OSHA Kicks Off 2011 Inspection Program
September 19, 2011
On September 9, 2011, OSHA announced that it has begun its 2011 Site-Specific Targeting (“SST”) Program, a targeted enforcement effort under which it will conduct comprehensive inspections of worksites across the country. OSHA will select worksites for inspection based on injury and illness data for 2009 collected by OSHA in 2010.
In April 2011, OSHA selected about 14,600 worksites that may receive SST inspections based upon their injury rates, and sent each of these worksites a letter informing them of a possible future inspection. From that initial list, OSHA designated approximately 3,700 worksites as “primary” inspection targets, and directed OSHA Area Offices to inspect those sites first. Although the list of approximately 3,700 worksites has not been published by OSHA, it is possible for an employer to determine whether it is on the list by following these steps:
1. Calculate your DART and DAFWII rates.
Days Away, Restricted, or Transferred (DART) rate:
The DART rate accounts for injury and illness cases involving days away from work, restricted work activity, or transfers to another position (the total of columns H and I on the OSHA-300 log).
DART rate = 200,000 * (# of DART injuries) / (Total # of hours worked by all employees for calendar year).
Days Away From Work Injury and Illness (DAFWII) rate:
The DAFWII rate accounts for injury and illness cases involving only days away from work (column H on the OSHA-300 log).
DAFWII rate = 200,000 * (# of DAFWII injuries) / (Total # of hours worked by all employees for calendar year).
2. Compare your DART rate AND your DAFWII rates to the criteria below to determine if your site is a primary inspection site.
Manufacturing establishments with a DART rate greater than or equal to 7.0, or a DAFWII rate greater than or equal to 5.0, are primary inspection sites. There are approximately 3,000 manufacturing primary inspection sites.
Non-manufacturing establishments (except for Nursing and Personal Care Facilities) with a DART rate greater than or equal to 15.0, or a DAFWII rate greater than or equal to 14.0, are primary inspection sites. There are approximately 400 non-manufacturing primary inspection sites.
Nursing and personal care facilities with a DART rate greater than or equal to 16.0, or a DAFWII case rate greater than or equal to 13.0, are primary inspection sites. There are approximately 300 nursing and personal care facility primary inspection sites.
Even if your site is not one of the 3,700 primary inspection sites, you may still be selected for an SST inspection if your facility is on the list of 14,600. Once all primary inspection sites in an area have been inspected, OSHA will inspect secondary inspection sites as follows:
Manufacturing establishments with a DART rate of 5.0 or more but less than 7.0, or a DAFWII case rate of 4.0 or more but less than 5.0, are secondary inspection sites.
Non-manufacturing establishments with a DART rate of 5.0 or more but less than 15.0, or a DAFWII case rate of 4.0 or more but less than 14.0, are secondary inspection sites. (Note that this is more inclusive than last year’s list, which would inspect facilities with DART rates of 7-15, and DAFWII rates of 5-14).
Nursing and personal care establishments with a DART rate of 13.0 or more but less than 16.0, or a DAFWII case rate of 11.0 or more but less than 13.0, are secondary inspection sites.
