The Occupational Safety and Health Administration has overhauled its Site-Specific Targeting (SST) inspection program, marking a major shift in how the agency identifies and prioritizes workplaces for inspection.
Effective May 20, 2025, the new guidance applies to non-construction employers with 20 or more employees and significantly increases OSHA’s reliance on employer-reported injury and illness data submitted every year on Form 300A.
For business owners, especially those in high-risk industries like warehousing, transportation, distribution and health care, this shift brings the potential for more frequent and comprehensive inspections, even if their workplaces appear to be in compliance on the surface.
A deeper dive into OSHA’s new approach
Under the updated SST plan, OSHA will use Form 300A data from calendar years 2021 through 2023 to generate inspection lists. Employers may be selected for inspection based on:
- High DART (days away, restricted or transferred) rates in 2023
- Upward-trending DART rates over the three-year period
- Unusually low DART rates compared with industry averages (to verify data accuracy)
- Failure to submit Form 300A
The DART rate, which reflects the number and severity of injuries or illnesses affecting an employee’s ability to work, will play a central role in OSHA’s targeting decisions. Even employers who have submitted their data correctly and on time may find themselves flagged for inspection if their DART rates stand out, either for being too high or suspiciously low.
Compliance officers are instructed to assess hazards across the entire workplace, not just to focus on areas where injuries have occurred. This means that while an inspection may be triggered by injury rates in one part of your operation, inspectors are free to examine other areas and issue citations for unrelated violations they encounter.
What’s changed — and what hasn’t
The new guidance eliminates the previous requirement that OSHA conduct a partial inspection even if an establishment was mistakenly included on the inspection list.
At the same time, inspectors are now encouraged to conduct thorough walkthroughs of workplaces, potentially over multiple shifts, to evaluate exposure risks and overall safety conditions.
What hasn’t changed is the program’s reach: the SST still excludes construction, agriculture and maritime sectors but applies to all other industries. OSHA also continues to divide establishments into manufacturing and non-manufacturing categories, applying different thresholds for DART rate comparisons.
What employers should do now
Business owners should treat these changes as a call to action. Being proactive is key to avoiding costly inspections and penalties.
Here are some practical steps employers can take:
- Audit your OSHA 300 and 300A records: Ensure that only recordable incidents are reported. Avoid over-reporting non-recordable events that can inflate your DART rate and draw OSHA’s attention.
- Prepare for inspections: Designate a trained point person who will handle OSHA visits and make sure that any inspection stays within its legal scope.
- Know your rights: You are not obligated to allow an inspector on site without a warrant. Employers may ask OSHA to verify whether they are on the SST list before proceeding.
- Limit the first-day disclosure: Do not voluntarily turn over documents beyond your OSHA 300 logs, 300A summaries, 301 forms and relevant Safety Data Sheets on the first day of inspection.
- Stay inspection-ready: Conduct internal walkthroughs using the same criteria OSHA uses — especially focusing on high-hazard areas, employee exposures and recent injuries.
- Train employees: Educate your team, particularly non-supervisory staff, on what to expect during an OSHA visit and how to respond appropriately to inspector questions.