How OSHA Picks Who to Inspect: The Site-Specific Targeting Program, Explained

Most small employers think of OSHA inspections as something that happens after a complaint, an injury report, or a referral. Those are real triggers, but they are not the only way OSHA decides where to send an inspector. The agency also runs a structured, data-driven targeting program that selects general industry establishments for inspection based on injury and illness rates pulled directly from electronically submitted 300A data. It is called Site-Specific Targeting, or SST, and it is the single largest programmed inspection initiative OSHA operates outside of construction.

If you submit a 300A through the ITA portal, you are part of the data set the program uses to build its inspection list. Understanding how that list is built — and what gets you on or off it — is one of the highest-leverage compliance moves a small employer can make.

What Site-Specific Targeting Actually Is

The SST program is OSHA's primary site-specific programmed inspection initiative for non-construction workplaces with twenty or more employees. Programmed inspections are the ones OSHA plans in advance, as opposed to unprogrammed inspections that respond to a specific event like a complaint, a referral, or a reported fatality. SST does not replace those event-driven inspections; it runs alongside them.

The program is governed by Directive CPL 02-01-067, which OSHA signed on April 8, 2025 and put into effect on May 20, 2025. The directive replaces the previous SST instruction (CPL 02-01-064 from February 2023) and remains in effect for two years from the effective date unless superseded — meaning, absent a new directive, it carries through May 2027.

Construction is excluded. Public-sector employers are excluded. Establishments that have had a comprehensive OSHA inspection within the past thirty-six months are generally excluded, as are participants in the Voluntary Protection Programs (VPP) and the Safety and Health Achievement Recognition Program (SHARP).

Everything else with twenty or more employees and a 300A on file is fair game.

The Four Ways to Land on the SST List

The current directive uses four selection criteria. An establishment can land on the inspection list through any one of them.

The first is high DART rates. OSHA pulls Calendar Year 2023 Form 300A data and identifies establishments with elevated DART rates compared to industry averages. Manufacturing and non-manufacturing are evaluated separately, and the inspection list is split roughly fifty-fifty between the two groups so that neither sector dominates the program's resources.

The second is upward-trending DART rates. OSHA looks at three consecutive years of submitted data — 2021, 2022, and 2023 — and flags establishments whose injury and illness rates have been climbing year over year. An establishment with a moderate but rising DART rate can end up on this list even if its absolute rate is below the high-rate threshold.

The third is a random sample of low-rate establishments. This is a data-quality audit. OSHA selects a portion of establishments with surprisingly low DART rates and inspects them to verify that the reported numbers match what is actually happening in the workplace. The agency wants to know whether low rates reflect genuinely safer operations or sloppy recordkeeping.

The fourth is the non-responder list. Establishments that were required to submit a CY 2023 300A under 29 CFR 1904.41 but failed to do so are added to a separate list and prioritized for inspection. Non-submission is its own enforcement trigger, independent of injury rates.

Why Manufacturing and Non-Manufacturing Are Treated Differently

Manufacturing establishments tend to have higher injury rates than the broader non-manufacturing economy. If OSHA used a single threshold, the inspection list would be dominated by manufacturers and other sectors would barely register. The current directive splits the lists explicitly so that targeting is meaningful in both categories.

NAICS classification determines which list you fall into. If your establishment is incorrectly classified — and this happens more often than employers realize, particularly in mixed-operation businesses — you may end up evaluated against the wrong threshold. Verifying your NAICS code against your actual primary business activity is one of the simplest pre-submission checks worth running.

What the Numbers Look Like

The previous version of SST, which ran under CPL 02-01-064, generated 652 inspections between April 2023 and December 2024. That program had a higher rate of violations per inspection and a lower rate of "no inspection" outcomes than other programmed inspections OSHA conducts in non-construction settings — meaning when SST sends an inspector, that inspector is significantly more likely than average to find something citable.

This is not a coincidence. The program is designed to focus enforcement resources where the data already suggests problems exist. By the time a SST inspection opens, OSHA has reason to believe the workplace will have findings.

How SST Stacks With Current OSHA Priorities

SST does not operate in a vacuum. It runs alongside other targeting initiatives, and an establishment can sit at the intersection of multiple programs.

The most relevant overlap right now is the Heat National Emphasis Program. On April 10, 2026, OSHA issued an updated version of CPL 03-00-024, replacing the prior Heat NEP that expired on April 8, 2026. The updated NEP identifies fifty-five high-hazard industries — thirty-three carried over from the previous program and twenty-two newly added — and is in effect for five years. New target industries include plastic product manufacturing, metalworking machinery manufacturing, department stores, general freight trucking, animal slaughtering and processing, and electric power generation, transmission, and distribution.

If your establishment is in one of those NAICS codes and also lands on the SST high-rate or upward-trending list, you are in two enforcement queues at the same time.

OSHA Cares, the compliance-assistance initiative announced in March 2026, does not change SST. OSHA Cares is outreach and voluntary support; SST is enforcement. They run on parallel tracks.

What Changed in the Current Directive

A few specific updates in CPL 02-01-067 are worth flagging.

The data window moved. The previous program used CY 2019–2021 data; the current program uses CY 2021–2023 data. If your injury rates have improved meaningfully since 2021, that improvement is now part of the trend OSHA is evaluating. If your rates worsened in 2022 or 2023, those are the years driving your current targeting risk.

The "record-only inspection" practice is gone. Under the prior directive, if OSHA arrived at an establishment that turned out to be wrongly listed, the inspector would still conduct a partial walkthrough of certain areas. The current directive eliminates that practice. If an establishment is genuinely off-list — for example, because it had a comprehensive inspection within the prior thirty-six months — the inspection closes without a walkthrough.

Walkthrough scope is broader. The directive instructs compliance officers to evaluate hazards across the entire workplace during an SST inspection, not just the areas where logged injuries occurred. The data on your 300 log gets the inspector through the door, but once inside, the inspection is comprehensive in scope.

Five Things to Do Before Your Next 300A Submission

The submission deadline for CY 2025 data was March 2, 2026, which has already passed. CY 2026 data will be submitted by March 2, 2027. Treat the months between now and then as your window to put yourself in the best possible position.

Reconcile your hours worked against payroll. The denominator on your DART rate calculation is total hours worked by all employees. Underreporting hours inflates your rate; overreporting deflates it. Either way, an inspector who notices a discrepancy between your 300A and your payroll system has a thread to pull on.

Verify your NAICS code. Pull up your most recent business filings and your OSHA submission record. If they disagree, figure out which is correct before next year's submission. NAICS classification determines which DART threshold you are evaluated against and whether you fall under the Heat NEP target list.

Audit your recordability decisions on borderline cases. The first aid versus medical treatment distinction, the work-relatedness exceptions in 29 CFR 1904.5, and the privacy-case rules under 1904.29(b)(7) are where most recordkeeping mistakes happen. An over-recorded incident inflates your DART rate. An under-recorded one becomes a recordkeeping citation if OSHA finds it during an inspection.

Document your abatement and your safety program. Under the July 14, 2025 update to OSHA's Field Operations Manual, the 70 percent small-employer penalty reduction now applies to employers with twenty-five or fewer employees, up from the previous ten-employee threshold. The 15 percent reduction for prompt good-faith abatement is also still in effect. Both reductions require documentation that you can produce during an inspection.

Save your ITA submission confirmations. If your establishment ends up on the non-responder list because of a system error or a missed deadline, the timestamped confirmation email from the ITA portal is your primary evidence that you complied. Print or archive these in the same folder as your annual 300A.

What to Do If OSHA Shows Up

A short primer, because SST inspections are unannounced and most small employers have never been through one.

Ask the compliance safety and health officer for credentials and the basis of the inspection — programmed (SST), complaint, referral, or follow-up. You are entitled to know which it is. Designate a management representative to accompany the inspector on the walkthrough. The employer representative has the right to attend the opening conference, the walkthrough, and the closing conference. Take your own contemporaneous notes and photographs in parallel with whatever the inspector documents. Do not impede the inspection, but do not volunteer information beyond what is asked. If you have a written safety program, your training records, your 300 logs, and your abatement documentation organized and accessible, the inspection goes faster and the findings tend to be cleaner.

A standalone inspection-preparation guide is worth its own post. The short version: the SST inspector is at your door because of data you submitted. The best preparation is making sure that data, and the records behind it, hold up to scrutiny.