Employment Law Blog

News, trends and analysis in employment law and HR

Feb 08, 2019

OSHA launches new inspection initiative based on 2016 data

Safety and Health 

Employers who reported high injury and illness rates in 2016, or who failed to report at all, will be targeted for inspections by the federal Occupational Safety and Health Administration (OSHA).

Site-Specific Targeting

The agency announced the directive, “Site-Specific Targeting 2016,” on October 16, 2018. States with their own safety programs, such as California, Oregon, and Washington, have six months to adopt OSHA’s plan or communicate their own inspection targeting program.

OSHA’s New Program

OSHA’s new program is based on 2016 data from Form 300A (Summary of Work-Related Injuries and Illnesses) that covered employers were required to electronically submit to OSHA in 2017.

Here’s what’s changed:

  • OSHA will create inspection lists for establishments with a high Days Away, Restricted, or Transferred (DART) rate compared to others in their industry.
  • OSHA will also randomly select covered establishments that failed to electronically submit the Form 300A.
  • To verify reliability of the data, OSHA will generate a random sample of establishments that reported low DART rates.

OSHA’s Inspections

The inspections will be comprehensive in scope and will include a review of recordkeeping compliance. OSHA will cancel inspections for establishments that are purely offices; for establishments that are approved for the Safety and Health Achievement Recognition Program (SHARP) or Voluntary Protection Program (VPP); and for establishments where OSHA began conducting a comprehensive safety or health inspection of that location within the past three years.

Tips for Employers

Required to Submit Form 300A?

Wondering whether you’re a covered employer that must electronically submit your Form 300A? Each establishment (physical location) must electronically submit the summary if (1) it has 250 or more employees regardless of industry; or (2) it has at least 20 employees and is in a designated high-risk industry (including agriculture, manufacturing, warehousing, and residential care facilities). On April 30, 2018, OSHA announced that it expects all covered employers, even in states with their own safety and health agencies, to electronically submit their data to OSHA. The deadline for submitting the 2018 Form 300A to OSHA will be March 2, 2019. (The deadline in previous years was July 1, but is accelerated to March 2 beginning in 2019.)

Vigilant Safety Services

If you’re interested in improving your workplace safety and OSHA compliance, work with a Vigilant dedicated safety professional today.  Not a member? Learn more about Vigilant membership. For a flat monthly fee, members receive unlimited access to a dedicated employment attorney and safety professional, in addition to access to a host of employer-specific resources, including legal guides.

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