3.18.14

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OSHA recently announced, and then amended, this year’s Site-Specific Targeting (SST) plan for general industry employers with 20 or more employees. Employers will be selected for inclusion on the SST inspection list based on a random selection of worksites visited during the 2011 SST inspections.

OSHA’s SST-14 Primary Inspection List for federal OSHA jurisdiction Area Offices will be comprised of 1,260 establishments in what the Agency describes as high-hazard industries. The targeted work places were randomly selected from the 2011 SST Primary and Secondary Lists, which were based on 2009 injury and illness data. Rather than rely on Days Away, Restricted, or Transferred (DART) and Days Away From Work Injury and Illness (DAFWII) rates to determine the Primary Inspection List as it has done in the past, OSHA is seeking by this year’s inspections to determine whether the safety records of establishments inspected in 2011 under the SST targeting plan have improved as a result of those earlier inspections. In sum, if your manufacturing facility was inspected in 2011 as part of that year’s Site Specific Targeting Plan, you may be subject to inspection again in 2014. If your facility was subject to a comprehensive safety inspection within the last 24 months, however, you will be deleted from the inspection list.

In addition to the 1260 establishments covered by this year’s SST Plan, Nursing and Personal Care establishments will continue to be targeted under OSHA’s National Emphasis Program for establishments in SIC codes 8051, 8052 and 8059.

If you have an establishment in a state with its own state OSHA agency, these states are required either to adopt the federal approach or to adopt their own inspection targeting plan.

This SST plan does not apply to construction workplaces.

The amended version of this year’s SST plan is published on OSHA’s website at:
http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-14-01.pdf

If you have any questions, feel free to e-mail us at David Smith at dsmith@constangy.com; Bill Principe at bprincipe@constangy.com, Steve Simko at ssimko@constangy.com, Pat Tyson at ptyson@constangy.com, or Neil Wasser at nwasser@constangy.com. You may also call us at 404-525-8622.

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Constangy, Brooks & Smith, LLP has counseled employers on labor and employment law matters, exclusively, since 1946. A "Go To" Law Firm in Corporate Counsel and Fortune Magazine, it represents Fortune 500 corporations and small companies across the country. Its attorneys are consistently rated as top lawyers in their practice areas by sources such as Chambers USA, Martindale-Hubbell, and Top One Hundred Labor Attorneys in the United States, and the firm is top-ranked by the U.S. News & World Report/Best Lawyers Best Law Firms survey. More than 130 lawyers partner with clients to provide cost-effective legal services and sound preventive advice to enhance the employer-employee relationship. Offices are located in Alabama, California, Florida, Georgia, Illinois, Massachusetts, Missouri, New Jersey, North Carolina, South Carolina, Tennessee, Texas, Virginia and Wisconsin. For more information, visit www.constangy.com.

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