How OSHA Targets Workplace Inspections and What the Latest SST Directive Means for EHS

June 24th, 2025 by Dakota Software Staff

More than 5,000 Americans are killed each year in work-related accidents, according to Bureau of Labor statistics. The Occupational Safety and Health Administration (OSHA) was created in 1971 as a regulatory agency under the Department of Labor to assure America's workers have safe and healthful working conditions free from unlawful retaliation.

To carry out this mission, OSHA sets and enforces workplace safety and health standards, provides training and resources to employers and workers, and conducts inspections to ensure employers are complying with regulations across a wide range of industries. Today, the agency oversees more than 7 million worksites nationwide.

Given the sheer scale of its oversight responsibilities, OSHA cannot inspect every workplace. Instead, it prioritizes its inspection efforts using a targeted, data-driven approach. A key component of this strategy is the Site-Specific Targeting (SST) program, which uses employer-submitted Form 300A data to identify higher-risk establishments.

How OSHA Directs Its Enforcement Efforts

Inspection targeting by OSHA is designed to maximize the Agency’s resources. By focusing on worksites with elevated or rising injury rates, and those that fail to submit required data, OSHA aims to allocate its limited resources where they can have the greatest impact.

OSHA Inspection Criteria

OSHA utilizes the following criteria to prioritize inspections:

• Imminent danger — any situation that could cause death or serious physical harm is the Agency’s top priority. When compliance officers find these hazards, they will ask employers to correct them immediately or remove endangered employees.

• Severe injuries and illnesses are second in priority. Employers are required to report:

a. All work-related fatalities within 8 hours.
b. All work-related inpatient hospitalizations, amputations, or losses of an eye within 24 hours.

• Worker Complaints — any alleged hazards or safety violations from current employees are high priority. When filing complaints, employees are allowed to do so anonymously.

• Hazards that are reported from other federal, state or local agencies, individuals, organizations or the media receive consideration for inspection.

• Follow-up inspections are conducted by the agency in certain circumstances to ensure previous violations have been corrected.

Site-Specific Targeting (SST)

The OSHA Site-Specific Targeting (SST) inspection program is the Agency’s “main site-specific programmed inspection initiative for non-construction workplaces that have 20 or more employees,” according to the OSHA CPL 02-01-067 directive. Targeted inspections are aimed at specific high-hazard industries or individual workplaces that have experienced high rates of injuries and illnesses.

What’s New in CPL 02-01-067

This directive replaces CPL 02-01-064, the previous 2023 SST enforcement directive. It will remain in effect for two years until May 2027 but does not invalidate any ongoing inspections.

Key Changes

The main differences in the updated SST directive are:

• High-rate incident inspection selections are now based on Form 300A data submitted in 2023.
• Upward-trending rates now utilize data submitted from three consecutive years (2021–2023) to determine selection criteria and trend analysis.
• Increased attention to workplaces:

- With rising injury rates

- That failed to submit Form 300A data

• Clarifies procedures for:

- Scheduling inspections
- Documenting inspections
- Prioritizing inspections
- Coding records

• Updates information for utilizing the SST OSHA Tools Dashboard to manage inspection lists.

New Inspection Criteria

This updated SST directive means establishments may be selected for inspection based upon:

• High-rate Establishments: Elevated Days Away, Restricted, or Transferred (DART) rates for CY 2023
• Upward trending Establishments: Upwardly trending injury and illness rates based on 2021-2023 data at or above twice the 2022 private sector average.
• Low-rate Establishments: Injury and illness rates that are markedly below industry averages to verify data accuracy and quality control.
• Non-responders: Failure to submit an OSHA Form 300A in 2023.

Scheduling and Inspection Procedures

The SST application is utilized by Area Offices (AOs) to randomly generate and update inspection lists. AOs are not allowed to manually create inspection cycle lists.

“SST inspections shall be comprehensive in scope,” states the OSHA CPL 02-01-067 directive. “An AO may open an inspection conducted under this program as either a comprehensive safety or health inspection, based on the AO’s knowledge of the workplace’s potential hazards. During the course of an inspection the scope may be expanded in accordance with the FOM (Field Operations Manual).”

In addition to evaluating the employer’s safety and health management system, OSHA inspectors will also review for three calendar years, to include Calendar Years (CY) 2021, 2022, and 2023, the following data:

• OSHA 300 logs
• 300A summaries
• 301 individual incident reports

“Establishments that received a comprehensive inspection within the past thirty-six months, are public-sector employers, or are participants in OSHA’s Voluntary Protection Programs (VPP) or Safety and Health Achievement Recognition Program (SHARP) are generally excluded from the inspection list,” advises Ogletree Deakins. “Small employers that are not required to submit their OSHA Form 300A electronically will not be subject to the program.”

Why This Matters to Safety Leaders

With OSHA utilizing software to analyze employer submitted data, ensuring the data submitted is accurate is more important than ever. Accurately tracking your own data is also important to discern high or rising injury rates that could trigger an OSHA SST inspection. If your establishment failed to submit a 2023 Form 300A, note that this is likely to trigger an SST inspection.

This type of trend analysis by government agencies increases risk exposure, meaning patterns matter and individual bad years are not so easily dismissed. With broader applicability, companies who are doing “okay” can now be singled out for SST inspections based on relative performance or past issues.

Savvy safety leaders understand the importance of creating an OSHA compliance strategy by utilizing Environmental, Health, and Safety (EHS) software to improve safety performance, ensure comprehensive incident reporting, identify and address issues, centralize EHS analytics, and manage compliance programs.

Steps Businesses Should Take Now

1. Be sure to submit accurate 300A forms on time.

2. Take stock of injury and illness trends over the last three years within your organization.

3. Conduct root cause analysis (RCA) to uncover underlying safety issues.

4. Prepare documentation and train teams on what to expect during an SST inspection.

5. Conduct mock inspections and internal audits to spot and correct any issues.

6. Carefully review safety initiatives within high-risk areas and update as necessary.

7. Review and refresh inspection programs regularly.

8. Utilize Environmental Health and Safety (EHS) software and consultants to build regulatory registers, track safety incidents and create proactive inspection processes.

Conclusion

OSHA’s updated SST directive (CPL 02-01-067) highlights a clear shift: the agency is increasingly relying on employer-submitted data to guide its inspection efforts. For safety leaders, this means that a passive approach is no longer an option. Accurate reporting, trend analysis, and a solid understanding of the selection criteria are essential for staying ahead of inspections and avoiding penalties. By using that same data to monitor performance, identify risks, and improve compliance, organizations can build safer and more resilient operations.

View Dakota Software's demo library to learn more about how our EHS solutions can help you create a safer, more compliant workplace.