OSHA's 2014 SST Inspection Program Enters Final Months

The 2014 Site-Specific Targeting program ends in March of 2015, so right now OSHA Area Offices are working to finish all of the inspections on lists that were created early in the year, to satisfy quotas before the next SST program directive is issued.

If an OSHA inspection leaves management at your organization with the sense that it is being targeted, well . . . they may be right. In fact, OSHA's Site-Specific Targeting (SST) program is structured to guarantee that Compliance Safety & Health Officers show up at high-risk industrial sites all over the country. If your company happens to receive an SST inspection, it's because your business has made it onto an OSHA list of organizations falling into certain industrial risk classifications.

Yet characterizing an OSHA inspection as "unfair" is probably going too far—there's a reason for every type of inspection and policies in place to ensure that inspections are randomized, neutral.

Through the Site-Specific Targeting program, OSHA is actively inspecting operations involved in high-risk work, but the agency isn't singling out any certain business. There is a method to the madness, and understanding how the Site-Specific Targeting program works can help you prepare for an eventual inspection, estimate the probability of inspection, and proactively respond to SST inspection triggers. Remember, the 2014 Site-Specific Targeting program ends in March of 2015, so right now OSHA Area Offices are working to finish all of the inspections on lists that were created early in the year, to satisfy quotas before the next SST program directive is issued. If your high-risk industrial operation has yet to be inspected this year and your safety statistics are not exactly where you want them to be, then you really need to understand the SST program and educate management on the matter.

Who Makes It Onto SST Inspection Lists?
In the spectrum of OSHA inspections, Site-Specific Targeting is unique in that there is a detailed, objective methodology behind the "neutral" scheduling of inspections under this category. The Site-Specific Targeting program is guided by data gathered through the OSHA Data Initiative (ODI). Each year, the ODI collects injury and illness data from approximately 80,000 employers within specific industry and employment size specifications. ODI data is used by OSHA to calculate the injury and illness rates of your organization.

The ODI survey helps OSHA achieve its goal of reducing the number of injuries and illnesses that occur at individual workplaces by directing enforcement resources to those workplaces having the highest rates. OSHA considers a "high hazard" industry to be one within a Standard Industrial Classification code with a national lost workday injury and illness rate among the highest 200 as published for calendar year 1992 by the Bureau of Labor Statistics (BLS) at the 4-digit SIC level.

OSHA Area Offices generate three types of lists: primary, secondary, and tertiary. These lists use SIC/NAICS codes to categorize organizations according to the risk of occupational health for participating workers. If your industry is known for high Days Away, Restricted, and Transfer (DART) rates and/or high Days Away From Work (DAFWII) rates, there is a strong possibility that your operation is on one of the three lists. Appearance on these lists great increases the probability of inspections, which, while scheduled at random, draw from a small pool of companies in high-risk industries.

But that doesn't mean your company will be inspected, only that the probability of an inspection is high; again, SST program inspections are randomly ordered. However, all companies under direct federal jurisdiction that are listed on a primary inspection list will be inspected under the 2014 SST program.

OSHA's Scheduling System Software
You probably didn't know that the Site-Specific Targeting Program has its own website, but it does—OSHA Area Offices can access the resource to automate SST inspection scheduling by generating lists that correspond with and localize ODI information. The software and databases for the primary and secondary lists are available through the Site-Specific Targeting program website, which is not accessible to the general public; only OSHA's National Office, Regional Offices, Area Offices, and State Plan authorities, are able to access the website. The database contains the information for all organizations on the primary, secondary, and tertiary inspection lists for each region.

If the Area Office in your state were to commence with execution of SST inspections pursuant to regional goals, personnel would simply log in to the SST website to access and generate the inspection lists—they click a "Create" button. The lists are randomized by the software, but the data is weighted to ensure that organizations in the highest risk category—based on DART & DAWII rates—do not escape the SST inspection cycle.

SST Inspection Cycles
The inspection lists generated by each Area Office through the SST software constitute an "inspection cycle"—if there are 50 organizations on the SST inspection list, then that's what the cycle is. Area Offices base the determination of cycle size (i.e., 5 to 50 establishments) on consideration of available resources and geographic range of the office. Not all companies available in the database are placed on SST inspection lists.

Within a cycle, establishments may be scheduled and inspected in any order that makes efficient use of available resources—it's up to OSHA Area Offices to carry out the randomly generated cycles according to capability. The number of inspections actually performed depends on factors such as staffing, unprogrammed inspection activity, and special emphasis programs. If all businesses in an inspection cycle are inspected before the end of the fiscal year, OSHA field offices may generate another cycle by extending the inspection register, using the internal SST software. However, all of the organizations in a cycle must be inspected (that is, the inspection must be initiated) before any company in a new cycle may be inspected.

The Site-Specific Targeting program is not OSHA’s top enforcement priority, but it also isn't an afterthought. SST inspections are carried by out by Area Offices throughout the year, and these inspections happen when CSHOs are not busy responding to unprogrammed inspection demands, such as fatality investigations, serious accidents, and safety complaints. SST inspections target, statistically, the most hazardous work environments in the country. Not only are these types of inspections thorough, but often they include the participation of occupational health-focused inspectors along with general safety inspectors.

The SST program is designed to keep safety professionals with organizations in high-risk industries on their toes. That's why understanding how the SST program works is crucial to organizational preparedness. On a basic level, as evidenced by the SST program, OSHA wants to encourage organizations to improve DART and DAWII rates. Knowledge of the program can be used by safety professionals to make the case to management for greater investment in supporting compliance, improving the safety culture, or engineering controls. Also, the SST program is a great reason for launching new safety initiatives, because regardless of where an organization lands on any of the three SST inspection lists, the probability of inspection is high.

Be sure to keep an eye out for the 2015 Site-Specific Targeting program directive, sometime after the expiration of the 2014 program, on or after March 6, 2015. The program changes annually.

Barrett Pryce is a content strategist with Vivid Learning Systems, an online safety training provider making life a little easier for safety professionals.

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