Labor & Employment Developments Blog

On May 20, 2025, the Occupational Safety and Health Administration (OSHA) updated its Site-Specific Targeting (SST) inspection program. The SST inspection program is OSHA’s primary planned inspection initiative for non-construction workplaces with 20 or more employees. The updates are expected to increase on-site inspections in highly regulated sectors, such as warehousing, transportation, distribution, and healthcare. For non-construction workplaces, this update marks a significant shift in how OSHA prioritizes enforcement, relying more heavily on employer-reported injury and illness data or the lack thereof.

Under the updated SST program, OSHA will utilize Form 300A data from calendar years 2021-2023 to identify workplaces for inspection based on:

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

Employer “Days Away, Restricted, or Transferred” (“DART”) rates will be a key metric utilized by OSHA when identifying employers for inspection. The DART rate is a calculation of the severity of injuries and illnesses that affect an employee’s ability to work. Industries with DART rates significantly above the private industry average should expect to be the focus of additional OSHA inspections. 

With increased inspections, employers should also be mindful that OSHA inspections tend to go far beyond their initial scope. Although an inspector may arrive at a workplace due to high injury rates, the inspector may leave the establishment after also issuing citations for unrelated safety violations. Even if the employer-submitted data appears accurate and compliant, other areas of non-compliance may come to light during an inspection. Avoiding the inspection through accurate record keeping and diligent reporting is the first line of defense.

Key Takeaways for Employers

Employers in high risk industries should expect more frequent inspections in the future. Even if an employer has complied with all reporting requirements, OSHA may identify it for an inspection because of the employer’s DART rate. Taking proactive safety measures and hazard-specific interventions based on past data will reduce the likelihood of unwanted OSHA citations during the inspection. The KMK Labor and Employment team is ready to provide advice and counsel regarding the steps you should take to ensure compliance with workplace safety regulations.