email | site map

SAFETY TIPS

HAS YOUR COMPANY BEEN TARGETED?

Earlier this year, the newest Site-Specific Targeting list was issued by OSHA (Occupational Safety and Health Administration).  For all federal OSHA states, which includes Ohio, the list contains approximately 14,000 companies who have experienced an incident rate higher than the national average for their industry. The list is available to the public courtesy of the Freedom of Information Act. For the most current SST go to OSHA's Web site at http://www.osha.gov and click on D in the alphabet at the top of the page, then Directives, then Information Date, and finally 2007, and scroll down to May and the current SST.
 
This information is based on data collected in 2006 for FY2005.  Some local employers have probably received a letter recently informing them that their establishment has been identified as having a DART (Days Away from work, Restricted, or job Transfer) rate higher than most other businesses in this country.  What does all this mean?

While some companies have found themselves on this list due to their high incident/accident rates, some have mistakenly been placed on the list because they submitted incorrect information.  Accurate recordkeeping practices may help you to avoid an inspection based on the SST list.  Sometimes personnel will over-record incidents or accidents, which will raise your DART rate.

Of the approximately 40,000 inspections OSHA conducts in a year, about 4,150 are Site-Specific Targeting (SST) inspections. The remaining inspections are imminent danger, fatality, catastrophe, complaint, referral, follow-up, and other programmed inspections. The other programmed inspections are mainly Emphasis Program inspections, which focus on a particular safety or health hazard (e.g., amputation, silica), or the hazards of a specific industry (e.g., logging, nursing homes). 

Each year, OSHA sends its data survey form (the "OSHA Work-Related Injury and Illness Data Collection Form") to approximately 80,000 non-construction establishments, requesting from each employer (1) the average number of employees who worked for the employer during the prior calendar year, (2) the total hours the employees worked during the prior year, and (3) the summary injury and illness data from the employer's OSHA Log form.

The SST inspection plans are based on the self-reported injury and illness information submitted by employers in OSHA's Data Initiative.  From the data submitted, OSHA compiles two inspection targeting lists, a primary and a secondary list of non-construction worksites. The primary list initially will cover worksites that reported 11 or more injuries or illnesses as their DART rate.  It will also include establishments based on a Days Away from Work Injury and Illness (DAFWII) rate at or above 9.0.

Each Federal OSHA Area Office receives a list of establishments for their primary targeting list, and is expected to complete inspections of these establishments in about a year.   Northwest Ohio is in OSHA’s Region 5, with 650 targeted inspections scheduled for this year.

After an area office completes its primary list, the secondary list is used. The secondary list includes establishments that reported a DART rate between 7.0 and 11.0, or DAFWII rates of between 4.0 and 9.0.

The DART rate is calculated based on (N / EH) x (200,000) where N is the number of cases involving days away, and/or restricted work activity, and/or job transfer; EH is the total number of hours worked by all employees during the calendar year; and 200,000 is the base number of hours worked for 100 full-time equivalent employees. For example: Employees of an establishment including management, temporary, and leased workers worked 645,089 hours at this worksite. There were 22 injury and illness cases involving days away and/or restricted work activity and/or job transfer from the OSHA 300 Log (total of column H plus column I). The DART rate would be (22 / 645,089) x (200,000) = 6.82.

The national DART rate in 2005 for private industry was 2.4, while the national incident DAFWII rate was 1.4. The 14,000 establishments chosen based on this recent survey had a DART rate of 5.3 or more.

Establishments selected for a site-specific inspection receive a comprehensive safety inspection and will possibly receive a comprehensive health inspection if the Area Director deems it necessary or if the establishment is a nursing home or personal care facility. Occasionally, if an employer has been greatly improving its safety and health performance, an SST inspection may be a "records only" inspection. That is, if the employer's DART rate, as calculated by the OSHA compliance officer during the inspection, shows the establishment to have a low DART rate for at least two out of three years, then the compliance officer may confine the inspection to a review of the employer's safety and health records.  If the DART rate is above 4.8 for any two years, then the comprehensive inspection will be conducted.  If the DART rate is below 4.8, but the DAFWII is above 2.8, the inspection will also be done.  If the DART rate is below 4.8 and the DAWFII rate is below 2.8 for the same two years, then it will be a “records only” inspection.

The intention of the SST and the Data Initiative is to help OSHA make more effective use of its enforcement resources. In order to achieve OSHA's goal of reducing the number of injuries and illness that occur at individual worksites/establishments, the SST directs enforcement resources to those worksites where the highest rate of injuries and illnesses have occurred.

Ensure that your recordkeeping practices are complete and accurate.  If you have received a notification letter and have not already done so, audit your recordkeeping to determine what are the root causes of your incidents/accidents.  Don’t wait until you have an inspector at your door to start protecting your employees and resources.  Safety and health add value to business, to the workplace, and to life.

 

Excerpts taken from: http://www.osha.gov  (Sec. 8(a) and 8(b), Pub. L. 91-596, 84 Stat. 1599 (29 U.S.C. 657) 4/27/04); OSHA Trade News Release 5/18/07; OSHA Directive #70-73 (CPL 02)

Submitted by Sharon Roman, Regulatory Compliance Consultants, Inc.
For more information or questions concerning this article, contact our office at 419-882-9224.

 

Call 911

 

Previous Tips