Targeted for an OSHA inspection this year?

In a September 9, 2011 directive, Federal OSHA details their Site-Specific Targeting 2011 Inspection Plan. In short, if you fit the profile outlined in the 46-page directive, you should expect a comprehensive inspection this year. The program does not include construction worksites, and the eligibility threshold is changed from 40 employees to 20.

For targeting, OSHA used 2009 injury and illness data collected via survey of approximately 100,000 establishments in “historically high-rate industries.” Exceeding either of two thresholds puts you on the list. The first is your DART rate, calculated based on injuries or illnesses resulting in days away from work, restricted work activity and/or transfers to another job.

The second is your DAFWII rate, also calculated based on the number of cases that involve days away from work per 100 full-time equivalent employees, except that cases involving only temporary transfers to another job or restricted work are not included.

To screen for target facilities, different DART and DAFWII rates were created for manufacturing, non-manufacturing and nursing and personal care facilities and compared to the 2009 national DART rate (1.8) and DAFWII case rate (1.1) for private industry. The results and the respective criteria:

  • Approximately 3,000 manufacturing establishments with a DART rate at or above 7.0 or a DAFWII case rate at or above 5.0;
  • Approximately 400 non-manufacturing establishments (except for Nursing and Personal Care Facilities) with a DART rate at or above 15.0 or a DAFWII case rate at or above 14.0; and
  • Approximately 300 Nursing and Personal Care Facilities (SIC code 805) with a DART rate at or above 16.0 or a DAFWII case rate at or above 13.0. This group of inspections will focus specifically on ergonomics, exposure to blood and other potentially infectious materials, exposure to tuberculosis and slips, trips and falls. However, when additional hazards come to the attention of the compliance officer, the scope of the inspection may be expanded to include those hazards.

A random sample of survey non-responders was also added to the inspection list “to discourage employers from not responding to the Data Initiative in order to avoid inspection.”

If you are targeted but are currently participating in an OSHA on-site consultation, Strategic Partnership, VPP or Pre-SHARP program, there are deletion or deferral provisions depending on the program. State programs must notify Fed-OSHA as to whether they intend to adopt the identical program or propose their own version.

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