OSHA Creates Targeting Program Based on 300A Submissions

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The Occupational Safety and Health Administration is implementing a site-specific targeting program based on injury and illness data from electronically-submitted Forms 300A for CY 2016, which certain employers were to have submitted by December 15, 2017.

Form 300A is required for employers with 250 or more employees that are currently required to keep OSHA injury and illness records, as well as employers with 20-249 employees in certain industries with historically high rates of injury or illness. The program targets for inspection: (1) those employers with a high rate of injury, as reported on the Form 300A; (2) employers who failed to submit Form 300A, in order to discourage non-reporting; and (3) a random sample of low-rate employers, for purposes of quality control. Those states with OSHA-approved State Plans are required to have their own inspection targeting programs.

OSHA’s October 17, 2018 press release on the program also notes that it offers an On-Site Consultation Program for employers with up to 250 workers, which provides “free, confidential safety and health advice on complying with OSHA standards, and establishing and improving safety and health programs.” If an employer is participating in this consultation program, the consultation either will take priority over or result in a deferral of a targeted inspection.