OSHA Issues Updated Guidance on Site-Specific Targeting Inspections

On May 20, 2025, the U.S. Department of Labor issued a press release updating the Occupational Health and Safety Administration’s (OSHA) Site-Specific Targeting (SST) inspection program focusing on workplaces with the highest injury and illness rates, effective immediately. OSHA’s SST inspection program is the agency’s primary planned inspection program for non-construction workplaces with 20 or more employees. This guidance replaces previous agency-issued guidance from 2023 and will terminate two years from the effective date, unless replaced. 

The SST inspection program gathers employer-submitted Form 300A data, which requires employers to report the total number of job-related injuries and illnesses that occurred within the calendar year. The updated guidance provides that the SST program will use injury and illness data from calendar years 2021-2023 when selecting establishments for inspections. The “Inspection List Selection Criteria” outlined in the updated guidance specifies that OSHA may select employers for inspection based on:

• High Days Away, Restricted, or Transferred (DART) rates identified in 2023 data;
• Upwardly trending DART rates that are equal to or above twice the 2022 private sector national average, based on 2021-2023 data;
• DART rates markedly below industry averages, selected randomly to verify the accuracy of Form 300A data; and
• Failure to submit an OSHA Form 300A in 2023, selected randomly to discourage employers from failing to comply with their duty to report work-related injury and illness.

Notably, OSHA will set one DART rate for the manufacturing industry and a different DART rate for the non-manufacturing industry. Nonetheless, this guidance applies to “general industry” establishments, which encompasses most businesses outside of the construction, maritime, and agriculture industries. 

Employers across the country should be aware of OSHA’s updated SST inspection guidance. SST inspections are programmed and, as such, comprehensive in scope. While the scope of an unprogrammed inspection is tailored based on a particular accident, injury, complaint, or referral, programmed inspections are broader. OSHA’s updated guidance instructs Compliance Safety and Health Officers (CSHO) to evaluate potential hazards “in all areas of the workplace,” while focusing on the areas where injuries or illnesses were documented by the employer to have occurred. Nevertheless, a CSHO may expand the scope of the inspection, in accordance with OSHA’s Field Operations Manual and with justification for the expansion.

Although the updated guidance prioritizes unprogrammed inspections, it also requires that all establishments on the SST inspection list be inspected, with few exceptions. Furthermore, if an unprogrammed event triggers inspection of an establishment slated for an SST inspection, the two inspections should be conducted at the same time. 

Due to the broad scope of SST inspections, employers should prepare for increased programmed inspections and enforcement by ensuring they have assessed their health and safety programs to maintain an OSHA-compliant workplace.