Even though there has been a change in administration with President Donald Trump being elected, the Occupational Safety and Health Administration (OSHA) agency sent a clear signal that it is not going to back down from enforcement in 2025. After not being revised since 2023, in May 2025 OSHA revamped its Site-Specific Targeting (SST) inspection program.
The SST program was originally created in 2011 and has been used to identify “high risk” workplaces with 20 or more employees for inspection. Under the SST program, OSHA may select an employer’s establishment for a comprehensive safety or health inspection, which is a “wall-to-wall” inspection without there being a reportable accident or complaint.
Under the revamped SST program, OSHA will use the data that companies submit to the Injury Tracking Application (ITA). This information is due every March 2 on Form 300A to report the previous year’s injuries and illnesses. The SST Plan will select establishments for OSHA inspection based on data for the period 2021 to 2023.
OSHA will take the ITA data and sort companies into four categories under the SST program by comparing their Days Away, Restricted, or Transferred (DART) rate with national averages.
Using the DART rate, OSHA places establishments (e.g., companies or each location for companies with multiple locations) into four categories.
“High-rate establishments.” The directive does not provide a threshold DART rate, but establishments with rates above the industry average can expect to be included in this category. According to the Bureau of Labor Statistics, the overall DART average rate in 2023 for manufacturing was 1.8 per one hundred full-time workers. The average DART rate for printing operations was 1.7 per one hundred full-time workers.
“Upward trending establishments.” These had DART rates “at or above twice the private sector” industry average in calendar year (CY) 2019 and continued to trend upward through CY 2021. The average DART rate for private industry in 2023 was 2.4 per one hundred full-time workers.
“Low-rate establishments.” These are establishments with low DART ratings but also subject to the SST program so OSHA can “verify the reliability” of reported data. Low-rate establishments are not subject to “comprehensive” inspections but are subject to a walk-through recordkeeping inspection. These walk-through inspections can easily become a comprehensive inspection if the inspector observes situations that warrant further investigation.
“Non-responders.” This category is based on the complete absence of data. Establishments that should have, but did not, submit required OSHA Form 300A data in CY 2023.
The SST program does not set an inspection quota per area office or total number of inspections that the agency must conduct per year. The selection process is random based on a computer program. Ultimately, OSHA area offices will determine the number of establishments subject to SST inspections, that can range from five to fifty establishments per fiscal year, based on available resources.
While overall inspections are expected to decline due to a reduction in staffing, OSHA will continue targeting non-construction industries with historically high rates of workplace injuries and illnesses.
The new plan places greater emphasis on the ITA data to identify establishments for inspection. This shift underscores the importance of maintaining accurate and timely injury and illness records.
One significant change from the previous SST program involves situations where a company is mistakenly inspected due to not correctly reporting injuries and illnesses. Not all injuries and illnesses are recordable, and in these cases, OSHA will not continue with a "record-only" inspection and will leave the premises.
This change in the SST program highlights the need for companies to be prepared for inspections at any time. Printing operations need to ensure that they submit the correct Form 300A data, even if there were no recordable injuries or illnesses. OSHA’s revamped SST program signals a renewed focus on data-driven enforcement, making it more important than ever for printing operations to stay compliant, accurate in their reporting, and ready for an inspection at any time. Printing operations are encouraged to develop a plan to respond to an OSHA inspection, so that, in case one occurs, it will go as smoothly as possible.
In this article, Gary Jones, Vice President of EHS Affairs, PRINTING United Alliance, addresses OSHA enforcement. More information about OSHA can be found at Business Excellence-EHS Affairs or reach out to Gary should you have additional questions specific to how these issues may affect your business: gjones@printing.org.
To become a member of the Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org.