Labor & Employment Law Daily Wrap Up, OSHA NEWS—Date ranges for data collection updated for Site-Specific Targeting inspection program, (May 21, 2025)

By Patricia K. Ruiz, J.D.

The data collected through Form 300A aids OSHA in determining establishments’ rates of injuries and illnesses.

The Department of Labor (DOL) Occupational Safety and Health Administration updated the Site-Specific Targeting (SST) inspection program, which directs agency enforcement resources to establishments with the highest rates of injuries and illnesses. An instruction document from OSHA identifies the significant changes made to the program.

SST inspection program. The SST plan is OSHA’s main state-specific programmed inspection initiative for non-construction workplaces with 20 or more employees. The program uses objective data from injury and illness information submitted by employers under 29 C.F.R. §1904.41. The program helps OSHA achieve the goal of ensuring employers provide safe and healthful workplaces by directing enforcement resources to workplaces with the highest rates of injuries and illnesses. OSHA applies industry and establishment-size criteria to focus data collection on establishments most likely to be experiencing elevated rates and increased numbers of injuries and illnesses, based on submissions of Form 300A data.

Significant changes. For high-rate establishment, the SST plan selects individual establishments for inspection based on calendar year (CY) 2023 Form 300A data, while the previous SST used CY 2021 data. For upward trending establishments, the SST plan selects individual establishments for inspection based on CY 2021 through 2023 Form 300A data, while the previous SST used CY 2019 through 2021 data. The low-rate establishments list is generated using CY 2023 Form 300A data, while the previous SST used CY 2021 data. Finally, the non-responders list is generated using CY 2023 data, while the previous SST used CY 2021 data.

State adoption, notification. States with OSHA-approved state plans are required to have their own inspection targeting systems (a “core inspection policy”), which must be revised as necessary to reflect current practices. The inspection policies and procedures must be at least as effective as OSHA’s and be available for review. State plans must notify OSHA within 60 days of the date of notification in the state plan application (SPA) whether they intend to adopt policies and procedures identical to the SST program’s or adopt and maintain different policies and procedures for targeting of general industry inspections. State adoption must be accomplished within six months.

State plans adopting identically must provide the date of adoption to OSHA, due within 60 days of adoption. State plans adopting or maintaining policies differing from the SST must, within 60 days of adoption, either post its different policies on its state plan website and provide a link to OSHA or provide OSHA with an electronic copy and the name and contact information of an official within the state plan who can assist the public with obtaining a copy.

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