OSHA Inspection Program Updates: Enhancing Safety Through Strategic Enforcement

In a continued effort to reduce workplace injuries and ensure safe working conditions, the Occupational Safety and Health Administration (OSHA) has rolled out several major updates to its inspection and enforcement programs. These updates reflect a data-driven, targeted approach to inspections, with additional emphasis on worker representation, heat safety, and expanded reporting requirements.

Top 4 OSHA Inspection Program Updates:

  1. Updated Site-Specific Targeting (SST) Inspection Program
  2. Employee Representation During Inspections
  3. National Emphasis Program (NEP) on Heat-Related Hazards
  4. Expanded Electronic Submission Requirements

Updated Site-Specific Targeting (SST) Inspection Program

On May 20, 2025, OSHA released Directive CPL 02-01-067, a revised version of its Site-Specific Targeting (SST) inspection program. This initiative focuses on non-construction establishments with 20 or more employees, using injury and illness data gathered from the OSHA Form 300A submissions for calendar years 2021 through 2023.

Key Components:

  • High-Rate Establishments: Facilities with elevated Days Away, Restricted, or Transferred (DART) rates in 2023 are prioritized for inspection.
  • Upward Trending Establishments: Establishments with a DART rate at or above twice the 2022 private sector average and a rising trend in injuries from 2021 to 2023 are targeted to address potential emerging hazards.
  • Low-Rate Establishments: A random sample of low-rate establishments is selected to validate the accuracy of reported data and deter underreporting.
  • Non-Responders: Facilities that failed to submit their 2023 Form 300A data are also eligible for inspection.

This updated directive replaces the previous version issued on February 7, 2023, and will be in effect for two years, unless superseded.

Employee Representation During Inspections

OSHA reinforced its stance on worker rights by updating guidance on employee representation during inspections. Effective May 31, 2024, employees may authorize a representative to accompany OSHA inspectors during workplace walkarounds.

This representative can be:

  • Another employee, or
  • A third-party non-employee, such as a union representative, safety consultant, or public health expert, provided their presence is “reasonably necessary” for an effective inspection.

The updated guidance emphasizes OSHA’s commitment to transparent and inclusive inspections, ensuring workers have a voice in safety evaluations.

National Emphasis Program (NEP) on Heat-Related Hazards

With heat-related injuries and fatalities rising, OSHA extended its National Emphasis Program (NEP) on Outdoor and Indoor Heat-Related Hazards through April 8, 2026.

Highlights:

  • Since the NEP’s launch in 2022, OSHA has conducted over 7,000 heat-related inspections.
  • The program targets industries with high exposure risks, including agriculture, construction, warehousing, and manufacturing.
  • Employers are urged to implement heat safety plans, including hydration, acclimatization, rest breaks, and training.

OSHA is also progressing toward a permanent federal heat standard. A Notice of Proposed Rulemaking was published on August 30, 2024, with a virtual public hearing scheduled to begin June 16, 2025.

Expanded Electronic Submission Requirements

Beginning January 1, 2024, OSHA’s recordkeeping rule mandates that certain employers in high-hazard industries with 100 or more employees must electronically submit data from:

  • OSHA Form 300 (Log of Work-Related Injuries and Illnesses)
  • OSHA Form 301 (Injury and Illness Incident Report)
  • OSHA Form 300A (Summary of Work-Related Injuries and Illnesses)

This rule is aimed at:

  • Increase transparency of workplace safety data.
  • Enhance OSHA’s ability to identify and target high-risk establishments.
  • Improve public access to employer safety records.

A Stronger, Smarter Enforcement Strategy

These updates signal a shift toward smarter, more strategic enforcement that relies on data analysis, employee engagement, and hazard-specific initiatives. By leveraging modern tools and focusing on areas of greatest need—such as heat illness prevention and accurate injury reporting—OSHA continues to modernize its oversight while reinforcing its core mission: to ensure safe and healthful working conditions for every worker in America.

For EHS consultation or support with any of these changes contact Cardinal Compliance Consultants.



from Cardinal Compliance Consultants https://cardinalhs.net/blog/osha-inspection-program-updates-2025/
via Cardinal Compliance Consultants

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