You’ve probably heard by now that OSHA has launched the new Site-Specific Targeting 2016 (SST-16) program, which changes the way they will target employers for inspections in 2019. OSHA will use Form 300A data that was electronically submitted by employers for calendar year 2016.

As an agent, this is a critical topic to discuss with your clients to ensure they are prepared for a potential OSHA visit. These visits will occur without prior notice and if any OSHA violations are discovered, employers will be on the hook for significant fines.

In addition to talking to your clients, the SST-16 program is a perfect opportunity to reach out to prospects. If their agent hasn’t informed them about (and helped them prepare for) a potential OSHA inspection, educating them will demonstrate your value while casting doubt about their current agent.

The basics of SST-16

OSHA is targeting employers for inspection based on three categories:

• High rate establishments, who have higher than average injury rates (OSHA will look at manufacturing and non-manufacturing sectors separately in terms of average rates, but plan to target each equally).

• Establishments with lower than average injury rates, to ensure accurate reporting.

• Employers who were required to submit 2016 300A data electronically but did not.

When you talk to clients or prospects, here are some suggestions to help them prepare for a potential OSHA inspection.

• Inform them that the inspection will not be limited to OSHA recordkeeping, but instead could extend to the entire facility.

• Ask if they have submitted their 2016 300A data electronically—and if not, help them do so as soon as possible.

• Ensure they have also submitted their 2017 and 2018 300A data electronically.

• Check their DART rate against the industry average, and if it is significantly below average, suggest auditing the data for accuracy.

• Review past logs for common mistakes and help fix them (use this checklist!).

• Review past logs and analyze if certain hazards have led to multiple incidents, then work with the employer to address those hazards.

Find more suggestions for preparing your clients for an OSHA visit here. Below are some sales scripts and resources to help you as you reach out to prospects.

Cold call script

Hi [prospect name]. I’m [name] from [agency] and I am reaching out to make sure you are aware that OSHA will be targeting more organizations for unannounced inspections this year, and you may be vulnerable. Has your agent talked to you about this?

If the prospect says no…

OSHA has a new Site-Specific Targeting program based on 2016 data that you have electronically submitted to OSHA. They will be inspecting not only your recordkeeping but your entire facility, so its critical to be prepared. I am happy to answer any questions you might have and send you more information on how OSHA is targeting businesses for inspection and how to prepare. How does that sound?

If the prospect is already aware of the program, ask if they have any questions and offer to still send some educational materials.

Voicemail script

Hi [prospect name]. I’m [name] from [agency] and I am reaching out to make sure you are aware that OSHA will be targeting more organizations for unannounced inspection this year, and you may be vulnerable.

OSHA has a new Site-Specific Targeting program based on 2016 data that you have electronically submitted to OSHA. They will be inspecting not only your recordkeeping but your entire facility, so its critical to be prepared. I’m going to email you some information on how OSHA is targeting businesses for inspection and how to prepare.

Please feel free to reach out to me with any questions!

Email script

Hi [prospect name].

[We just spoke on the phone/I just left you a voicemail] about OSHA’s new Site-Specific Targeting program.

Here is some more information about how OSHA is targeting organizations for inspection. Additionally, here are some tips to help you prepare:

• An inspection would not be limited to OSHA recordkeeping, but instead could extend to your entire facility.

• If you haven’t submitted your 2016 300A data, do so immediately as this is one way OSHA is targeting employers.

• Also, ensure that you have submitted your 2017 and 2018 300A data electronically.

• Check your DART rate against the industry average, and if it is significantly below average, consider auditing your data for accuracy.

• Review your past logs for any mistakes (use the attached resource for a list of common mistakes).

• Review past logs and analyze if certain hazards have led to multiple incidents, then work to address those hazards.

I hope you find these resources helpful. Please feel free to contact me with any questions you might have.

[Signature]

You can download the Top 10 OSHA Recordkeeping Mistakes to Avoid checklist here, to either link to or attach in the email.