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The Occupational Safety and Health Administration (OSHA) has one primary programmed inspection initiative for non-construction workplaces: the Site-Specific Targeting (SST) Program. Updated in 2025 under Directive CPL 02-01-067, this program focuses enforcement resources on establishments most likely to have elevated injury and illness rates, based on employer-submitted data. If your company operates in general industry with 20 or more employees, this program applies to you.

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The SST program uses injury and illness data submitted through OSHA’s Injury Tracking Application (ITA), specifically Form 300A summaries, to identify workplaces for inspection. OSHA analyzes data from the past three calendar years—in the current cycle, that’s 2021, 2022, and 2023. The goal is simple: direct inspections where they are most needed to reduce workplace hazards and improve safety outcomes.

The program does not apply to construction, maritime, or agriculture sectors. It targets general industry establishments, including manufacturing, healthcare, warehousing, utilities, and more. Some WABA members may fall under agriculture, but most do not. NAICS codes starting with 311 (Food and Animal Food Manufacturing), 4931 (Warehousing and Storage) and 114 (Postharvest Crop Activities if performed off the farm), are considered general industry, not agriculture.

OSHA generates inspection lists based on four main criteria:

High-Rate Establishments: Companies with high Days Away, Restricted, or Transferred (DART) rates in the most recent year (2023) are prioritized.

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Upward-Trending Rates: Establishments showing a consistent increase in injury and illness rates over the three-year period (2021–2023).

Low-Rate Establishments: OSHA randomly selects some companies with unusually low rates to verify data accuracy and recordkeeping compliance.

Non-Responders: Employers who failed to submit Form 300A data for 2023 are automatically included.

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If your company is on the SST list, expect a comprehensive safety or health inspection. OSHA compliance officers will:

Conduct an opening conference to explain the scope.

Perform a walkaround of your facility, focusing on areas with documented injuries or hazards.

Review your OSHA 300 logs, 300A summaries, and 301 incident reports for the past three years.

Evaluate your safety and health management system for adequacy in addressing hazards.

OSHA does not publish the full SST inspection list, but you can look at the data OSHA collected in its data initiative found here: <a href="https://www.osha.gov/sites/default/files/ITA_300A_Summary_Data_2024_through_04-30-2025.zip" target="_blank" rel="noreferrer noopener">https://www.osha.gov/sites/default/files/ITA_300A_Summary_Data_2024_through_04-30-2025.zip</a>

Compare your data to the data of other companies by state, NAICS code, zip code and several other data points to get a sense of your rates compared to others. Take these proactive steps:

Verify Your Data Submission: Log into OSHA’s Injury Tracking Application (ITA) and confirm that your Form 300A submissions for 2021–2023 were completed accurately and on time.

Review Your DART Rates: Compare your rates against industry averages.

Check for Anomalies: Extremely low rates can also trigger an inspection for data integrity.

Monitor OSHA Communications: Area offices often notify employers before inspections begin.

Use Compliance Tools: OSHA provides resources like the SST OSHA Tools Dashboard for managing inspection lists internally.

Audit Your Recordkeeping: Ensure your posted 300A matches your logs and ITA submissions.

Address Trends: If your injury rates are rising, implement corrective actions and document them. Look at your company injury and illness reports and apply a root cause analysis. Fix the root causes. That is the purpose for keeping the records.

Prepare for Inspections: Develop your own inspection protocols. Train staff on OSHA protocols, maintain accessible records, and conduct internal safety audits.

Join Our Upcoming Webinar: OSHA Site Targeting 2026: Are You a Target?

This webinar will let you know whether one of your locations is currently a target for OSHA inspection, how to handle required injury reporting ahead of the March 2, 2026 submission deadline to reduce targeting risk; how to accurately report (and revise) injury data to avoid unnecessary scrutiny under OSHA’s Site-Specific Targeting (SST) program; and how to properly handle OSHA inspections if and when they arise.

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From April 2023 to December 2024, SST inspections resulted in higher violation rates than other programmed inspections, underscoring OSHA’s focus on high-risk sites. Accurate reporting and proactive safety measures not only reduce the likelihood of being targeted but also protect your workforce and minimize liability.

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Understanding OSHA’s Site-Specific Targeting (SST) Program and How to Check If You’re on the List

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