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OSHA Initiates Site-Specific Targeting Using Form 300A Data

Updated: Dec 4, 2018


New inspection program will utilize employer-submitted data obtained through new electronic reporting regulations

Effective October 16, 2018, OSHA’s Directive # 18-01 (CPL 02) implemented the targeting for inspection, companies in both manufacturing and non-manufacturing industries having 20 or more employees, which will be based entirely on their electronically-submitted data.


The new inspection program is called Site-Specific Targeting 2016 (SST-16) and it utilizes the Form 300A injury and illness information which was electronically submitted by employers for Calendar Year 2016 under 29 CRF 1904.41.


This program helps OSHA achieve its goal of ensuring that employers provide a safe and healthful workplace by directing enforcement resources to those workplaces with the highest rates of injury and illnesses. Additionally, OSHA will target for inspection those employers which should have provided Calendar Year 2016 Form 300A injury and illness data but did not.


Under 29 CRF 1904.41, OSHA required employers to electronically submit Form 300A data by Dec. 15, 2017. For this year, the “2017 submission deadline” was July 1, 2018; however, employers may still provide this information to the database. Note: 300A submissions after the July 1, 2018 deadline will be flagged “LATE” by OSHA.


Those Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and those establishments with 20-249 employees that are in ‘high risk’ industries (companies with a historically high rates of occupational injuries and illnesses) will be required to submit online for Calendar Year 2018 Form 300A injury and illness data by March 2, 2019. Going forward, Form 300A injury and illness data submissions will be due every March 2.


OSHA will focus on establishments that are most likely experiencing elevated rates and numbers of occupational injuries and illnesses. The inspection lists will be comprised of those establishments that have elevated Days Away, Restricted or Transferred (DART) rate together with a random sampling of other establishments that did not provide the required 2016 Form 300A data to OSHA. Inclusion of these non-responders is intended to discourage employers from not reporting injury and illness information in order to avoid inspection.


Because the average DART rates vary widely among different industries, DART rates for manufacturing and non-manufacturing are set as a selection criteria to achieve a 50/50 representation of the “targeted companies” on OSHA’s list.


If an establishment is an approved participant in the Pre-Safety and Health Achievement Recognition Program (SHARP), it may be granted a deferral from OSHA targeted inspections. Additionally, Voluntary Protection Programs (VPP) Applicants will be removed from any inspection list for the duration of their VPP participation.


Under this new Federal program, those States with OSHA approved State Plans are also required to have their own Site-Specific Targeting (SST) inspection system, which must be documented and submitted to OSHA. The inspection policy and procedures must be at least as effective as OSHA’s and must be available for review. Adoption of these targeting policies and procedures by the State should be accomplished within 6 months of the effective date (March 15, 2019).


These targeted inspections will be comprehensive in scope and based on the OSHA Area office’s knowledge of the workplace. If the workplace site has been previously inspected, then then OSHA Director may expand the inspection to cover both health and safety hazards based on that prior inspection. During these inspections, review of the establishments OSHA 300 Logs for the past 3 years will also be scrutinized.


Those establishments that were required to submit 300A data online into OSHA’s Injury Tracking Application (ITA) and failed to do so may be subject to citation. In accordance with OSHA’s policy for recordkeeping related violations, failure to submit 300A records would be classified as an “Other Than Serious” violation. Even though a “failure to submit” violation will not usually cause death or a serious injury, it is related to job safety and employee health. The maximum penalty for each such violation is $12,675 and each violation is discretionary.


OSHA's On-Site Consultation Program offers no-cost and confidential occupational safety and health services to small to medium-sized businesses in all 50 states, the District of Columbia, and several U.S. territories, with priority given to high-hazard worksites. One important item, the On-Site Consultation services are separate from enforcement and do not result in any penalties or citations. Consultants from state agencies or universities work with employers to identify workplace hazards, provide advice for compliance to OSHA standards, and assist in establishing and improving safety and health programs.


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