NonsubscriberOSHA Issues Updated Guidance on Workplace Site-Specific Targeting Inspections for Job-Related Injuries

10/22/2025by Thomas Fee

The Occupational Safety and Health Administration (OSHA) has recently updated the criteria it uses to select which companies will be targeted during safety inspections. Employers should familiarize themselves with OSHA’s revisions to their inspection program and ensure proper reporting and safety procedures. They should also consult a lawyer if they have questions or need to navigate a Texas nonsubscriber employee injury claim. Fee, Smith & Sharp can provide trusted guidance to ensure maximum compliance.

Understanding the Role of an OSHA Site-Specific Targeting Inspection

Site-specific inspections target companies that have 20 employees or more, and are not in the construction industry. The purpose of these visits is to investigate companies that have injury or illness rates significantly above or below average, companies whose rates are increasing, and companies that fail to report illnesses and injuries in their Form 300 Logs altogether.

OSHA uses these criteria to determine, categorize, and prioritize which companies need targeted inspections. They will review the available data on companies and their accident statistics to determine which ones need to be inspected. They will then conduct inspections without advanced warning and thoroughly review the company’s safety policies, procedures, and environment. They also investigate any claims made by employees.

OSHA’s Changes to the Site-Specific Targeting Inspection Program

As of May 2025, the new OSHA instructions for site-specific targeted inspections state that for the next 2 years they will use data from 2021-2023 to select which companies they will select for site visits. While the types of workplaces they target remain the same, OSHA will be using an updated data set to prioritize companies for inspection. They will also be looking more closely at the Days Away, Restricted or Transferred rates (DART) when examining accident data.

Additionally, OSHA included information about how to handle walkthroughs. Inspectors are to focus in particular on areas where on-the-job accidents have occurred and which may hold more risk of injury. OSHA inspectors can investigate these areas to determine what hazards may be present and in need of repair. They will also assess whether the accidents were due to violations.

Workplaces with the Highest Rates of Injury and Illnesses

Certain industries have more inherent dangers than others, which elevate the risk of accidents, injuries, fatalities, and illnesses. These types of workplaces may be more likely to be subject to site-specific targeted inspections in order to assess what factors are contributing to the unsafe conditions. According to OSHA, the top 10 most dangerous jobs in the U.S. include:

  • Loggers
  • Roofers
  • Fishers and Hunters
  • Helpers in construction work
  • Aircraft pilots and flight engineers
  • Truck drivers
  • Refuse and recycling collectors
  • Iron and steel workers
  • Miners
  • Agricultural workers

Employers in these industries should keep this in mind and take extra steps to reduce the potential for injuries and fatalities to occur.

Important Factors Employers Should be Aware of In Light of OSHA’s New Guidance

Employers should be aware of these new changes and take steps to improve safety, reduce accidents, and report incidents. OSHA visits are typically not scheduled in advance, so employers should always be prepared for an unexpected inspection visit. Employers for high-risk jobs and industries should be especially prepared, as they may be inspected more often.

Accurate reporting will become more important than ever for employers since OSHA will be relying on updated data more heavily. Accurate reports can help employers reduce the frequency of site-specific visits, as well as prevent fines for failing to report. Conversely, accurate reporting can help ensure you are not subject to an OSHA visit that was not warranted.

In an effort to be prepared for OSHA visits, companies should think about how they will handle unannounced visits. They can put a plan in place that outlines the procedure for handling inspections. This can ensure a less stressful and more productive OSHA inspection. Any employee involved in the inspection process should know in advance their role and responsibilities and be cooperative.

How Employers Can Stay Compliant With OSHA’s Workplace Safety Instructions

Employers must take steps to remain compliant with OSHA regulations, as well as ensure the safety of their employees. Part of that responsibility includes making sure that detailed, thorough, and accurate 300 Log records are maintained and updated as applicable. This can also help prevent unwarranted OSHA visits as a result of failed reporting.

In an effort to prevent workplace injuries and ensure compliance, employers should carefully review their safety measures and workplace policies to see if they are in alignment and whether or not there are any gaps. Steps should be taken to strengthen safe workplace practices and the environment for workers. An experienced lawyer can provide insight and direction on steps to take to proactively mitigate the risk of safety violations on the job site.

Failure to comply with OSHA guidance in any capacity could result in steep fines for employers. Companies could be required to pay thousands of dollars in OSHA penalties if they do not implement or enforce the proper safety procedures. This often applies to each individual violation notice issued, which can end up being very costly for employers.

Reach Out to Fee, Smith & Sharp Today

Fee, Smith & Sharp remains updated on the latest OSHA guidance so we can provide our clients with accurate and trusted counsel. We protect your rights and ensure that you have the resources you need to maintain a safe work environment and comply with OSHA’s instructions. If you are unsure about a site-specific inspection, our team is here to answer your questions and discuss your options. Contact us today to schedule a consultation with our knowledgeable team.

Fee, Smith & Sharp White Logo
Dallas | 972-934-9100
Austin | 512-479-8400
Houston | 713-362-8300
info@feesmith.com

Follow us:

INFORMATION

Copyright © 2023 Fee, Smith & Sharp LLP All Rights Reserved

Privacy Policy