OSHA’s Updated Site-Specific Targeting Program Heightens Inspection Risks for Non-Compliant Sites

Key Takeaways

• OSHA's 2025 Site-Specific Targeting (SST) Program update uses 2021-2023 data to target high-risk facilities, potentially increasing inspections to more than 700 sites nationwide, a significant jump from 652 in the previous cycle.

• Automation and AI integration are outpacing safety updates, creating machine guarding failures and repetitive strain risks that elevate Days Away, Restricted, or Transferred (DART) rates in manufacturing and warehousing.

• Comprehensive safety programs return $4-6 per dollar invested through reduced workers' comp, avoided fines, and productivity gains, making prevention a strategic advantage.

• Underreporting or errors in injury data can trigger compliance investigations. OSHA's algorithms now detect statistical anomalies that suggest intentional misrepresentation.

• Companies using third-party audits, employee training, and AI-powered safety monitoring can reduce DART rates and avoid SST selection while demonstrating safety culture to OSHA.

As I go forward in my profession, I constantly encounter regulatory updates, which are a necessary part of keeping pace with industries that evolve year after year. The year 2025 began with a wave of these changes from various regulatory bodies. Many companies have already integrated some of these requirements into their operations, yet they’re still struggling to adapt as the mandates grow stricter.

On the bright side, these measures are how federal agencies ensure a safe and harmonious work environment for both employees and employers. 

And now, the Occupational Safety and Health Administration (OSHA) has rolled out another update, one that is more stringent than before. Breaking down the details of this change will help organizations better understand what must be done and how to prepare, starting with a closer look at the 2025 Site-Specific Targeting (SST) program and what it means for today’s workplaces.

What Is OSHA’s Site-Specific Targeting (SST) Program?

The Site-Specific Targeting (SST) program is OSHA’s primary method for scheduling programmed inspections for non-construction workplaces with 20 or more employees. First introduced in the late 1990s, the SST program was designed to make enforcement more strategic by focusing on sites with the highest reported injury and illness rates rather than relying solely on random inspections. Over the years, OSHA has refined the program through periodic updates, each time using more recent and accurate injury data to better identify high-risk workplaces.

At the core of the SST program is OSHA Form 300A, the annual summary of work-related injuries and illnesses that certain employers are required to submit electronically. This form includes key metrics such as the total number of cases with days away from work, job transfers, or restrictions (DART), as well as total hours worked by all employees. 

Accuracy is critical. It’s necessary that the numbers appropriately reflect a company’s safety performance to determine if they’re up for an inspection. Underreporting or errors can lead to compliance investigations, especially if injury rates seem suspiciously low.

To decide which workplaces to inspect, OSHA calculates injury incidence rates from the Form 300A data. One common metric is the DART rate, which measures the number of serious injury and illness cases per 100 full-time employees. Use this DART Rate calculator to estimate your facility’s risk level and understand how your data might influence selection under OSHA’s SST program.

The computed rate is then compared to national averages for similar industries, which is why OSHA separates manufacturing from other sectors, because injury patterns and hazards differ significantly between them.

What’s Inside the 2025 SST Update?

The 2025 SST update, which became effective on May 20, 2025, uses injury and illness data from 2021 through 2023, replacing the previous February 2023 version that relied on 2019–2021 data. This ensures OSHA’s targeting reflects the most current workplace risks and trends.

Here’s how it works in simple terms:

• High-Risk Sites: Places with many days away from work, restricted duties, or job transfers due to injuries in 2023 are top priorities. OSHA has different levels for manufacturing and other sectors.

• Rising Trends: If injury rates are at least twice the average for private businesses in 2022 and getting worse from 2021 to 2023, inspections are likely.

• Low-Risk Sites: To check if reports are honest, OSHA randomly inspects places with very low injury rates.

• Non-Reporters: If a company didn’t submit its 2023 form, it could get a random check.

From April 2023 through December 2024, the SST program led to 652 inspections, uncovering more violations on average than other inspection types. With the expanded criteria and fresher data, OSHA is projected to surpass that figure in 2025, potentially targeting over 700 facilities nationwide.

Why Is OSHA Updating Its SST Program Now?

OSHA’s latest revision to the SST program comes at a time when workplace safety landscapes are shifting more rapidly than in previous years. I’ve noted the significance of this timing, as many industries are now heavily integrating emerging technologies into their operations. These evolving processes, along with changes in workforce structures, have altered both the types and frequency of hazards employees face. 

In reviewing recent enforcement activity, I also found gaps where existing targeting criteria failed to capture certain high-risk scenarios, allowing some problem sites to avoid inspection. The 2025 update is OSHA’s strategic response, adjusting its inspection model to better address today’s most pressing safety challenges and to ensure its oversight keeps pace with the realities of modern workplaces.

Data-Driven Concerns

From 2021 to 2023, several industries showed persistent or rising injury rates, especially those with heavy automation, high-speed production lines, and physically demanding labor.

The warehousing and storage sector had a DART rate of 4.6 per 100 full‑time employees in 2021, which was more than double the rate across all private‑sector industries. By comparison, the overall incidence rate for total recordable cases in private industries was 2.4 per 100 full-time workers. These data suggest that hazards remain significantly prevalent, justifying the need to refine targeting criteria.

While national-level data shows a decline in recordable incidents for manufacturing, from approximately 396,800 cases in 2022 to 355,800 cases in 2023, with a TRC incidence rate of 2.8 per 100 FTE workers, it’s important to recognize that manufacturing still contributes substantially to overall injury volume. 

Technology and Automation

Automation has transformed productivity, but it has also created new categories of risk:

• Unprotected robotic arms and conveyor systems.

• Machine guarding failures.

• Increased pace of work leading to repetitive strain injuries.

• Complex maintenance hazards, especially in aerospace and automotive manufacturing.
  
  

OSHA officials note that these hazards often emerge faster than safety programs are updated, creating a gap that inspections are meant to close.

Recordkeeping and Transparency

OSHA has long suspected that some facilities underreport injuries, whether due to poor recordkeeping, lack of training on the Form 300A requirements, or intentional misrepresentation. The inclusion of low-rate sites and non-reporters in the 2025 SST plan is meant to verify accuracy and encourage compliance across the board.

Proven Impact

Past inspection cycles have shown that when OSHA focuses on high-risk workplaces using targeted selection, the likelihood of uncovering serious hazards increases. This targeted approach has consistently outperformed more generalized inspection methods in identifying violations that could lead to severe injuries or fatalities. Building on those results, OSHA expects the refined 2025 criteria to not only expand the number of inspections but also improve the precision of where those inspections take place, allowing the agency to intervene earlier and with greater impact.

Industries Affected by the 2025 SST Update

The 2025 SST plan casts a wider net than in previous years, using three years of injury and illness data to focus on industries where hazards are both frequent and severe. While aerospace manufacturing remains a priority, OSHA’s criteria bring several other high-risk sectors into sharper focus.

Aerospace Product and Parts Manufacturing (NAICS 3364)

Aerospace production combines heavy equipment, precision tooling, and robotic systems in high-speed assembly lines. The industry’s complexity brings risks of amputations, crush injuries, and severe lacerations, especially when machine guarding or lockout tagout (LOTO) procedures fall short. According to BLS data, aerospace manufacturing has recorded DART rates nearly double the national average in some years, reflecting both mechanical hazards and ergonomic strain from precision assembly work.

Food Manufacturing (NAICS 311)

From meatpacking plants to baked goods factories, food processing facilities often operate under strict deadlines and cold-storage conditions. Workers handle sharp blades, automated slicers, and conveyors, hazards that frequently lead to lacerations and amputations. The repetitive nature of the work also drives up musculoskeletal injury rates. Certain subsectors, like meat processing, have historically recorded DART rates more than twice the national private-sector average of 1.5.

Warehousing and Storage (NAICS 493)

With the e-commerce boom, warehousing has become one of the most injury-prone industries in the U.S. Forklift incidents, falling objects, and overexertion from manual material handling push DART rates consistently above national averages. The rapid pace of order fulfillment can also contribute to higher rates of slips, trips, and falls, making this sector a recurring focus for OSHA’s programmed inspections.

Chemical Manufacturing (NAICS 325)

Chemical plants handle volatile and hazardous substances daily, creating risks of burns, chemical exposure, and explosions. Workers may be injured during routine production, equipment cleaning, or emergency shutdowns. The nature of the work means that even single incidents can result in multiple serious injuries, which inflates DART rates and draws OSHA’s attention.

Ship and Boat Building (NAICS 3366)

Though smaller in overall workforce size, shipbuilding remains a high-hazard industry due to heavy lifting, welding in confined spaces, and exposure to toxic fumes. Injury rates in shipyards often exceed manufacturing averages, with falls from height and crush injuries being among the most common hazards cited by OSHA.

By prioritizing industries with persistently high or rising DART rates, the 2025 SST update ensures that inspection resources are directed toward the environments where workers face the greatest risks.

How Industries Are Adjusting to the Update

For companies that may be on OSHA’s radar, the 2025 SST update is a push to take a closer look at how they keep workers safe. Many are responding by upgrading equipment, expanding employee training, and adopting new technologies, all while weighing the investment against the risks and costs of falling short on compliance.

1. Safety Upgrades

Several facilities are investing heavily in machine guarding, automated shut-off systems, and barrier installations, which are controls that directly target top national injury causes like caught-in and struck-by incidents. 

According to Liberty Mutual’s 2025 Workplace Safety Index, these hazards are among the top 10 causes of serious, nonfatal workplace injuries, which together cost U.S. employers more than $50.87 billion annually.

“The Workplace Safety Index provides employers a trusted roadmap for improving workplace safety … valuable data and insights to help employers prevent injuries and manage risks more effectively, underscoring our commitment to protecting workers and supporting safer, more resilient businesses,” says Dorothy Doyle, Senior Vice President and General Manager, Risk Control at Liberty Mutual.

By aligning high-cost injury drivers with targeted upgrades, companies can not only prevent accidents but also offset the initial investment through reduced workers’ compensation premiums, lower downtime, and avoided OSHA penalties of up to $165,514 per willful or repeat violation in 2025.

2. Training and Workforce Engagement

Industries are strengthening training programs, focusing on hazard recognition, proper machinery operation, and emergency response, to build safer, more compliant workplaces.

• Evidence supports training effectiveness: A comprehensive meta-analysis found that engaging, interactive safety training methods are more likely to translate into lasting behavior changes compared to passive, lecture-only formats.

• E‑training works too: A 2023 literature review confirmed that e‑learning is adaptable, affordable, and effective at increasing worker knowledge and reducing workplace accidents. Plus, it helps track completion and competency across teams.

Approximately, an average company spends about $1,111 per employee annually on training, with small companies (100–999 employees) spending closer to $1,511 per employee. Factoring in lost production time for in-person sessions, the total annual investment for safety-related training typically falls in the $1,100–$1,500 per worker range. 

Even modest gains in safety behavior can lead to big wins, given that the cost of an injury averages around $43,000, and the cost per injured worker (covering lost productivity and ancillary expenses) hovers near $1,080. Reducing incident rates through training directly helps avoid SST-triggered inspections and associated fines.

3. Technology and Automation Safety

From wearable fatigue monitors to AI-driven safety cameras, companies are increasingly using technology to reduce risks and strengthen compliance. These tools enable real-time hazard alerts, help address problems before incidents occur, and offer valuable data to show OSHA that hazards are being proactively managed.

One example is Provectus, which has developed AI-powered video analytics to detect unsafe behaviors such as improper PPE use, hazardous proximity to moving equipment, and violations of restricted-area boundaries. The system can:

• Monitor work areas continuously without requiring additional human staff

• Trigger instant alerts to supervisors when risky behavior is detected

• Generate safety performance reports for compliance documentation and targeted training

By integrating such systems into daily operations, companies can not only reduce incident rates but also demonstrate a strong “culture of safety” during OSHA SST inspections, potentially influencing inspection outcomes in their favor.

4. Proactive Compliance Reviews

Some companies are hiring third-party auditors or using OSHA’s free On‑Site Consultation Program to uncover hazards before inspectors arrive.

• Cost range:

• Private audits (e.g., mock compliance reviews): $6,000–$20,000, depending on facility size and audit scope (industry estimate).

• OSHA On‑Site Consultation: Free, confidential, separate from enforcement, but requires correcting serious hazards, no citations or penalties issued.
  
  

• Why it’s valuable:
  Third-party auditors bring objectivity, industry-specific expertise, and a structured diagnostic process, far beyond what internal teams might offer. Their evaluations typically include documentation review, on-site observation, and a gap analysis, followed by prioritized corrective actions. These audits often deliver strong ROI by preventing injuries, reducing claims, and avoiding violations.
  
  

• Real-World Use Cases:

• Under OSHA’s PSM framework, industries use third-party and reciprocal audits to standardize safety evaluations across contractors, streamlining compliance and reducing audit overlap.

• Safety consultants provide diagnostic audits and mock OSHA inspections, complete with scoring systems, gap identification, and action plans to support continuous improvement.

Saving Lives or Slowing Progress?

The 2025 SST update has intensified OSHA’s focus on data-driven inspections. For companies in high-risk industries, it has raised an uncomfortable question: are tighter safety requirements a brake on operational speed, or a catalyst for smarter, safer growth?

Some executives argue that new requirements add red tape, delay projects, and divert resources from innovation. But in an SST environment, where OSHA selects inspection targets based on employer-reported injury and illness rates, every investment in safety becomes more than just a moral choice; it’s a strategic shield against costly, unplanned inspections.

Evidence shows that comprehensive health, safety, and environment (HSE) programs can return $4–$6 for every dollar invested, thanks to reduced workers’ comp claims, avoided fines, and productivity gains. These programs don’t just protect workers; they can directly influence the injury data that decides whether a facility ends up on the SST list.

In other words, far from slowing progress, targeted safety improvements can help companies comply faster, operate cleaner, and innovate with fewer costly disruptions. For industries under SST scrutiny, the balance tilts heavily toward prevention as both a business and ethical imperative.

FAQs

Can small companies with fewer than 20 employees be subject to SST inspections?

No, SST targets non-construction workplaces with 20+ employees only. Smaller companies can still face inspections from complaints, incidents, or fatalities, but aren't included in the Site-Specific Targeting program.

Does OSHA require a site-specific safety plan?

OSHA doesn't mandate a "site-specific safety plan," but requires employers to identify and control workplace hazards. Written safety programs are required for specific standards like lockout/tagout, confined spaces, and hazard communication.

Do you need OSHA 30 if you have SST?

OSHA 30 training isn't required for SST-targeted facilities. SST is an inspection selection method, not a training requirement. However, comprehensive safety training can help reduce injury rates and avoid future SST targeting.

How can a company avoid being selected for an SST inspection?

Maintain DART rates below industry averages through accurate Form 300A reporting, comprehensive safety training, and proactive hazard controls. Companies with rates below 1.5 per 100 FTE workers are less likely to be targeted.

What happens if OSHA finds violations during an SST inspection?

SST inspections typically find more violations than random inspections. Penalties range from $16,131 for serious violations to $165,514 for willful offenses. Good faith compliance efforts can influence penalty calculations.

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