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Employer Bulletin No. 324 May 10, 2000
OSHA Targets Employers For Comprehensive Inspections Under Latest Site Specific Targeting Plan
The first inspections pursuant to the latest version of OSHA's Site Specific Targeting Plan are to begin soon for all manufacturing employers and numerous non-manufacturing employers in certain Standard Industrial Classifications (SICs). Under this latest plan, those worksites within these SICs (listed on the back page) that have a "lost workday injury and illness" (LWDII) rate at or above 14.0 are to be targeted for a comprehensive, wall-to-wall safety and health inspection. The LWDII rate is based on employers' injury and illness data in 1998, reported for the establishment in response to the 1999 Data Initiative survey. It is calculated by dividing the establishment's total number of lost workday cases listed in Columns 2 (injury) and 9 (illness) of the OSHA 200 Log by the total number of hours worked by all workers (including management, temporary and leased employees) during the calendar year, and then multiplying that quotient by 200,000. OSHA's example is:
Workers of an establishment including management, temporary, and leased workers worked 645,089 hours at this work site. There were 22 lost workday injuries and illnesses from the OSHA 200 (totals in columns 2 and 9). The LWDII rate would be (22/645,089) x (200,000) = 6.8.
OSHA estimates 4,200 worksites are at or above the high 14.0 rate. OSHA has identified approximately 13,000 establishments with 1998 LWDII rates of 8.0 or above, which is more than twice the national average, and has sent letters to those employers expressing concern and offering assistance in reducing the high rates. OSHA has posted a list of these 13,000 high-rate workplaces on its website, which can be downloaded from http://www.osha-slc.gov/html/hot_5.htm. If an OSHA Area Office completes its allotted number of inspections of establishments rated above 14.0 before January 31, 2001, it is to inspect additional establishments that reported a LWDII rate between 14.0 and 8.0.
This year's new inspections will begin with the OSHA compliance officer reviewing the OSHA 200 Logs for 1997, 1998 and 1999 and calculating the LWDII rate for all three years. The 1998 rate will be compared to the rate reported to OSHA on the 1999 survey. Even if the establishment's actual 1998 LWDII rate turns out to be lower than 14.0, the inspection will continue if either the 1998 or 1999 LWDII rate is at or above 8.0.
SICs Covered By New OSHA Site Specific Targeting Plan
20-39Manufacturing
0210Livestock, Except Dairy and Poultry 0240Dairy Farms 0250Poultry and Eggs 0290General Farms 0783Ornamental Shrub and Tree Services
4210Trucking and Courier Services, except Air 4220Public Warehousing and Storage 4230Trucking Terminal Facilities 4490Water Transportation Services 4510Air Transportation Services 4580Airports, Flying Fields, & Services 4783Packing and Crating 4953Refuse Systems
5010Motor Vehicles, parts, and Supplies 5030Lumber & Other Construction Materials 5050Metals and Minerals, Except Petroleum 5093Scrap and Waste Materials 5140Groceries and Related Products 5180Beer, Wine, and Distilled Beverages 5210Lumber, and other Building Materials 5310Department Stores
8050Nursing and Personal Care Facilities 8060Hospitals
For more information, phone your Constangy, Brooks & Smith attorney or one of the attorneys in the firm's OSHA practice group: David Smith, Neil Wasser, Bill Principe, Mitch Allen, or Pat Tyson at (404) 525-8622.
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