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On May 20th, 2025, the U.S. Department of Labor (DOL) issued a press release updating the Occupational Health and Safety Administration’s (OSHA’s) Site-Specific Targeting inspection program. Specifically, the Site-Specific Targeting program directs agency enforcement resources to establishments with the highest rates of injuries and illnesses. Overall, that information is gathered based on injury and illness data submitted under OSHA’s recordkeeping requirements. In April 2024, the DOL announced a final rule related to employee representation during workplace OSHA inspections.
What is the Site-Specific Targeting Inspection Program?
Basically, the Site-Specific Targeting (SST) program is OSHA’s primary planned inspection program for non-construction establishments with 20 or more employees. 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. Based on specific criteria, certain workplaces may be selected for inspections to identify and address potential workplace hazards.
Updates to the Site-Specific Targeting Inspection Program
The recent May updates to the original SST program guidance state that the program will use injury and illness data from calendar years 2021-2023 when selecting establishments for inspections. Additionally, the new 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 that are 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.
Furthermore, OSHA will set one DART rate for the manufacturing industry and a different DART rate for the non-manufacturing sector. Regardless, the new information about the SST inspection program applies to “general industry” establishments. This includes most businesses outside of the construction, maritime, and agriculture industries.
Employer Takeaways
In conclusion, all affected employers should be aware of OSHA’s updated SST inspection program. Although the site-specific inspection itself may be triggered by one of the four reasons listed above, the guidance includes new instructions that expand the scope of previous inspections. According to Littler, for instance, Compliance Safety and Health Officers (CSHOs) are now required to evaluate potential hazards “in all areas of the workplace.” This is in addition to focusing on the areas where injuries or illnesses were documented by the employer to have occurred.
Finally, the new Site-Specific Targeting inspection program took effect immediately on May 20th, 2025. It replaced the previous SST program directive issued on February 7th, 2023.
