OSHA Updates Site-Specific Targeting Program Based on Injury/Illness Rates: What Employers Should Know
On May 20, 2025, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) announced an updated directive to its Site-Specific Targeting (SST) inspection program. This program is OSHA’s primary mechanism for scheduling planned inspections at non-construction establishments with 20 or more employees.
Moving forward, OSHA will focus on workplaces with the highest injury and illness rates and those with upward trends or suspiciously low rates. The move highlights the ways in which OSHA plans to use injury and illness data that certain employers are required to submit online under 29 C.F.R. § 1904.41. With OSHA’s announcement, employers should reexamine their EHS programs to ensure that proper guardrails for accurate and thoughtful decisions on OSHA recordkeeping are in place.
Key Features of the Updated Program
OSHA will now use injury and illness data from calendar years 2021 through 2023—specifically Form 300A submissions—to determine inspection targets. Form 300A is the annual summary of work-related injuries and illnesses that employers are required to compile and post each year (i.e., from the employer’s more detailed log). Under the revised criteria, establishments may be selected for inspection based on:
- High injury and illness rates in 2023.
- Upward trends in injury and illness rates across the 2021-2023 period, particularly where those rates exceed twice the 2022 private sector average.
- Unusually low injury and illness rates, which may trigger inspections to verify underreporting or recordkeeping violations.
- Failure to submit OSHA Form 300A data for 2023.
The new directive replaces the previous one issued on February 7, 2023.
Implications for Employers
OSHA’s revised SST program increases the likelihood of onsite inspections for employers who meet any of the updated selection criteria, particularly those in higher-risk industries or with inconsistent recordkeeping practices. Importantly, even employers with comparatively low injury and illness rates may be flagged for inspection if OSHA suspects inaccurate reporting.
Employers should take proactive steps now to ensure that:
- OSHA Form 300A logs have been properly submitted and accurately reflect injury and illness data;
- All incidents have been appropriately recorded—with an eye towards thornier recordkeeping judgment calls such as those on “work-relatedness”;
- Internal safety and health programs are updated and actively monitored for compliance gaps.
Sidley is prepared to assist employers that are inspected by OSHA under the SST program or who are unsure whether past submissions or current workplace metrics might trigger scrutiny.
This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.
