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Site-Specific Targeting focuses on high-injury work sites

By Sherman Williamson, OSHA Department of Enforcement -- Plant Engineering, 12/1/2005

The Site-Specific Targeting program is OSHA's main programmed inspection plan for non-construction worksites that have 40 or more employees. The SST directs enforcement resources to those worksites with the highest rate of injuries and illnesses as shown by the OSHA Data Initiative survey.

The ODI survey collects calendar year injury and illness data annually. The survey is mailed each spring to approximately 80,000 establishments, and collected from the establishments during the year. For example, the 2003 injury and illness data was collected by the 2004 Data Initiative for use in the 2005 SST program.

The first SST program was initiated in April 1999, and has been updated yearly. The SST program for 2005 consists of three inspection lists, a primary, secondary, and tertiary list. After an area office completes its primary list the secondary list is made available. If an area office completes both its primary and secondary lists, the area office may request additional sites from the National Office; these additional sites will constitute the tertiary list.

Over the last six years, the threshold rate for the primary list varied between a Lost Work Day Injury and Illness (LWDII) rate of 14.0 to 16.0, and the threshold rate for the secondary list varied between an LWDII rate of 8.0 to 10.0.

For the 2005 program the rate is 12.0 for the primary list and 7.0 for the secondary list. To put these rates in perspective, the LWDII national incident rate ranged between 2.6 and 3.3 for these years. In other words, the SST primary list historically has included worksites with injury/illness rates about five times the national incident rate, and the secondary list has included worksites with rates about three times the national rate.

The new OSHA recordkeeping rule, effective January 1, 2002, replaced the LWDII rate with the Days Away, Restricted, or Transferred (DART) rate. Beginning in 2003, the establishment's Days Away From Work Injury and Illness (DAFWII) case rate was added as a factor for selection. The DAFWII is a component, or subset, of the DART rate that involves at least one day away from work. Also, as in prior SST programs, some establishments that did not respond to the ODI survey are added to the primary list of the SST-05 program.

Compliance officers for the SST-05 program will only be required to conduct a comprehensive safety inspection. SST programs for prior years required both a comprehensive safety and a comprehensive health inspection.

Health inspections under the SST-05 program will be limited to:

  • focused inspections of nursing and personal care facilities,
  • CSHO referrals, and
  • Area Director discretion.

Since the majority of occupational illnesses captured by the ODI from which the SST is drawn are 10 to 30 years after-the-fact, many argue these measures are useless as a way of preventing such illnesses. The agency believes that health hazards are better addressed by OSHA's numerous special emphasis programs.

Historically, OSHA has tried to proactively identify and target specific processes and industries that have health hazards. This type of health hazard targeting is most effectively accomplished through its special emphasis programs, i.e., national emphasis programs (NEPs) and local emphasis programs (LEPs), such as current NEPs and LEPs covering lead and silica hazards. Other existing LEPs address such health hazards as methylene chloride, methylene diphenyl isocyanate (MDI), formaldehyde, and beryllium.

This year's program will initially cover about 4,400 individual worksites on the primary list that reported 12 or more injuries or illnesses resulting in days away from work, restricted work activity, or job transfer for every 100 full-time workers (known as the DART rate). The primary list will also include sites based on a DAFWII rate of 9 or higher (9 or more cases that involve days away from work per 100 full-time employees).

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