OSHA 2011 Site-Specific Targeting Directive

Each year, OSHA revises its Site-Specific Targeting Directive based on the previous year’s data relating to workplace injuries and illnesses. OSHA “uses these data to calculate establishment-specific injury/illness rates, and in combination with other data sources, to target enforcement and compliance assistance activities.” Based on the results, locations with higher incident rates are scheduled for comprehensive inspections, including review of OSHA 300 logs for at least three of the past four years.

The current inspection priorities govern Non-Construction Industries and are based on data collected in 2010 for occurrences in 2009. OSHA divides such establishments into primary, secondary, (and tertiary) targets for inspection prioritization. The stated goal is to allocate enforcement resources to workplaces where the highest rates of injuries and illnesses occur. Last year, only establishments with 40 or more employees were listed. This year, the “high hazard” establishments list includes locations with as few as 20 employees. With this greater inclusion on primary and secondary locations, inspections at tertiary establishments become less likely.

“Primary” Inspection List

• Manufacturing Establishments – with a Days Away, Restricted, or Transferred (DART) rate at or above 7.0 or Days Away from Work Injury and Illness (DAFWII) rate at or above 5.0.
• Non-manufacturing Establishments – with a DART rate at or above 15.0, or a DAFWII rate at or above 14.0.

Also included are a random number of establishments that failed to timely provide rate information in response to OSHA’s 2010 data survey. OSHA has added non-responders to “discourage employers from not responding to the Data Initiative in order to avoid inspection.”

“Secondary” Inspection List

• Manufacturing Establishments – with a DART rate of 5.0 or greater but less than 7.0, or DAFWII rate of 4.0 or greater but less than 5.0.
• Non-manufacturing Establishments – with a DART rate of 5.0 or greater but less than 15.0, or a DAFWII rate of 4.0 or greater but less than 14.0.