OSHA Updates Inspection Program to Focus on Workplaces With Highest Injury and Illness Rates

On May 20, 2025, OSHA announced its updated Site-Specific Targeting (SST) inspection program, which directs agency enforcement resources to inspect establishments with the highest rates of injuries and illnesses. The SST inspection program uses objective data from injury and illness information that employers submit under OSHA’s recordkeeping requirements.

The changes went into effect on May 20, 2025, and the new directive replaces the previous SST inspection program directive issued on Feb. 7, 2023. This directive terminates May 20, 2027, unless a new instruction replaces it.

Background

The SST inspection program is OSHA’s primary planned inspection program for non-construction establishments with 20 or more employees. It uses employer-submitted Form 300A data for calendar years 2021, 2022 and 2023.

By applying industry and establishment-size criteria, OSHA focuses data collection on establishments most likely to be experiencing elevated rates and increased numbers of occupational injuries and illnesses.

Key Information

Using OSHA Form 300A data from calendar years 2021-23, establishments may be selected for inspection based on:

• High injury and illness rates from 2023 data;
• Upwardly trending injury and illness rates based on 2021-23 data at or above twice the 2022 private sector average;
• Injury and illness rates that are markedly below industry averages; and
• Failure to submit an OSHA Form 300A in 2023.

Employer Next Steps

Employers should review all their workplace safety programs, policies and practices and ensure they provide a safe work environment for their employees that complies with OSHA standards. Employers can utilize OSHA’s On-Site Consultation Program, which provides free, confidential occupational safety and health services to help small and medium-sized businesses identify workplace hazards, comply with OSHA standards, and establish and improve safety and health programs. OSHA’s on-site consultation services are separate from enforcement and do not result in penalties or citations.  

Important Dates

• OSHA’s updated SST inspection program went into effect on May 20, 2025.
• The STT inspection program will be effective until May 20, 2027, unless a new instruction replaces it.

The SST inspection program helps OSHA achieve the goal of ensuring that employers provide safe and healthful workplaces by directing enforcement resources to those workplaces with the highest rates of injuries and illnesses.

This Legal Update is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.© 2025 Zywave, Inc. All rights reserved.