Seyfarth Synopsis: The
Occupational Safety and Health Administration (OSHA) has initiated
a Site-Specific Targeting 2016 (SST-16) Program
using the injury and illness information electronically submitted
by employers to initiate OSHA inspections. OSHA Directive No.
18-01, CPL 02, effective October 16, 2018.
In its news release about the Site-Specific Targeting
2016 Program, OSHA indicated that it "will target high injury
rate establishments in both the manufacturing and non-manufacturing
sectors for inspection." The agency will then perform
comprehensive inspections of employers who are selected for
Program. For CY 2016, OSHA required employers to
electronically submit Form 300A (Summary of Work-Related Injuries
and Illnesses) by December 15, 2017. The deadline for submitting
the 300A data for CY 2017 was July 1, 2018, though OSHA indicted
that employers may still provide this information to the
database.