OSHA Implements New Weighting System for Workplace Inspections
On October 1, OSHA implemented major changes to how it prioritizes workplace inspections and other compliance activities. The new OSHA Weighting System (OWS) replaces the OSHA’s previous Enforcement Weighting System (EWS) implemented in FY 2015, and expands the number of factors OSHA will consider when assigning enforcement unit (EU) values for different types of workplace inspections, rather than simply basing EU values on the time needed to complete an inspection.
The changes introduced by the OWS are based upon evaluation of existing inspection weighting criteria and working-group recommendations for improvements to the former EWS. Additional factors that will now be considered in inspection weighting include:
- Agency enforcement priorities
- Impact of inspections on improving workplace safety
- Hazards inspected and abated
- Site-Specific Targeting (SST) program objectives
The new OWS is intended to reinforce OSHA’s balanced approach to occupational safety and health (i.e., strong and fair enforcement, compliance assistance and recognition) and will further incorporate the three major work elements performed by the agency: enforcement activity, essential enforcement support functions (e.g., severe injury reporting and complaint resolution), and compliance assistance efforts.
A Brief History of OSHA Inspection Weighting
When we take a step back and look at the changes introduced by the OWS, a pattern begins to emerge. Prior to implementation of the EWS in 2015, OSHA’s inspection weighting policies focused almost solely on the quantity of inspections completed. The agency eventually realized that this quota-based approach disincentivized field inspectors from taking on more complex inspections that required longer periods of time to complete. The EWS dramatically changed OSHA’s inspection weighting policies to incentivize inspectors to perform more detailed inspections. It accomplished this by eliminating quotas and assigning enforcement unit (EU) values to different types of inspections. Under the EWS, inspectors were required to accumulate a set number of EUs within the year, with more complex inspections assigned a higher EU value.
The OWS represents the logical next step towards further refining OSHA’s inspection weighting policies. In the September 27, 2019 press release announcing the new OWS system, OSHA stated that their current enforcement focus is “on critical and strategic areas where the agency’s efforts can have the most impact,” based on the recognition that “time is not the only factor” to weigh when considering the potential impact of inspections. This is consistent with OSHA’s stance that targeting inspections on higher risk establishments in higher risk industries will achieve a greater positive impact on worker health and safety. That’s where the value of the SST program for inspection weighting comes in, since the SST program is specifically designed to target inspections at establishments with higher rates of occupational injuries and illnesses.
It should be noted that the most recent version of the SST program (SST 16), which OSHA implemented roughly one year ago, is the first such program to incorporate occupational injury and illness summary data reported to OSHA via the Injury Tracking Application (ITA). As part of the inspection targeting criteria under SST 16, OSHA indicated that they will be focusing on establishments with a Days Away, Restricted or Transferred (DART) rate significantly higher than their industry average, establishments with a DART rate significantly lower than their industry average (potentially a result of underreporting), and establishments which failed to meet the initial ITA reporting deadline of December 31, 2017 for CY 2016 data.
What Does This Mean for Me?
Since 2015, OSHA has moved away from simply performing as many inspections as possible, and focused on more effectively targeting their inspections based on establishment and industry data. Given this changing focus, it’s a good idea to make sure you have clear visibility of your injury and illness recordkeeping data. For example, you should be fully aware of any applicable electronic reporting requirements, and whether you have met all past electronic reporting deadlines. You should also be familiar with your DART rates, and how they compare with industry averages to know whether you may face an increased likelihood of being inspected by OSHA.
Remember that if you’re targeted for an inspection, OSHA will come to your establishment armed with any information they already have on your establishment, and will take as much time as they need to thoroughly evaluate your compliance. That’s why it’s important to ensure your records are quickly accessible and in good order, especially as they pertain to injury and illness recordkeeping. If OSHA begins identifying gaps in those records or perceives any difficulty in obtaining them from you, it may result in longer inspection times and increase the likelihood of a citation.
That’s why VelocityEHS has created our OSHA Inspection Preparation Checklist to help you make sure you’re ready in the event that OSHA comes knocking.
And for additional information on OSHA Recordkeeping compliance, including electronic reporting requirements, don’t forget to check out our OSHA Recordkeeping Webinar.
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VelocityEHS also makes meeting your electronic reporting requirements fast and simple. Our Incident Management solution allow you to automatically generate and export fully-formatted 300A injury and illness summary data in a standard .CSV file format for direct electronic submission to OSHA’s online Injury Tracking Application (ITA).
And if you’re looking to improve general compliance with OSHA requirements, our Audit and Inspection software helps you quickly and accurately evaluate compliance with regulations, policies and management standards to create consistent organizational protocols and processes, and boost employee involvement.
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