OSHA's 2009 Site-Specific Targeting Plan Establishes New Selection Criteria for Inspecting and Puts New Focus on Nursing Homes
On September 4, 2009, the Occupational Health and Safety Administration (OSHA) announced that it would focus its 2009 Site-Specific Targeting (SST) Program on nearly 4,000 high-hazard worksites on the agency's list for comprehensive safety inspections. For the past 11 years, OSHA has used the SST Program to target non-construction employers with high numbers of serious injuries and illnesses. OSHA revises its SST Program annually based upon injury and illness data gathered from its annual Data Initiative Survey of approximately 80,000 employers. The employers surveyed have 40 or more employees and historically high rates of occupational injury and illness.
OSHA uses data collected to develop primary and secondary lists of targets for inspection. OSHA targets employers based upon their "DART" or "DAFWII" rates. DART is the rate of recordable injuries and illness cases per 100 full-time employees, resulting in days away from work, restricted work activity and/or job transfer in a given time frame. DAFWII is the rate of "days away from work injury and illness" cases per 100 employees. Any employer that is required to but does not submit the "OSHA Work-Related Injury and Illness Data Collection Form" also may be added to the inspection list.
In 2007 and 2008, OSHA targeted workplaces with DART rates at or above 11 or DAFWII rates at or above nine. In 2009, however, OSHA moved away from using one rate for all establishments and has established new minimum rates for employers falling into three sectors: manufacturing, non-manufacturing and nursing homes. According to OSHA, this will allow the agency to inspect even more establishments that exceed the minimum rates specific to that sector.
Using 2008 data, OSHA's primary targets for 2009 include 3,100 manufacturing sites with a DART rate of eight or more or a DAFWII rate of six or more. These rates are significantly lower than those used in 2007 and 2008. Using these rates, 500 non-manufacturing facilities and 300 nursing home facilities are on the 2009 primary list. Additionally, for the first time, nursing homes and personal care facilities that do not make the primary list may be added to the secondary inspection list.
In addition to increasing the number of facilities to be inspected, the revised SST guidelines also will lead to more focused inspections, particularly with regard to nursing homes and personal care facilities. The SST guidelines state that such facilities on the primary list will be inspected unless, within 36 months of the creation of the current inspection cycle, the facility had an inspection that focused on ergonomic stressors relating to resident handling, exposure to bloodborne pathogens or tuberculosis, and slips, trips and falls.
Nonetheless, facilities initially appearing on the primary inspection list may be deleted under certain circumstances. For example, employers may be deleted for a period of time established by the On-Site Consultation Project and approved by the regional administrator if the employers are approved participants in the Voluntary Protection Programs (VPP) or are participating in an OSHA Strategic Partnership. Employers in the OSHA Consultation Safety and Health Achievement Recognition Program (SHARP) also may be deleted from the inspection list for a period of time established by the On-Site Consultation Project and approved by the Regional Administration.
In sum, OSHA appears to be stepping up its inspection program and new targets include the nursing home facilities.
OSHA uses data collected to develop primary and secondary lists of targets for inspection. OSHA targets employers based upon their "DART" or "DAFWII" rates. DART is the rate of recordable injuries and illness cases per 100 full-time employees, resulting in days away from work, restricted work activity and/or job transfer in a given time frame. DAFWII is the rate of "days away from work injury and illness" cases per 100 employees. Any employer that is required to but does not submit the "OSHA Work-Related Injury and Illness Data Collection Form" also may be added to the inspection list.
In 2007 and 2008, OSHA targeted workplaces with DART rates at or above 11 or DAFWII rates at or above nine. In 2009, however, OSHA moved away from using one rate for all establishments and has established new minimum rates for employers falling into three sectors: manufacturing, non-manufacturing and nursing homes. According to OSHA, this will allow the agency to inspect even more establishments that exceed the minimum rates specific to that sector.
Using 2008 data, OSHA's primary targets for 2009 include 3,100 manufacturing sites with a DART rate of eight or more or a DAFWII rate of six or more. These rates are significantly lower than those used in 2007 and 2008. Using these rates, 500 non-manufacturing facilities and 300 nursing home facilities are on the 2009 primary list. Additionally, for the first time, nursing homes and personal care facilities that do not make the primary list may be added to the secondary inspection list.
In addition to increasing the number of facilities to be inspected, the revised SST guidelines also will lead to more focused inspections, particularly with regard to nursing homes and personal care facilities. The SST guidelines state that such facilities on the primary list will be inspected unless, within 36 months of the creation of the current inspection cycle, the facility had an inspection that focused on ergonomic stressors relating to resident handling, exposure to bloodborne pathogens or tuberculosis, and slips, trips and falls.
Nonetheless, facilities initially appearing on the primary inspection list may be deleted under certain circumstances. For example, employers may be deleted for a period of time established by the On-Site Consultation Project and approved by the regional administrator if the employers are approved participants in the Voluntary Protection Programs (VPP) or are participating in an OSHA Strategic Partnership. Employers in the OSHA Consultation Safety and Health Achievement Recognition Program (SHARP) also may be deleted from the inspection list for a period of time established by the On-Site Consultation Project and approved by the Regional Administration.
In sum, OSHA appears to be stepping up its inspection program and new targets include the nursing home facilities.
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