OSHA Plans To Target Certain Employers In 2000
May 1, 2000
Has OSHA specifically targeted your workplace for inspection in the upcoming
year? A close review and analysis of OSHA’s Site Specific Targeting 2000
compliance directive, which was issued on February 4, 2000, may help you answer
that question.
In recent years, OSHA has implemented its site specific targeting plan to
identify those sites with high accident rates for inspections. The concept
stands on the economic base that limited resources are best expended in those
areas in which they can have the most effect, on inspections of those employers
with the worst history of Loss Work Day Injury and Illnesses (LWDII). Surveys
are distributed to 80,000 employers and some of those who report high rates of
workplace injuries or illnesses are targeted for inspection.
Certain industries are not included in this program. Construction, mining,
sports, deep sea transportation and industries with high concentrations of
government workers have been excluded because their inspections are covered by
another administrative plan or are not subject to or are beyond the scope of
OSHA enforcement. Establishments with less than 10 workers are excluded from the
program as are those that have received a comprehensive safety and health
inspection after January 1, 1998.
Computing the LWDII for an establishment is the most important step in the
analysis. The LWDII is defined as the number of loss work day injuries divided
by the total number of hours worked, times 200,000. That is the number of lost
work day injuries per 100 employees working 2,000 hours per year. The national
average LWDII for 1998 was 3.1. Establishments with LWDII greater than 14.0 are
the first targeted, with the maximum of 4200 sites, with the exception of
nursing homes – all of which will be inspected. Establishments with less than
40 workers will be inspected if no records are available.
If an OSHA area office completes all of its inspections with LWDII greater
than 14.0 between January 31, 2001, it will then move on to establishments with
rates between 8.0 and 14.0.
If your workplace is selected for inspection, the first action taken by the
compliance safety and health officer (CSHO) will be to review your OSHA 200 logs
for 1997, 1998 and 1999. The 1998 rate, (as calculated by the compliance
officer), will be compared to that reported by the employer to OSHA. The CSHO
may also check the OSHA 101, (Accident Report), forms as they deem appropriate
to validate the 200 logs. If the CSHO calculated rate for 1998 or 1999 is above
8.0, he will proceed with an inspection. If the rate is less than 8.0 for each
year, he will do a records review only and record the inspection as such and
exit the facility. However, even for records only inspections, the CSHO may
conduct a partial walk-through and interview workers to verify the records
review. Any serious violations that are observed or brought to the attention of
the CSHO will be cited, as well as any record-keeping violations.
Employers would do well to review their OSHA 200 logs for each of the past
three years to determine if their LWDII is greater than 8.0. If it is greater
than 8.0 for any of the years, they should: (1) recognize that they have what
may be a safety problem at their facility and take appropriate actions to reduce
their LWDII; and (2) proceed as if an OSHA inspection is imminent. I would
suggest that number 2 is sound advice for any employer, independent of their
LWDII, who wants to instill a culture of safety among its employees, provide a
safe work place, and reap the economic benefits that flow therefrom.
For more information please contact Michael G. Murphy at 1-888-688-8500 or
mgmurphy@hklaw.com.
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