In the good old days, OSHA inspections occurred as the result of one of three events: employee complaints, accidents or random inspection (with a statistical probability of once every 200 years). However, this system was not yielding the results OSHA desired -- namely, an overall reduction in accidents and injuries. As a result, several years ago, OSHA developed a new approach to achieve its goals: target and inspect the countrys most dangerous employers.
This OSHA initiative is referred to as the Site-Specific Targeting (SST) inspection program. While the approach seems to make sense, it can penalize employers that over-report, or small employers that might experience several serious injuries in a calendar year.
OSHA uses common statistical safety benchmarks to identify the employers it deems most dangerous. It draws on the Data Initiative, a nationwide collection of specific injury and illness data from approximately 80,000 employers, that collects data using the OSHA Work-Related Injury and Illness Data Collection Form. This form is required by law to be completed, and the penalty for not completing it is automatic inclusion on the list of employers targeted for inspection. Information is obtained from the OSHA 300 log of injuries and illnesses, and the current SST initiative is based on data reported for calendar year 2003.
Unfortunately, many employers have assigned the task of completing the OSHA 300 logs to clerical personnel who might not be familiar with OSHA record-keeping criteria. Many of these employers tend to over-report by placing all occurrences on the log. If these same clerical personnel transpose the OSHA 300 form information onto OSHAs survey form, they are also overstating the actual incident rates in which OSHA is most interested. The OSHA 300 form should be prepared as you would your personal or business tax return: carefully and correctly.
Since the inception of this initiative, OSHA has been targeting based on the Days Away, Restricted or Transferred (DART rate): injuries that have resulted in days away from work, restrictions from normal job duties, or both. The DART rate for the current SST initiative is 6.5 per 100 employees. Of more than 80,000 employers surveyed, approximately 14,000 reported DART rates exceeding 6.5. The average DART rate for all employers nationwide is 2.5.
OSHA sent a form letter to employers on the list explaining the SST program and why each was being placed on this list. However, many employers I have spoken with werent aware theyre on the list because the form letter never reached the proper safety personnel within their organization.
The list is public information. You can download it from the OSHA Web site at www.osha.gov/as/opa/foia/hot_11.html.
In view of OSHAs new Site Specific Targeting Inspection Initiative, employers should:
- Inform company management about this OSHA initiative.
- Ensure OSHA survey forms are being completed correctly.
- Know and understand what is being recorded on your OSHA 300 logs.
- Carefully monitor you companys injury rates, particularly the DART rate.
- Determine if your company has been targeted for inspection.
- Prepare for an inspection if your company is on the list.
OSHAs new approach of targeting certain employers represents a significant and important departure from the way it has previously conducted business. In the past, OSHA would randomly inspect employers, many of which had exemplary safety programs, and find various minor and technical violations, as it would at any employer. OSHA was roundly criticized for penalizing good employers and not expending its resources on more dangerous employers that were not being inspected simply through random chance.
Under the SST initiative, employers on the list are expected to have hazards that are not being adequately identified or controlled. Inspections of such employers will inherently result in more violations than inspections of an employer not on the list.
Companies on the list should understand why. If over-reporting on the OSHA log and survey form, the fix is simple. If accidents and injuries are higher than average for you or your peer group, opportunities exist to improve. You can find statistics to benchmark your safety performance against the average for your industry peer group at www.bls.gov/iif/oshwc/osh/os/ostb1355.pdf.
All employers would be well advised to conduct periodic but thorough safety, health and compliance audits of their facilities and operations to identify opportunities for improvement. A more expensive approach is to let OSHA point out deficiencies for you!
Gary Glader, CSP, is president of Network Safety Consultants, Orland Park, Ill. E-mail him at [email protected].