OSHA’s Site-Specific Targeting Program (SST)
The Site-Specific Targeting Program is OSHA’s primary programmed inspection plan. Its chief purpose is to cover non-construction worksites having 20 or more employees. In the spectrum of OSHA inspections, Site-Specific Targeting is unique in that there is a detailed, objective methodology behind the “neutral” scheduling of inspections under this category. Site-Specific Targeting plans are also based on employer Days Away, Restricted, or Transferred (DART) and Days Away from Work Injury and Illness (DAFWII) data obtained through the ODI.
Site-Specific Targeting Inspection Lists
If your company is included in a high-risk industry category, then it will appear on one of three inspection lists generated for the Site-Specific Targeting program: Primary, Secondary, or Tertiary.
Yet that doesn’t mean your company will be inspected, only that the probability of an inspection is high; SST program inspections are randomly ordered.
OSHA considers a “high hazard” industry to be one within a Standard Industrial Classification (SIC) code with a National lost workday injury and illness rate among the highest 200 as published for calendar year 1992 by the Bureau of Labor Statistics (BLS) at the 4-digit SIC level. For the purpose of scheduling programmed inspections, construction and maritime are considered to be categories of high hazard employment. OSHA uses Standard Industrial Classification (SIC) and North American Industry Classification System (NAICS) Codes for categorizing businesses.
Primary Inspection List
The Site-Specific Targeting program primary inspection lists consist of 1,00+ establishments selected as part of an ongoing OSHA study that focuses on recidivism rates for businesses having been previously subjected to programmed inspections.
All companies under direct federal jurisdiction that are listed on a primary inspection list will be inspected under the SST program.
State Plan State Selection Criteria
For participating State Plan states, selection of organizations for primary lists is based on recent company-specific injury and illness rates.
The SST program calls for inspection of all organizations with the following DART and DAFWII case rates:
- Manufacturing establishments with a DART rate at or above 7.0 or a DAFWII case rate at or above 5.0 (only one of these criteria must be met).
- Non-manufacturing establishments(except for Nursing and Personal Care Facilities) with a DART rate at or above 15.0 or a DAFWII rate at or above 14.0 (only one of these criteria must be met).
Secondary Inspection List
SST Secondary Inspection lists use the most recent injury and illness data. The list is made up of organizations with the following DART and DAFWII case rates, and will be inspected as follows:
Manufacturing Establishments reporting DART rates of 5.0 or greater, or a DAFWII case rate of 4.0 or greater. Only one of these criteria must be met.
Non-manufacturing Establishments (excluding Nursing and Personal Care Facilities) Establishments reporting DART rates of 7.0 or greater, or a DAFWII case rate of 5.0 or greater. Only one of these criteria must be met.
Nursing and Personal Care Facilities Programmed inspections of Nursing and Personal Care establishments shall be conducted under OSHA Directive CPL 03-00-016, National Emphasis Program – Nursing and Personal Care Facilities (NAICS 623110, 623210, and 623311).
Inspections on the Secondary List do not have to be completed by an Area Office before the end of OSHA’s fiscal year, which normally begins on October 1st and ends on September 30th of the following year.
Tertiary Inspection List
If an Area Office completes inspections of all companies on its Primary and Secondary Inspection Lists before the expiration of the SST program, it may obtain additional establishments by contacting OSHA’s Office of Statistical Analysis (OSA). OSA provides each Area Office with the number of companies specifically requested by that Area Office, but selected randomly. No establishments with a DART rate of 3.6 or lower and a DAFWII case rate of 2.2 or lower will be included. Industries without Permanent Workplaces For industries like SIC 0783, Ornamental Shrub and Tree Services, which do not have permanent workplaces, the organization list normally only identifies the employer’s central office. The Area Office will, so far as possible, determine (e.g., by visiting the central office) which worksites are available based on the type of work scheduled for each worksite and the length of time remaining to complete the work, and then choose one worksite to inspect by using a random number table. This method applies to each company on all SST inspection lists.
Establishments with Fewer than 20 Employees
If an establishment to be inspected under the SST plan has fewer than 20 employees at the time the CSHO arrives on site to begin the inspection, the inspection will still be conducted, provided that the establishment has more than 10 employees and either its calculated DART rate or DAFWII case rate is at or above twice the private sector national incidence rates (DART = 3.6; DAFWII = 2.2), or records are not available. If the establishment has had 10 or fewer employees at all times during the previous twelve months at the time of the inspection, the CSHO will not conduct an SST inspection.
The SST is not intended to include organizations that are only offices, because those are low-risk environments, generally speaking. If a CSHO arrives at a company to find only an office at the site, the CSHO will attempt to determine what site or sites were referenced in corresponding ODI survey data. If the ODI data includes data for a site (or sites) in addition to an office, then an inspection of that site (at least one of several sites) willbe conducted if it is within the Area Office’s jurisdiction.
Site-Specific Targeting Inspection Scheduling
State-plan states have some flexibility with scheduling systems; federal states do not. Either way, the scheduling systems invariably target a similar pool of high-risk employers in high-risk industries.
The SST Program gives state-plan states the following options:
- Use a state-developed high hazard inspection targeting system based on available state data; or
- Use a high hazard inspection targeting system based on OSHA Instruction CPL 02- 00-025, Scheduling System for Programmed Inspections (January 4, 1995), which is based on Bureau of Labor Statistics (BLS) injury/ illness rate data. The Office of Statistical Analysis (OSA) will make these state-specific lists available to a state, upon request. This option may not be available in future years; or
- Use OSHA’s Site-Specific Targeting inspection plan. The plan is based on establishment specific employer Days Away, Restricted, or Transferred (DART) and Days Away from Work Injury and Illness (DAFWII) data obtained through the ODI.
OSA will provide a list of high-rate employers within the state and criteria for inspection categories upon request. But, of the three options listed above, the 3rd option, the inspection scheduling plan used by federal OSHA is probably the simplest—it leverages the efficiency of software. SST Inspection Scheduling State-plan states have some flexibility with scheduling systems; federal states do not.
OSHA’s Scheduling System Software
You probably didn’t know that the Site-Specific Targeting Program has its own website, but it does— OSHA Area Offices can access the resource to automate SST inspection scheduling, by generating lists that correspond with and localize ODI information. The software and databases for the primary and secondary lists are available through the Site-Specific Targeting program website, which is not accessible to the general public; only OSHA’s National Office, Regional Offices, Area Offices, and State Plan authorities, are able to access the website. The database contains the information for all organizations on the Primary, Secondary, and Tertiary inspection lists for each region. So, if the Area Office in your state were to commence with execution of SST inspections pursuant to regional goals, personnel simply login to the SST website to access and generate the inspection lists—they click a “Create” button. The lists are randomized by the software, but the data is weighted to ensure that organizations in the highest risk category—based on DART & DAWII rates—do not escape the SST inspection cycle. SST Inspection Cycles The number of SST inspections for each Area Office is different, based on the number of organizations in the jurisdictional range for each one; that’s the number of businesses appearing on the Primary, Secondary, and Tertiary inspection lists for its coverage area.
Area Offices do not create inspection cycles manually, for uniformity and propriety of enforcement. Inspection cycles for the Primary and Secondary Inspection Lists are generated through SST software that randomly selects companies. Each Area Office must use the “Create” function of the SST web-based application to create cycles from the SST inspections lists. The inspection lists generated by each Area Office through the SST software constitute an “inspection cycle”—if there are 50 organizations on the SST inspection list, then that’s what the cycle is. Area offices base the determination of cycle size (i.e., 5 to 50 establishments) on consideration of available resources and geographic range of the office. Within a cycle, establishments may be scheduled and inspected in any order that makes efficient use of available resources—it’s up to OSHA Area Offices to carry out the randomly generated cycles as best fits capabilities. The number of inspections actually performed depends on factors such as staffing, unprogrammed inspection activity, and special emphasis programs. If all businesses in an inspection cycle are inspected before the end of the fiscal year, OSHA field offices may generate another cycle by extending the inspection register, using the internal SST software.
However, all of the organizations in a cycle must be inspected (that is, the inspection must be initiated) before any companies in a new cycle may be inspected. OSHA Area Offices use the SST website to manage inspection information as the offices work through each respective SST cycle, working with the application to update inspection lists regarding deletions and conducted inspections. For example, the SST software keeps track of the opening conference date entered for companies that have been deleted because of prior comprehensive inspections within the last 24 months. Once the 24-month period passes, the software will make that organization available again for selection. For deletion purposes, the date when a company is considered to have received a comprehensive safety inspection will be the opening conference date, not the closing conference date or the citation issuance date. For example, if the opening conference date occurred within the previous 24 months of the creation of the current inspection cycle, the business will be deleted from the list for 2014 SST inspections. Because the Site-Specific Targeting Program is a programmed inspection and, therefore, a lower priority inspection for OSHA, Area Offices continue to conduct unprogrammed inspections and programmed inspections under national emphasis programs, or under regional, local emphasis, as Area Office and Regional goals dictate.
What Does An SST Inspection Look Like?
Inspections conducted under the SST Program plan are comprehensive safety inspections, but partial inspections, records only inspections, and walk-through inspections are also possibilities, if your DART & DAWFII scores are low enough. A programmed inspection is a comprehensive inspection of the worksite but may be limited as necessary with consideration of resource availability and other enforcement priorities such as focused inspections. (Low hazard areas, such as office space, may be excluded from inspection without affecting the comprehensiveness of the inspection.) A comprehensive inspection is a substantially complete and thorough inspection of all potentially hazardous areas of the operation. An inspection may be deemed comprehensive even though, as a result of the exercise of professional judgment, not all potentially hazardous conditions or practices within those areas are inspected.
Because inspections have an air of mystery and dread about them, we know that the possibility of inspection is never far from the mind of safety professionals or that of the folks tasked with ensuring organizational compliance; for management types in high-risk industries, OSHA inspections are a top concern. After all, OSHA totals thousands of serious violations resulting from enforcement efforts—compliance is hard to achieve. That’s especially true for large, decentralized operations. We’ve focused here on federal enforcement, using statistics that didn’t account for state directed occupational safety programs. OSHA state & federal enforcement programs—combined—perform nearly 100,000 inspections all over the country. That’s why a basic understanding of the agency’s inspection system is critical. In high-risk work environments, the circumstances impacting the safety of workers may change each day, which means that strict attention to detail, along with a strong priority on safety, is required to sustain compliance. Designated safety professionals and compliance officers have tough jobs, and are indispensable to organizations that are serious about the safety of the workforce.
What do you do with this knowledge of inspections?
Well, now that you know about inspections and causes, or triggers for each type, the importance of preparedness is fundamental. There are 2,200 27 Compliance Safety & Health Officers carrying out inspections from 90 Area Offices spread across the country. Without question, the best thing you can do for your company is to get a handle on recordkeeping. Setting up a system of reporting and recording that’s as close to automatic as possible is essential, because the first thing a visiting Compliance Officer will ask for is your safety program documentation. OSHA requires around 1.5 million employers to keep records of work-related injuries and illnesses, pursuant to Title 29 CFR, Part 1904. Any employer under OSHA’s jurisdictional umbrella—and that’s most employers—are subjected to Part 1904, a key section of the legislation that first established the agency. Part 1904 is a rule which states that employers must use three specific OSHA forms for recording workplace injuries and illnesses: OSHA Form 301 (Injury and Incident Report), OSHA Form 300 (Log of Work-Related Injuries and Illnesses), and OSHA Form 300-A (Summary of Work Related Injuries and Illnesses).
Use this information to estimate the probability of your next inspection, and be sure to take a look at your recordkeeping practices.