In May 2025, the Occupational Safety and Health Administration (OHSA) released an updated Site-Specific Targeting (SST) Inspection Program directive. The SST Inspection Program is OSHA’s main site-specific programmed inspection initiative for non-construction workplaces that have 20 or more employees. The SST Inspection Program uses employer-submitted injury and illness information (i.e., Form 300A data) to determine workplaces that will receive comprehensive (e.g., site-wide) inspections. The updated SST Inspection Program now utilizes Form 300A data for calendar years (CY) 2021, 2022, and 2023.

The main focus of the revised program is establishments with high injury and illness rates reported between 2021 and 2023, especially those with inconsistent record-keeping or injury rates exceeding twice the national private sector average. For example, sectors like trucking, warehousing, and nursing facilities tend to have higher Days Away, Restricted, or Transferred (DART) rates, which OSHA uses to assess injury severity.

This update signals a heightened focus on workplaces in sectors like warehousing, transportation, and healthcare. Employers in these industries should be prepared for increased on-site inspections. Notably, on-site inspections will not just be limited to workplaces with high rates of injuries. Workplaces with lower injury rates are also at risk of being randomly selected to verify the reliability of submitted data.

Other significant updates to the program include:

• For high-rate establishments, individual establishments will be selected for inspection based on CY 2023 Form 300A data, instead of 2021 data.
• For upward trending establishments, individual establishments will be selected for inspection based on CY 2021-2023 Form 300A data, instead of CY 2019-2021 data.
• The low-rate establishments list will be generated using CY 2023 Form 300A data, instead of CY 2021 data.
• The non-responders list will be generated using CY 2023 data, instead of CY 2021 data.

This update only reconfirms OSHA’s trend towards an increasingly data-driven approach, aiming to target workplaces with the greatest potential hazards. Employers are advised to scrutinize their injury logs and ensure accurate documentation, especially if their data indicates rising or elevated injury rates.

It is also important to keep in mind that while OSHA may begin an on-site inspection for one reason (e.g., injury rates), these inspections often result in citations for unrelated violations observed during the inspection. That being said, with anticipated workforce reductions within OSHA and other budget cuts, OSHA’s ability to maintain a robust number of on-site inspections is uncertain. Nevertheless, employers should proactively review their injury data, address hazards, and ensure compliance to avoid surprises during inspections.