Are You On OSHA’s 2025 Site Specific Targeting List

If you have ever wondered why one establishment gets a planned OSHA inspection and a similar shop down the street does not, the answer is often a quiet spreadsheet called the Site Specific Targeting plan. OSHA refreshed the plan in 2025 and the mechanics matter. The new instruction uses injury and illness summary data employers submitted electronically, and it builds several lists that can send a compliance officer to your door. If you operate a non construction establishment with twenty or more employees, assume the program applies and plan accordingly. The directive is explicit that this is OSHA’s primary planned inspection program for non construction workplaces, which means it drives a significant share of inspection resources for the year.

Selection is never random in the way people think. OSHA pulls from electronically submitted Form 300A summaries and looks for sites with rates that are outliers when compared with peers. The 2025 instruction also brings trend analysis into the picture, which means an establishment can be selected because its outcomes are moving in the wrong direction across multiple years, not just because a single year looks bad. At the same time, the plan flags establishments that did not submit data when they should have, and it sets aside a smaller track for verifying unusually low rates. The common theme is data integrity. If the numbers suggest risk, expect a knock. If you skipped submission, expect a knock. If your results look implausibly perfect, you may still expect a knock while OSHA checks the recordkeeping. The structure is spelled out in the instruction and echoed in OSHA’s public release that announced the 2025 update.

The practical response begins before you ever see an inspector. Start with your own data trail. Confirm that your posted 300A matched the totals in your log. Confirm that your Injury Tracking Application submission actually went through for the correct establishment names and addresses. If you discover a mistake, correct it now and keep evidence of the correction. When the plan singles out a facility with an upward trend, the case file that follows you into the opening conference will be stronger if you can show that the hazards behind those numbers were addressed with specific changes and not just slogans. The companies that fare best treat the selection as a mirror. If musculoskeletal injuries drove a rising DART rate, they can point to redesigned workstations, pacing changes, and training on body mechanics and lifting. If falls and sprains spiked around a seasonal peak, they can show adjusted staffing and better inspection and cleanup routines.

There is a second mirror in the legal framework. Recordkeeping accuracy is a core enforcement target because OSHA uses those numbers to allocate its time. If your counts are wrong, scope can expand as the inspection turns toward logs, case narratives, and the quality of your decision making. The instruction explains that compliance officers can broaden an inspection when they discover issues that justify a deeper look. What feels like a paperwork review quickly becomes a tour of how the organization controls real hazards. That is why your best insurance is to make sure the floor matches the binder and the binder matches the database you used to submit your totals. Local teams are not flying blind when they arrive.

Owners sometimes ask if they should push back at the opening conference and argue that their site should not have qualified. The answer is that you can raise scope and eligibility questions, but you will not talk your way out of the visit. The selection happened before the car pulled in. Invest your energy in a clear plan for a productive inspection. Identify your management escort and a backup. Set up a space for document review and interviews that does not stall production. Mirror the documentation the compliance officer gathers and correct simple hazards while the walkaround is still in progress, then record what you changed. Those habits matter if you end up at an informal conference talking about classification and penalties. OSHA’s broader penalty guidance recognizes immediate abatement when an employer moves quickly and can show proof, which means the way you handle issues during the inspection can influence the math later.

The mindset shift is to treat selection as a safety signal rather than a verdict. You control what happens next. If the SST list found you because of high rates in a particular department, go there first with your own team. If you were flagged as a non responder, fix the submission issue and build a simple calendar so it does not recur. If you were pulled for low rates that seem too good to be true, audit your logs and make sure your definitions and counting methods are correct. Inspectors respect employers who take responsibility, correct errors, and act fast on real hazards. They are less patient when they see a sterile binder that bears no resemblance to how the work actually gets done.

The last piece is to treat this as a leadership moment. Explain the visit to your team. Share the selection logic in plain language. Connect the dots between the numbers and the jobs where people get hurt. The directive is public. When employees understand why the inspection is happening and how it ties to the risks they live with, you replace fear with purpose. That is the culture OSHA hopes to encourage with data driven selection. It is also the culture that reduces the chance you will see your establishment on a future list.

Sources and further reading: OSHA directive for Site Specific Targeting 2025. OSHA national news release announcing the update and selection criteria based on 2021 to 2023 Form 300A data. OSHA recordkeeping hub at osha.gov/recordkeeping.