This fall, OSHA issued its Site-Specific Targeting Directive for FY 2011 based on work injury and illness data from 2010. The 2011 SST Directive includes some key changes that put more companies in the cross hairs for targeted OSHA inspection. Here are the key points of the 2011 Directive you need to know about.
How SST Works
Worksites outnumber OSHA inspectors by a ratio of over 150 to 1. Since inspectors can’t visit every site, OSHA targets facilities that present the highest safety risks. The SST program is the centerpiece of this strategy.
Under SST, OSHA surveys nearly 80,000 workplaces each year and selects about 14,000 “high hazard facilities based on their Days Away, Restricted, or Transferred (DART) rate and Days Away From Work Injury and Illness (DAFWII) rates.
“High hazard” establishments are grouped into a primary, secondary and tertiary lists based on their DART and/or DAFWII rates and type of industry. (SST covers companies not in the construction sector.) Those facilities are then candidates for comprehensive inspection, including OSHA 300 logs, for at least 3 of the previous 4 years, unless they make safety improvements (or OSHA doesn’t get to them on the list.)
The 2011 SST Directive
The biggest change in the 2011 Directive: A worksite with as few as 20 employees can be listed as a high hazard establishment. Before, an establishment had to have at least 40 employees to be considered a “high hazard.” Result: Smaller companies will now be in OSHA’s cross hairs for SST.
Here are the trigger DART/DAFWII rates for 2011:
|PRIMARY INSPECTION LIST|
|Manufacturing||At or above 7.0||At or above 5.0|
|Non-manufacturing||At or above 15.0||At or above 14.0|
|SECONDARY INSPECTION LIST|
|Manufacturing||5.0 to 6.9999||4.0 to 4.9999|
|Non-manufacturing||5.0 to 14.9999||4.0 to 13.9999|
Other OSHA Inspection Hit-Lists
Keep in mind that SST is just one of the many OSHA inspection targeting programs. Federal OSHA also has 13 national Emphasis Programs targeting specific hazards or operations, including:
PROCESS SAFETY MANAGEMENT
TRENCHING & EXCAVATION
The states also have approximately 140 Regional Local Emphasis programs of their own.[fbcomments]