Share this:|More

OSHA’s inspection plan for site-specific targeting

McAfee & Taft RegLINC - January 2012


By Heidi Slinkard Brasher

In October 2011, OSHA issued its SST-11 annual inspection plan directing the agency’s enforcement efforts toward high-hazard workplaces (those with the highest rates of injuries/illnesses). The SST program focuses on programmed inspections of particular fields which are nonconstruction worksites. The SST-11 employee threshold was lowered to 20 or more employees, down from the previous 40 employee threshold. If you feel as though your industry is being targeted, you may be right. In addition to the SST-11’s random inspection of a small list of manufacturing, nonmanufacturing and nursing and personal care facilities categorized as high hazard workplaces, OSHA also administers national, regional and local emphasis inspection programs which may target your industry.

Some of those targeted on a national scale include industries, processes or practices related to the following:

Combustible dust - including metal dust (aluminum and magnesium), wood dust, coal and other carbon dusts, plastic dust and additives, biosolids, organic dust (sugar, flour, paper, soap and dried blood), and some textile materials, including the following industries:

  • Agriculture
  • Food products
  • Chemicals
  • Textiles
  • Forest and furniture products
  • Metal processing
  • Tire and rubber manufacturing plants
  • Paper products
  • Pharmaceuticals
  • Wastewater treatment
  • Recycling operations
  • Coal handling and processing

Hazardous machinery/amputation hazards - failure to properly use machine guarding and control associated energy hazards when servicing or maintaining machines, including the following industries:

  • Meat packing, preparing meat products, and slaughtering and processing
  • Cheese, bread and other food production
  • Logging, sawmill, planing mill, millwork, pallet and skid, kitchen cabinet, furniture, and paper mill facilities
  • Fiber boxes, plastic/foil/paper bags, and plastic products production
  • Concrete products
  • Steel wiredrawing, nails and spikes, cold-rolled sheets/ strips/bars, pipe and tubes, and foundries
  • Fabricated metal, plate work and metal products
  • Metal work, iron and steel forgings, metal and automotive stamping
  • Dies and tools, die sets, jigs and fixtures, and industrial molds
  • Fans, blowers, air purification equipment, and heating and air conditioning equipment
  • Commercial and industrial refrigeration equipment
  • Industrial and commercial machinery and equipment
  • Motor vehicle parts and accessories

Lead exposure – particularly in the following workplaces:

  • Construction
  • General industry
  • Shipyards
  • Longshoring
  • Marine terminals

Hexavalent chromium exposure – often found in dyes, paints, inks and plastics; as an anti-corrosive agent added to paint, primer, coatings; and in welding, brazing and cutting of metals like stainless steel

Primary metal manufacturing facility exposure to chemicals and physical stressors – particularly in workplaces involved in smelting and refining ferrous and nonferrous metals - refined from ore, pig and scrap during rolling, drawing, casting and alloying metal operations, including:

  • Nail or spike manufacturing
  • Insulated wire and cable manufacturing
  • Steel piping, sheets and bar manufacturing
  • Copper and aluminum products
  • Coke facilities

Process safety management (PSM)

  • Chemical facilities with highly hazardous chemicals above a certain threshold will be the target of inspection of the facilities’ PSM-covered processes, including:
    • Ammonia refrigeration
    • Personal protective equipment (PPE)
  • Petroleum refineries with highly hazardous chemicals above a certain threshold will be the target of inspection by use of a program-quality-verification (PQV) approach, which is a global, open-ended inspection strategy that is very resource-intensive

Trenching and excavating activities in all worksites

Recordkeeping regarding recording and reporting of occupational illnesses and injuries - particularly for businesses reporting low incidents despite operating in industries with historically high incident rates