OSHA SST Program

OSHA announced on December 16, 2020, that they’ve updated their Site-Specific Targeting (SST) Program for 2021.  For those who may not be familiar with this program, it’s been in place for several years (minus a 4-year hiatus from 2014 to 2018 to evaluate the program’s effectiveness) and is designed to focus enforcement resources toward companies (non-Construction establishments with 20+ employees) that have incurred higher than average injury-illness rates.

One key issue with this program has been the criteria for which companies are targeted.  Site-Specific Targeting uses “employer-submitted” injury and illness data.  A potential problem exists when companies under-report data on their OSHA logs and Summary.

Reasons for under-reporting could be ignorance, complacency, or willful omission.  None of these are acceptable.  What’s worse, this potentially leaves companies that are informed and accurately record their injury and illness data at a greater risk for enforcement activity.

Another issue is the potential for a company to incur an unusually bad year with regards to recordable incidences, but otherwise, they have a stellar safety record.  That one “blip” on the radar potentially puts them in the crosshairs with other perpetually high-risk establishments.

In short, the SST Program has always been flawed…but give OSHA credit where credit is due.  Their latest updates have addressed some of these flaws.

Key changes include:

  • Companies with upward trending Incidence Rates over a 3-year period are added to the list.
  • A random sample of low-rate companies will be included in the list to verify data accuracy and quality control.
  • Records-only inspections (as opposed to Comprehensive) will be completed for companies who were targeted but were found to have mistakenly “over-reported” data.


Kudos to OSHA for these changes, but don’t forget, the best way to avoid being placed on OSHA’s SST List is to maintain a safe work site, which will, in turn, help you prevent injuries and illnesses.  Visit
Safety Reports’ website for information on how we can help you achieve this goal!

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