OSHA Issues Site-Specific Inspections Targeting Directive for 2014

By James L. Curtis, Meagan Newman, and Craig B. Simonsen

OSHA has just released its Site-Specific Targeting 2014 (SST-14) Program (Program) Directive, which replaces its Site-Specific Targeting 2012 that we previously blogged about, and was in effect during 2013. Directive No. 14-01 (CPL 02).

The OSHA SST-14 Program is intended to direct its enforcement resources to workplaces where the “highest rates of injuries and illnesses occur.” The Directive calls for programmed inspection plans targeting high-hazard, non-construction workplaces that have 20 or more workers. The Program is based on data collected from the last year’s OSHA Data Initiative survey of 80,000 establishments in high-hazard industries. In the Directive appendix A, OSHA lists the many industries that were surveyed, and so targeted, including: manufacturing, trucking, warehousing, air transportation and courier services, automobiles, construction materials, scarp and waste, groceries, poultry products, department stores, medical facilities.

OSHA’s intention is that implementation of the Directive will achieve its goal of reducing the number of injuries and illnesses that occur at individual workplaces by directing enforcement resources to those workplaces where the highest rate of injuries and illnesses have occurred.

Among other things, the Directive provides a checklist for compliance safety and health officers and provides scheduling and inspection procedures. According to the Directive, the Program’s primary inspection lists for federal jurisdiction Area Offices will be comprised of 1,260 establishments.

We previously noted that the Consolidated Appropriations Act had increased OSHA’s funding above the 2013 sequestered spending limits to $552.2 million. While several compliance assistance programs were being cut, OSHA’s enforcement activities received $207.8 million — the full amount asked for by the White House. Accordingly, employers should continue to expect a high OSHA emphasis on enforcement inspections in 2014.