The Occupational Safety and Health Administration (OSHA) uses inspections to help ensure employers provide safe and healthy workplaces. In April 1999, OSHA implemented its first nationwide Site-Specific Targeting (SST) plan to conduct comprehensive programmed inspections in non-construction worksites with 20 or more employees. The SST inspection program has been renewed and updated since that time, and on May 20, 2025, OSHA issued the most recent directive for its SST inspection program. This new version is more narrowly focused, prioritizing programmed inspections at establishments with high or upward-trending injury and illness rates, as well as those that failed to submit required information.

Key Changes

The SST program uses injury and illness data that employers submit under 29 CFR 1904.41 through OSHA Form 300A. The new SST directive was updated to rely on data from calendar year (CY) 2023 versus CY 2021, reflecting OSHA’s continued efforts to allocate enforcement resources based on the most recent injury and illness data. OSHA then uses this data to target and identify facilities for a potential SST inspection, as follows:

• High-rate establishments: Facilities with elevated Days Away, Restricted, or Transferred (DART) rates for CY 2023. Importantly, OSHA will set one DART rate of manufacturing and a different DART rate for non-manufacturing to provide for equal targeting from both groups.
• Upward-trending establishments: Facilities with rates at or above twice the private sector national average in CY 2022 that have continued to trend upward annually from CY 2021-2023.
• Low-rate establishments: Those with low DART rates. Low-rate facilities will be randomly selected for inspection to verify the reliability of Form 300A data.
• Non-responders: Facilities that failed to submit CY 2023 Form 300A data, as required. A random sample of non-responders will be inspected to discourage employers from not reporting.

What’s Involved

Based on data collected and the above criteria, OSHA Area Offices (AOs) select facilities to target for planned SST inspections. The SST inspections are comprehensive in scope and may be expanded with justification (e.g., including health hazards based on prior inspection history in industry classification).

During the SST inspection, the Certified Safety and Health Official (CSHO) will do the following:

• Review data. The CSHO will review available OSHA 300 Logs, Form 300A summaries, and 301 Incident Reports for CY 2021, 2022, and 2023.
• Conduct a facility walkthrough. During the walkthrough, the CSHO will evaluate potential hazards in all areas of the workplace; however, the focus will largely be on those areas where the facility has had documented injuries and illnesses.
• Evaluate employee exposures. The CSHO will pay particular attention to hazards observed during the walkthrough, discussed in employee interviews, and/or identified on OSHA 300 Logs and 301 Incident Reports.
• Assess the safety and health management system. The SST inspection will focus on whether the management system is adequate to identify and address the elevated injury and illness rates.
• Conduct a closing conference. The CSHO will discuss with the employer identified hazards, gaps in reporting practices, and deficiencies in the safety and health management system during the closing conference.

What You Can Do

The updated SST inspection program update reflects OSHA’s ongoing commitment to data-driven enforcement and targeted inspections in general industry. Correspondingly, accurate data is critical. Facilities must have their OSHA recordkeeping and reporting practices in check. Not only should records be verified as accurate and complete, but each accident should have a documented corrective action. This information should be checked, and any additional actions should be made to fully comply with Occupational Safety and Health (OSH) Act requirements.

But beyond recordkeeping and reporting, facilities can take steps to avoid an SST inspection altogether by making sure they have the processes, programs, and systems in place—and documented—to protect employees’ safety and health:

• Develop comprehensive safety programs and a robust safety management system. A compliance management information system can provide a centralized location to track and manage all safety-related information (e.g., policies, procedures, and practices) to not only help ensure going compliance but to also provide the documentation required should an inspection occur.  
• Regularly assess the level of existing OSHA programs against compliance issues and potential accidents. Identify what may need to change in the facility’s OSHA compliance programs and practices to ensure their effectiveness and then implement and document appropriate corrective actions.
• Maintain robust occupational health and safety and incident. Information technology (IT) tools, such as KTL’s OSHA 300 Power App, with its comprehensive intake form tailored to OSHA 300 and OSHA 300A requirements, make it easier to collect, search, and analyze data—and maintain OSHA compliance. Using a digital forms further helps ensure no crucial data points are missed and makes it easy to filter, search, and analyze records and data to offer deeper insights into safety performance.
• Understand what to expect from an OSHA inspection. Educate staff on the process a CSHO will follow and make sure team members understand their roles in the inspection. Prepare staff to respond appropriately to the CSHO’s questions and, importantly, make sure they know how to locate requested documentation.
• Train employees. All employees should receive ongoing training to fully understand and follow safety processes and procedures. Training should focus on worker knowledge and understanding their responsibilities to comply with identified requirements.