OSHA’s Site-Specific Targeting Program

On April 8, 2025, the Occupational Safety and Health Administration (OSHA) released directive CPL 02-01-067, updating its site-specific-targeting (SST) program. The SST is the agency’s primary initiative for targeting non-construction workplaces with 20 or more employees for inspections based on reported injury and illness data. It aims to identify and inspect establishments with higher-than-average rates of incidents—or those that have failed to report required data altogether.

With the newest version of the SST program now in effect, OSHA is using injury and illness data from Calendar Years 2021 through 2023 to determine which workplaces should be inspected.

Who is OSHA Targeting for Inspection?

The recent update of the SST replaces the previous SST directive issued in February 2023 and significantly updates how OSHA selects workplaces for inspection. OSHA will now focus inspections on establishments with

• Days Away, Restricted, or Transferred rate (DART) rates that are trending upward from 2021–2023
• Higher DART rates in CY2023
• Failure to submit Form 300A data for 2023
• Unusually low DART rates, to verify data integrity

To create its inspection list, OSHA utilizes NAICS codes, applying one DART rate threshold for manufacturing establishments (NAICS codes 31-33) and a different rate for non-manufacturing establishments (all other NAICS codes excluding construction). This approach typically results in an even split between manufacturing and non-manufacturing sites. Manufacturing codes include all manufacturing industries including but not limited to food and beverage, electronics, medical devices and chemical manufacturing. Non-manufacturing codes include but are not limited to other industries such as healthcare, warehousing, and utilities.

Between April 7, 2023, and December 12, 2024, the SST program led to 652 OSHA inspections. Data from this period shows that SST-selected sites had a higher number of violations per inspection and a greater rate of non-compliance.

What to Expect During an Inspection

There are three parts to an OSHA inspection: an opening conference, a walkaround, and a closing conference. The inspection starts with the opening conference and involves a brief meeting between the inspector and employer representatives. During this meeting, OSHA will explain the purpose and scope of the inspection.  After the opening conference, the inspector will conduct the walkaround of the facility, touring the workplace looking for hazards and potential violations. In addition to the site tour, as part of the SST, OSHA will conduct a comprehensive review of recordkeeping including a review of OSHA 300 logs, 300A summaries, and 301 incident reports for 2021-2023. The final step in the OSHA inspection process is the closing conference. If any hazards or violations have been identified, the inspector will discuss their findings during the closing conference and explain the next steps with regard to issuing potential citations, fines, corrective actions, and deadlines.

The Time to Prepare is Now

Where do you stand? The time is now to determine if your business meets the criteria for an increased likelihood of an OSHA inspection. If your business were to be inspected by OSHA, how would this inspection go? In addition to determining the likelihood of inspection, it is crucial to be proactive with safety and evaluate compliance status with health and safety regulations.  Employers should take the following actions:

• Audit your OSHA Logs: ensure OSHA logs have been accurately completed and submitted on time.
• Determine your DART rate: Calculate your DART rate, compare it to industry averages, determine trends and if it has increased or decreased from 2021-2023.
• Evaluate and Strengthen your Safety Program: does your safety program effectively meet compliance with OSHA regulations and industry best practices?
• Conduct Mock Inspections: Have a third-party audit your safety programs. Determine compliance gaps and recommendations for improvement.
• Create a Plan for the event of an OSHA inspection: Establish a site lead who will be the main point of contact during inspection and be present throughout. Be professional, but don’t volunteer information, consider your route during the walkaround and limit the scope of the inspection as much as you can.

We’re Here to Help

Navigating OSHA regulations can be overwhelming, but you don’t have to do it alone. Our team at ALL4 specializes in helping employers evaluate compliance, reduce risk, and build successful health and safety programs.

If you’re unsure whether your business may be targeted or you just want to be prepared contact us today for a health and safety assessment or to schedule a mock inspection. If you have any questions related to OSHA or the SST program, please reach out to John Kelleher, CSP at 774-249-3497 or jkelleher@all4inc.com.