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:

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: