OSHA Sets its 2020 Inspection Agenda: Who’s in the Crosshairs?

Which companies will receive OSHA inspections in Fiscal year 2020 (which began Oct. 1, 2019)? No one can provide an exact list.

But OSHA’s FY 2020 budget request, updated Field Operations Manual (FOM) for its inspectors and its new weighting system for inspections provide enough clues so companies know whether they’re more likely to be inspected.

4 Inspection Priorities

The FOM, which took effect Sept. 13, 2019, lists four priority levels for inspections:

• First: Imminent Danger –conditions where a danger exists that could reasonably cause death or serious physical harm
• Second: Fatality/Catastrophe –OSHA defines catastrophe as the hospitalization of an employee, an amputation or physical loss of an eye
• Third: Complaints/Referrals
• Fourth: Programmed Inspections –these occur where known hazards (combustible dust, chemical processing, falls in construction) exist

Exceptions can be allowed by OSHA Area Directors due to a National, Regional or Local Emphasis Program, and follow-up or monitoring inspections. On the other hand, companies that participate in voluntary compliance programs (Consultation, SHARP and VPP) may be exempt from programmed inspections. Companies that are part of OSHA Strategic Partnerships or Alliances are not exempt.

OSHA Weighting System

Beginning in 2015, OSHA counted how many inspections it completed using a weighting system.

Consuming inspections received multipliers (enforcement units, or EUs). This helped OSHA prioritize its limited resources, including inspectors.

For the first time since 2015, the system has been modified. The OSHA Weighting System (OWS) for FY 2020 took effect Oct. 1, 2019. OSHA is putting less emphasis on how long an inspection takes and more on other factors, including the impact of inspections and agency priorities. One of those priorities: Site-Specific Targeting, which focuses inspections on high injury rate facilities.

Here’s the new OWS:

• Group A, criminal and significant cases (those where fines total more than $180,000): 7 EUs
• Group B, fatalities and catastrophes (hospitalization, amputation, physical loss of an eye), chemical plant National Emphasis Program, process safety management inspections: 5 EUs
• Group C, the “fatal four” –caught-in, electrical, fall and struck-by hazards: 3 EUs
• Group D, priority hazards: amputation, combustible dust, heat, non-PEL overexposures, workplace violence, permit-required confined space, air contaminants, noise and site-specific targeting: 2 EUs
• Group E, everything else: 1 EU

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