Workplace Alert: OSHA Releases SST (Site Specific Targeting) Enforcement Directive

Date: Jun 06, 2006

As in prior years, OSHA has used site-specific OSHA 300 data to target its enforcement efforts at what new OSHA Administrator Edwin G. Foulke Jr. described as "those workplaces with the highest safety and health hazards." Sites on those lists will be subject to comprehensive safety inspections. In addition, OSHA area offices are given discretion to expand the scope of the inspection to address health issues.

There are approximately 4,000 worksites on the SST 2006 primary list. After an OSHA area office completes any remaining inspections of the sites on its 2005 SST primary list, it will turn to the sites on its 2006 SST primary list. If an area office inspects all sites of the sites on its SST 2006 primary list, it will then turn to the secondary list.

This year's program is based on OSHA 300 data from calendar year 2004 that was collected from a survey of approximately 80,000 employers (with 40 or more employees) in 2005. According to OSHA, the primary list includes:

  1. Sites with a DART Rate of 12 or more (12 or more cases with days away from work, restricted work activity or job transfer per 100 full-time workers);
  2. Sites with a DAFWII Rate of 9 or more (9 or more cases with days away from work per 100 full-time employees); and
  3. Randomly selected sites that did not respond to the 2005 data survey on the primary list.

Employers on the secondary list reported DART rates of between 7.0 and 12.0, or DAFWII rates of between 5.0 and 9.0. The national incident DART rate in 2004 for private industry was 2.5, while the national incident DAFWII rate was 1.4.

Finally, OSHA says it will randomly select and inspect about 175 workplaces (with 75 or more employees) that reported low injury and illness rates for the purpose of reviewing compliance with the injury and illness recordkeeping requirements. These establishments will be selected from with industries above the national incident DART and DAFWII rates.

Click here for a copy of the full directive.

If you have any questions about the SST or other OSHA related issues, please contact Stefanie Corbitt at corbitt@khlaw.com or 202-434-4276.

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