OSHA’s Site-Specific Targeting program splits its annual inspection list roughly 50/50 between manufacturing and non-manufacturing establishments. That second half includes healthcare, transportation and warehousing, and utilities and energy, all of which are explicit priorities under the directive OSHA updated in May 2025. If your organization operates a hospital, a distribution center, a fulfillment hub, or a utility plant, and you have assumed OSHA’s targeting programs are primarily a manufacturing concern, that assumption is incomplete. The mechanism, and the exposure it creates, applies just as directly to your facility.
The program most safety teams have never fully mapped
Site-Specific Targeting is OSHA’s primary planned inspection initiative for non-construction workplaces with 20 or more employees. It is not a manufacturing program with occasional exceptions. It uses NAICS industry codes to set one DART rate threshold for manufacturing establishments and a separate threshold for every other covered non-manufacturing sector, a design specifically intended to split enforcement attention evenly across both groups.
Healthcare facilities land on SST lists frequently, driven by DART rates from patient handling injuries, slips and falls, and workplace violence incidents. Transportation, warehousing, and distribution operations show elevated DART rates from forklift operation, repetitive motion injuries, and material handling hazards. Utilities and energy operations, including power generation, water treatment, and gas distribution, are fully covered given the severity risk associated with high voltage exposure and chemical handling.
Construction is the one major exclusion. OSHA does not apply SST to job-site construction work, and instead manages that sector through separate National Emphasis Programs and Local Emphasis Programs built around job-site conditions. The distinction that matters for skilled trades specifically: a job-site trade, such as roofing or structural steel work, sits outside SST. A fixed-facility trade operation, such as an HVAC repair shop or a plumbing fabrication shop, is classified as general industry and remains fully subject to SST.
How your own data builds the list
The mechanism is not opaque. It is built entirely from data every covered employer already submits. Each year, covered establishments file Form 300A summary data through OSHA’s Injury Tracking Application, with the calendar year 2025 submission deadline having passed on March 2, 2026. That data reports the number of days employees were away from work, on restricted duty, or transferred to a different role due to injury or illness.
OSHA converts that submission into a DART rate using a public formula: the number of days away, restricted, and transferred cases, multiplied by 200,000, divided by the total hours worked by all employees at the establishment. That rate is then compared against the manufacturing or non-manufacturing threshold appropriate to the facility’s NAICS code.
Establishments are sorted into four categories. Facilities with DART rates above their industry threshold make the list. Facilities with rates trending upward across the prior three years of submitted data make the list. Facilities that fail to submit required data at all are added automatically. And a sample of facilities reporting unusually low rates are included specifically so OSHA can verify the accuracy of the underlying data across the system. Once an inspection is triggered, it is comprehensive by default. The specific incidents reported in the 300A filing select the establishment, but the inspecting officer is authorized to evaluate hazards anywhere in the facility.
The formula is public. The inspection trigger is automatic. The engagement data that predicted the DART rate increase was sitting in a separate system the whole time.
The connection most safety programs have not made
None of this is sector-specific. A disengaged nurse is more likely to skip a step in a patient handling protocol under time pressure. A disengaged warehouse associate is more likely to bypass a forklift safety check when a shift is behind schedule. A disengaged utility technician is less likely to flag a near-miss to a supervisor they do not trust to act on it. None of that registers as a compliance failure until it becomes a recordable incident, at which point it becomes both a safety event and, through the ITA data pipeline, a contributing input to the facility’s DART rate and its position on next year’s SST list.
Gallup’s Q12 research has found engaged teams post meaningfully fewer safety incidents than disengaged ones, a relationship that holds across industries. We’ve written separately about that research and the mechanism behind it in more depth. What matters for a compliance conversation specifically is where that data ends up: the regulatory framework assumes a workforce that is present, attentive, and willing to report hazards candidly. Disengagement erodes all three assumptions simultaneously, in a hospital, a distribution center, a utility plant, or a factory floor alike. Compliance programs built entirely around inspection checklists and documentation are managing the visible symptom. The underlying driver, whether the workforce is engaged enough to execute the safety program that exists on paper, typically sits outside the compliance function’s visibility altogether.
The question worth taking to your next safety and compliance review
What is your facility’s current engagement score, and has anyone cross-referenced it against your ITA-reported DART data by shift, by unit, or by department? Across manufacturing, healthcare, transportation, and utilities alike, most safety and HR functions have never run that comparison, because the two data sets typically live in separate systems, owned by separate teams, reviewed on separate schedules.
The organizations reducing preventable OSHA exposure are not simply the ones with the most thorough training documentation. They are the ones that connected workforce engagement data to safety outcomes early enough to intervene before a near-miss became a recordable incident, and before that recordable incident became the data point that placed their facility on next year’s inspection list.
About People Element
People Element is a Denver-based HR technology company providing employee survey software for mid-market organizations. We help HR teams upgrade from DIY tools with an easy-to-use, full-lifecycle survey platform covering engagement, onboarding, stay, 360, and exit surveys. Built for frontline-heavy industries, we combine transparent pricing, integrations with HRIS and payroll systems, proprietary benchmarks, and exceptional customer support that consistently sets us apart. Our platform’s simplicity, guided service, and reliable results have earned us repeated High Performer recognition on G2.
Sources
- OSHA. “Site-Specific Targeting Program.” CPL 02-01-067, effective May 20, 2025. osha.gov/news/newsreleases/osha-national-news-release/20250520
- Keating Muething & Klekamp PLL, cited via JD Supra. “OSHA’s Updated Inspection Program: What Employers Should Know and Expect.” jdsupra.com/legalnews/osha-s-updated-inspection-program-what-8508944
- Fisher Phillips LLP. “OSHA’s Updated Site-Specific Targeting Inspection Plan Just Took Effect.” May 29, 2025. fisherphillips.com
- ALL4 Environmental. “OSHA’s Site-Specific Targeting Program.” June 5, 2025. all4inc.com/4-the-record-articles/oshas-site-specific-targeting-program
- National Law Review. “New OSHA Directive Retains Site Specific Targeting Program.” natlawreview.com/article/osha-s-site-specific-targeting-inspection-program-nonconstruction-employers
- LogStead. “How OSHA Picks Who to Inspect: The Site-Specific Targeting Program, Explained.” May 4, 2026. logstead.app/blog/how-osha-picks-who-to-inspect-site-specific-targeting-program-explained
- ManufacturingLeadGeneration.com. “90+ Manufacturing Safety Statistics: Injuries and OSHA (2026).” July 19, 2026.
- Occupros. “OSHA Penalties 2026: Full Fine Table.” occupros.com
- OSHA Workplace Safety. “OSHA Violation Types and Penalties Explained (2026 Guide).” April 6, 2026.
- Workplace Compliance Insights. “OSHA Enforcement Is Intensifying in 2026.” May 27, 2026.
- Gallup. “Q12 Meta-Analysis,” cross-industry. gallup.com
- MDPI Sustainability. “The Influence of Safety Culture and Climate on Safety Performance: Mediating Role of Employee Engagement in Manufacturing Enterprises.” mdpi.com/2071-1050/15/14/11274
- OSHA. “Safety Pays Program.” osha.gov/safetypays
