Effective October 16, 2018, OSHA has launched a Site-Specific Targeting (SST) program for health and safety inspections. The program is called SST-16
for short, because the Agency used employer-submitted injury and illness data from 2016 to construct its list of targeted sites.
OSHA’s main site-specific targeting inspection plan
for non-construction workplaces with more than twenty employees, SST-16, will target workplaces in the following groups:
- High-Rate Establishments. Individual establishments selected for inspection due to a high rate of DART (Days Away, Restricted, or Transferred) incidents.
- Low-Rate Establishments. To ensure the data OSHA collects is reliable, a random sample of sites with a low DART rate will also be targeted for inspection.
- Non-Responders. Employers who failed to electronically submit 2016 injury and illness data from 300A will also be targeted, in order to discourage employers from not reporting to avoid inspection. Covered employers had until December 15, 2017 to submit this data through OSHA’s Injury Tracking Application (ITA).
What OSHA Inspectors Are Looking For
In Section XIII of its SST-16 Enforcement Directive
, OSHA plainly states that inspections conducted under this targeting program will be comprehensive in scope
. At sites that have been inspection previously, the inspection may be expanded to cover both health and safety hazards.
While conducting inspections, OSHA inspectors will review injury and illness logs (Form 300) for years 2016, 2017, and 2018 to present.
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Penalties for Failure to Submit 300A Data
If OSHA issues a citation for failure to report 2016 injury and illness data from Form 300A, the penalties will follow an enforcement memo issued in early 2018:
“If the employer was required to submit the data and did not attempt to do so, the Area Director shall issue a citation using the following guidance:
- If the employer failed to submit, but immediately abates during the inspection by providing a paper copy of the records, an “Other Than Serious” citation will be issued with no penalty.
- If the employer failed to submit its CY2016 data, but shows it has already submitted its CY2017 data, an “Other Than Serious” citation will be issued with no penalty.
- If the employer does not produce the records, an “Other Than Serious” citation will be issued with the appropriate penalty.”
In other words, if you forgot to submit data from Form 300A last year, make sure you submit it electronically ASAP or have paper copies ready to go when an OSHA inspector shows up.
See OSHA's Top Ten most cited safety standards for FY 2018 here.
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