it used 2008 injury and illness data to compile the targeting lists, and removed references to the Enhanced Enforcement Program (EEP). The EEP was designed to supplement the agency’s National Emphasis Programs (NEP), which focus on specific industries with high injury, illness, or fatality rates, or on hazards such as lead, silica, or amputations. The EEP has been replaced by the Severe Violator Inspection Program.

According to the Compliance Officer Checklist included in the SST’s appendix, if the CSHO discovers that the establishment is a Voluntary Protection Programs (VPP) site, he or she must exit the site without conducting an inspection, and the establishment must be deleted from the inspection list. Similarly, if the establishment takes part in OSHA’s Consultation Safety and Health Achievement Recognition Program (SHARP), then the CSHO must leave the site without conducting an inspection. If the establishment’s application to either of these programs is pending, then the inspection will be deferred.

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Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.