division of labor and industry j. ronald dejuliis, commissioner maryland occupational safety and health eric m. uttenreither, asst. com

DIVISION OF LABOR AND INDUSTRY
J. RONALD DEJULIIS, COMMISSIONER
MARYLAND OCCUPATIONAL SAFETY AND HEALTH
ERIC M. UTTENREITHER, ASST. COMMISSIONER
10946 GOLDEN WEST DRIVE, SUITE 160
HUNT VALLEY, MD 21031-8212

MOSH INSTRUCTION
INSTRUCTION NUMBER: 13-1
EFFECTIVE DATE: January 23, 2013
SUBJECT: Site-Specific Targeting
ISSUANCE DATE: January 23, 2013
CANCELLATION: MOSH Instruction 11-8
EXPIRATION: Effective until replaced by a new Instruction. Upon
replacement of this Instruction, inspection cycles already underway
must be completed as provided in Paragraph IV.B.
Purpose: This Instruction implements MOSH’s Site Specific Targeting
(SST) inspection plan. This program does not include construction
sites.
Scope: MOSH-wide
Reference: OSHA Directive 13-01 (CPL 02)
Contact: Chief of MOSH Compliance Services
See MOSH Website for Current Information
http://www.dllr.maryland.gov/labor/mosh.html
I.
Background
A.
MOSH’s Programmed Inspection Programs
MOSH’s Site-Specific Targeting (SST) program is MOSH’s main programmed
inspection plan for non-construction workplaces. The SST plan is based
on the data received from the prior years’ OSHA Data Initiative
survey. The Data Initiative survey and the SST program help MOSH
achieve its goal of reducing the number of injuries and illnesses that
occur at individual workplaces by directing enforcement resources to
those workplaces where the highest rate of injuries and illness have
occurred.
In addition, MOSH implements “emphasis” inspection programs to target
high-risk hazards and industries.

Martin O’Malley, Governor • Anthony G. Brown, Lt. Governor • Leonard
J. Howie III, Secretary
MOSH INSTRUCTION 13-1
January 23, 2013
Page 2
B.
Creating the SST Inspection Lists
By applying industry and establishment-size criteria, OSHA focuses its
data collection towards establishments that are most likely to be
experiencing elevated rates and numbers of occupational injuries and
illnesses. Specifically, OSHA collects injury and illness data through
the Data Initiative survey from larger establishments (20 or more
employees) in historically high-rate industries.
NOTE: The 2010 and 2011 injury and illness data that was collected by
the 2011 and 2012 Data Initiative is used in this Site-Specific
Targeting program.
C.
SIC and NAICS Codes
The Standard Industrial Classification (SIC) codes as well as the
North American Industry Classification System (NAICS) codes are
referenced in this Instruction. Eventually the NAICS codes will
replace the SIC codes, but during the years of the transition, one or
the other, and sometimes both, will be used.
Beginning with calendar year 2003, injury and illness data published
by the Bureau of Labor Statistics (BLS) uses the NAICS codes. BLS data
referenced in this Instruction uses NAICS codes.
Coverage of OSHA’s injury and illness recordkeeping rule (29 CFR Part
1904) is defined by SIC in §1904.2. In turn, the OSHA Data Initiative
survey is based on the coverage of the recordkeeping rule. Until OSHA
amends the coverage of its recordkeeping rule to reflect data
published under the NAICS coding system, this Instruction will use
both the NAICS and SIC codes.
Whenever possible, both the SIC and NAICS codes for individual
establishments will be supplied to the Regional Offices.
II.
Definitions
A.
Comprehensive Inspection
A comprehensive inspection is a complete and thorough inspection of
all areas of the establishment.
B.
Data Initiative
The Data Initiative is a nationwide collection of
establishment-specific injury and illness data from approximately
80,000 establish­ments. It collects data from establishments by using
the “OSHA Work-Related Injury and Illness Data Collection Form.” The
Data Initiative is OSHA’s Annual Survey that is referred to in 29 CFR
§1904.41.
MOSH INSTRUCTION 13-1
January 23, 2013
Page 3
C.
Days Away, Restricted, or Transferred (DART) Rate
The DART rate includes cases invol­ving days away from work,
restricted work activity, and transfers to another job. It is
calculated based on (N  EH) x (200,000) where N is the number of
cases involving days away and/or restricted work activity, and/or job
transfers; EH is the total number of hours worked by all employees
during the calendar year; and 200,000 is the base number of hours
worked for 100 full-time equivalent employees.
For example: Employees of an establishment, including management,
temporary, and leased employees, worked 645,089 hours at the
workplace. There were 22 injury and illness cases involving days away
and/or restricted work activity and/or job transfer from the OSHA-300
Log (total of column H plus column I). The DART rate would be (22
645,089) x (200,000) = 6.8.
D.
Days Away from Work Injury and Illness (DAFWII) Case Rate
The DAFWII case rate is the number of cases that involve days away
from work per 100 full-time equivalent employees. Cases that involve
only tempor­ary transfers to another job or restricted work are not
included. It is calculated based on (N  EH) x (200,000) where N is
the number of cases involving days away from work; EH is the total
number of hours worked by all employees during the calendar year; and
200,000 is the base number of hours worked for 100 full-time
equivalent employees. NOTE: The DART and DAFWII rates are
differentiated by the makeup of N in the calcula­tion formula. For the
DAFWII rate, N is equal to the total of Column H from the OSHA-300
Log.
For example, from the OSHA-300 Log: Employees of an establishment,
including management, temporary, and leased employees, worked 452,680
hours at the workplace. There were 25 injury and illness cases
involving days away from work from the OSHA-300 Log (total of column
H). The DAFWII case rate would be (25 ÷ 452,680) x (200,000) = 11.0.
E.
Establishment
An establishment is a single physical location where business is
conducted or where services or industrial operations are performed.
For activities where employees do not work at a single physical
location, such as transportation, communications, electric, gas,
sanitary services, and similar operations, the establishment is
represented by main or branch offices, terminals, stations, etc., that
either supervise such activities or are the base from which personnel
carry out these activities. For a more detailed definition of “Establishment,”
see 29 CFR 1904.46. For purposes of this Instruction, the term
“Establishment” does not include construction worksites.
MOSH INSTRUCTION 13-1
January 23, 2013
Page 4
III.
Description of the Site-Specific Targeting Plan
A.
Primary Inspection List
1.
Selection Criteria
Selection of primary list establishments will be based on CY 2010 and
CY 2011 establishment specific injury and illness rates. The SST plan
initially selects for inspecting all establishments with the following
DART and DAFWII case rates:
a.
Manufacturing Establishments
Manufacturing establishments with a DART rate at or above 7.0 or a
DAFWII case rate at or above 5.0 (only one of these criteria must be
met).
b.
Non-manufacturing Establishments
Non-manufacturing establishments (except for Nursing and Residential
Care Facilities) with a DART rate at or above 15.0 or a DAFWII rate at
or above 14.0 (only one of these criteria must be met).
c. Nursing and Residential Care Facilities
Programmed inspections of Nursing and Residential Care establish­ments
shall be conducted under MOSH Instruction 13-2 Nursing and Residential
Care Facilities (NAICS 623110, 623210, and 623311).
2.
Low-Rate Establishments in High-Rate Industries
This SST includes some inspections of low-rate establish­ments in
high-rate industries to verify the reliability of claims by
establish­ments that they had achieved low DART rates. These
inspections will be selected based on the Chief’s discretion utilizing
industry and historical knowledge.
2010 and 2011 OSHA Data Survey Non-Responders
All establish­ments that did not provide rate information in
accordance with the 2011 and 2012 OSHA Data Initiative survey have
been added to the Primary Inspection List. Inclusion of non-responders
is intended to discourage employers from not responding to the Data
Initiative in order to avoid inspection. The establishments selected
will be identified on the Regional Offices’ inspection lists by one
asterisks (*) and will not be deleted from the list.
MOSH INSTRUCTION 13-1
January 23, 2013
Page 5
If the company has gone out of business, moved, changed name, etc.,
the Office of Statistical Analysis (OSA) must be notified so that the
information can be updated for the next ODI survey. Steve Bisson by
e-mail at [email protected], or by telephone at 410-527-4499.
If it is found that an establishment consists of only an office, see
paragraph III.F, Office-Only Sites.
B.
Secondary Inspection List
1.
Selection Criteria
If a Regional Office completes its inspections of all estab­lishments
on its Primary Inspec­tion List before the expiration of this SST
program, it may obtain additional estab­lish­ments from its Secon­dary
Inspection List.
The Secondary Inspection List will contain establishments with the
following CY 2010 and CY 2011 DART and DAFWII case rates, and will be
inspected using the procedures of this Notice:
a. Manufacturing Establishments
Establishments reporting DART rates of 5.0 or greater, or a DAFWII
case rate of 4.0 or greater. Only one of these criteria must be met.
b. Non-manufacturing Establishments (not including Nursing and
Residential Care Facilities)
Establishments reporting DART rates of 7.0 or greater, or a DAFWII
case rate of 5.0 or greater. Only one of these criteria must be met.
Special Emphasis programs may run concurrently with Secondary
Inspection List.
Nursing and Residential Care Facilities
See Primary Inspection List
C.
Industries without Permanent Workplaces
For industries like SIC 0783, Orna­mental Shrub and Tree Services,
which do not have permanent workplaces, the establishment list will
normally, only identify the employer's central office. The Regional
Office will, so far as possible, determine (e.g., by visiting the
central office) which worksites are available based on the type of
work scheduled for each worksite and the length of time remaining to
complete the worksites, and then choose one worksite to inspect by
using a random number table. This will apply to such establishments on
all SST inspection lists.
MOSH INSTRUCTION 13-1
January 23, 2013
Page 6
D.
Different Address than on ODI Data Sheet
The ODI data sheet may show an address for an establishment that does
not match the named establish­ment in an Regional Office’s
jurisdiction. The ODI address may be that of the employer’s
administrative office or some other facility with a different economic
activity, or even the home address of the person completing the ODI
survey. This may also occur when the establishment changes physical
location – moves across the street or to the neighboring town – after
it has submitted its ODI data.
Whenever the address on the ODI data sheet differs from that of the
establishment in the Regional Office’s jurisdictional area, it must be
checked to determine that the ODI survey data relates to the same
establishment. If injury and illness data from the ODI data sheet
pertains to the establishment site in the Regional Office’s
jurisdic­tion, then it will be inspected. If such an address
discrepancy is found, then the Chief of Compliance or designee and the
Office of Statistical Analysis must be informed (Steve Bisson by
e-mail at [email protected], or by telephone at 410-527-4499) so
that its records can be corrected. The Chief of Compliance or designee
will transfer the establishment to the proper Regional Office’s
inspection list, if appropriate. See also paragraph III.F, Office-Only
Sites.
E.
Two or More Establishments in ODI Data
1.
General.
Whenever injury and illness data for two or more establishments of the
same employer are included in the same ODI data sheet, and the
employer is unable to separate the establishment-specific injury and
illness data for each establishment within a reasonable amount of
time, inspections of all the establishments will be conducted.
If the employer is able to separate the establishment-specific injury
and illness data for each of its establishments within a reasonable
amount of time, an inspection of one or more of the establishments
will be conducted, if the establishment’s DART rate is at or above 3.6,
or the DAFWII case rate is at or above 2.2.
The establishment(s) selected for inspection will be based on their
rate; the highest rate establishments will be inspected first.
If more than one establishment is inspected, an OSHA-1 will be opened
for each inspection.
MOSH INSTRUCTION 13-1
January 23, 2013
Page 7
2.
Recordkeeping Rule
The recordkeeping regulation at §1904.40(a) states that once a request
is made, an employer must provide the required recordkeeping records
within four (4) business hours.
Although the employer has four hours to provide recordkeeping records,
there is no requirement that compliance officers must wait until the
records are provided before beginning the walk around portion of the
inspection. As soon as the opening conference is completed, the
compliance officers are to begin the walk around portion of the
inspection.
3.
Contact Office of Statistical Analysis (OSA)
If any of the establishments are not within the Regional Office’s
jurisdiction, contact the Chief of Compliance or designee, so the
establishment(s) can be moved to the correct Regional Office’s
inspection list. If one of the establishments is an Office-Only site,
see paragraph III.F.
F.
Office-Only Sites
The SST is not intended to include establishments that are only
offices. Therefore, if a CSHO arrives at an establishment and
discovers that there is only an office at the site, the CSHO should
attempt to determine for what site or sites the OSHA Data Initiative
(ODI) survey data was entered.
If the ODI data includes data for a site (or sites) in addition to an
office, then an inspection of that site (at least one of several
sites) will be conducted if it is within the Regional Office’s
jurisdiction. If the site(s) is not within the Regional Office’s
juris­diction, contact the Chief of Compliance, or designee so the
establishment can be moved to the correct Regional Office’s inspection
list.
NOTE: Recordkeeping rule §1904.30 requires an employer to keep a
separate OSHA-300 Log for each establishment that is expected to be in
operation for one year or longer.
MOSH INSTRUCTION 13-1
January 23, 2013
Page 8
IV.
Scheduling
The Chief of Compliance, or designee, will provide each Regional
Office with the Primary and Secondary Inspection cycles for its
coverage area.
A.
Maintaining Inspection Lists/Cycles and Documentation
The Regional Supervisor is responsible for maintaining documentation
necessary to demonstrate that the SST inspection lists and cycles have
been properly utilized in accordance with the requirements of this
Instruction, including adequate documen­tation on all deletions,
deferrals or other modifications (modifications such as rationale for
inspections to be expanded to cover health hazards based either (a) on
the prior inspection history of the establishment, or (b) on current
knowledge concerning the industry in which an establishment is
classified). All such inspection lists, cycles and documentation must
be maintained in the Regional Office for a period of three years after
all the inspections conducted under this SST plan are closed.
B.
Cycle Size
Inspection cycles for the randomly ordered Primary and Secondary
Inspection Lists for each county will be distributed by the Chief of
Compliance, or designee. Regional Offices will base their
determination of cycle size (i.e., 5 to 50 establish­ments) on
consid­erations of available resources and geographic range of the
office. Larger cycle sizes will allow greater flexibility and
efficiency of sched­uling, but once begun, the cycle must be
completed. If a cycle larger than 50 would provide the Regional Office
with more efficient use of staff, the office will request approval for
a larger cycle size from the Chief of Compliance.
All of the establishments in a cycle must be inspected (that is, the
inspection must be initiated) before any establishments in a new cycle
may be inspected. In addition, any cycle begun but not yet completed
by the expiration date of this Instruction must be completed, even if
the inspections for the remaining establish­ments in the cycle are
initiated after the expiration date.
C.
Deferrals
1.
MOSH On-Site Consultation 90 Day-Deferral
a.
An establishment that has requested an initial full-service
comprehensive consultation visit for safety and health from
the MOSH Consul­­tation Program, may be deferred from the
SST inspection for 90 calendar days from the date of
notifica­tion by the State Consul­tation Program to the
Regional Office, providing that the visit has been scheduled
by the State Consultation Program.
b.
“In Progress” Deferral. No extension of the deferral beyond
the 90 calendar days is possible unless the consul­ta­tion
visit is “in progress,” which begins at the opening
conference of the consulta­tion visit. If an establishment
currently has a Consultation visit “in progress,” that site
shall receive a deferral for all hazards covered by the
Consultation visit. Such deferral will continue from the
beginning of the opening conference through the end of the
correction due dates and any
MOSH INSTRUCTION 13-1
January 23, 2013
Page 9
c.
extensions thereof. See 29 CFR 1908.7(b)(1) for a definition
of an on-site consulta­tion visit “in progress.”
2.
VPP Applicant
If an establishment is in the process of applying for OSHA’s Voluntary
Protection Program (VPP), the Chief of Compliance, or designee, upon
receiving notification from the VPP manager that a VPP on-site review
has been scheduled, will defer any programmed inspection. The
applicant workplace will be deferred starting no more
than 75 calendar days prior to the commencement of its scheduled
pre-approval on-
site review. The applicant workplace will be removed from any
programmed
inspection list for the duration of VPP participation, unless the site
chooses otherwise.
3.
Pre-SHARP
If an establishment is in pre-SHARP status, that is, in the process of
meeting the criteria of an MOSH Consultation Safety and Health
Achieve­ment Recognition Program (SHARP), it may be deferred for up to
18 months while the employer is working to achieve recognition and
exemption status. See 29 CFR 1908.7(b)(4)(i)(A).
D.
Inspection Priority
Normally, the first inspection priority for Regional Offices is to
conduct un-pro­grammed inspections, and the inspection priorities as
described in the FOM with the following guidance:
1.
Regional Offices that have started but not completed a cycle
of inspections from the previous SST plan must normally
complete that cycle before moving to inspections under the
current SST plan.
2.
All establishments on the SST-12 Primary Inspection List must
be inspected unless, in view of resource considerations, such
as agency emphasis programs, the Chief of Compliance
authorizes the Regional Supervisor to conduct a smaller number
of inspections. Such authorization will normally require the
Regional Office to complete all inspections in the current
cycle.
3.
The Secondary List does not have to be completed before the
expiration date of this Instruction.
4.
Regional Offices will continue to conduct other programmed
inspections under national emphasis programs, or under
regional/local emphasis/initiative programs, as the Regional
Office and Regional goals dictate.
V.
Deletions
Regional Offices will be responsible for making appropriate deletions,
as stated below, from the inspection cycle. In addition, deletions
will also include those establishments, such as those no longer in
business.
MOSH INSTRUCTION 13-1
January 23, 2013
Page 10
Deletion criteria for Previous Inspections, VPP, or SHARP
establishments may be applied to establishments either prior to
creating a cycle or after a cycle is created.
A.
Previous Inspections
Establishments will be deleted from the inspection list if, within 36
months of the current calendar year, establishment received a
comprehensive safety inspection.
The comprehensive safety inspec­tion need not have been initiated by
an SST inspection.
For deletion purposes, the date when an establishment is considered to
have received a comprehensive safety inspection will be the opening
conference date not the closing confer­ence date or the citation
issuance date. For example, if the opening conference date occurred
within
the previous 36 months of the current calendar year, the establishment
will be deleted from the list for SST inspections. If the inspection
is a “joint inspection,” conducted by both a safety CSHO and a health
CSHO, there will be two OSHA-1s. The two CSHOs may hold joint or
separate opening conferences. Therefore, there may be one opening date
for the safety inspection and a different opening date for the health
inspection for the same employer under the same SST inspection plan.
If the inspection is con­ducted by a cross-trained CSHO, there will be
one OSHA-1 and one opening conference date.
B.
VPP or SHARP
1.
If an establishment is an approved participant in OSHA’s
Voluntary Protection Programs (VPP) or in MOSH Consultation’s
Safety and Health Achievement Recognition Program (SHARP) it
is to be deleted from the inspection lists.
C.
Office-Only
See paragraph III.F as to when an establishment is to be deleted if
the establishment injury and illness data is only for an office.
VI.
Inspection Procedures
A.
Scope
1.
Inspections under SST
Inspections conducted under this plan will be comprehensive safety
inspections.
Health inspections under this plan will be limited to:
(a) CSHO referrals (i.e., when a CSHO on site sees a potential health
hazard); or
(b) Inspections expanded by the Regional Supervisor based on prior
inspection history of the employer.
MOSH INSTRUCTION 13-1
January 23, 2013
Page11
NOTE: The above health inspections conducted in accordance with this
Instruction are also to be coded as an SST-12 inspection. See
Recording and Tracking paragraphs VIII.A. and B.
2.
Health Inspections
When a Regional Supervisor orders an SST inspection to be expanded to
cover health hazards at a particular establishment based on the prior
inspection history of the employer, the Regional Supervisor must fully
explain and document his/her rationale for the expanded inspection.
In assessing prior inspection history, the Regional Supervisor will
consider the
employer’s MOSH inspection/violation history maintained in OSHA’s
Integrated Management Information System (IMIS) for the period three
years prior to the current calendar year. The Regional Supervisor will
consider the potential that similar hazards may be present.
Inspec­tions will be conducted in accordance with the procedures
described in the FOM and in other pertinent policy and procedure
documents.
Documentation is necessary to describe the rationale for expanding the
SST inspection to include health hazards/issues. This is to ensure
that the expansion was based on objective and neutral criteria.
Documentation specific to a particular case file is to be maintained
in the case file (i.e., on the OSHA-1 narrative or as a separate
memorandum). Since this documentation also describes a modification to
the SST inspection scope, it must also be maintained along with the
inspection lists. See paragraph IV.A., Maintaining Inspection
Lists/Cycles and Documentation.
3.
Both Safety and Health Inspection Conducted
If both a safety and health inspection are conducted, such inspections
may be conducted either as one combined safety and health inspection
by a cross-trained CSHO (as established through specific training or
demon­strated ability), or as separate safety and health inspections,
or as joint safety and health inspections.
When an SST inspection is assigned to a cross-trained Industrial
Hygienist (IH), the inspection (comprehensive safety) is counted as a
health inspection. If the crossed-trained IH is asked by the regional
supervisor to do a health inspection at an SST site, the inspection is
also counted as a health inspection. In addition, if the cross-trained
IH does both a combined safety and health inspection at an SST site,
it is counted as a health inspection because IMIS can only count an
inspection as either “Health” or “Safety,” but not both.
MOSH INSTRUCTION 13-1
January 23, 2013
Page 12
B.
Citations
Violations will be cited and penalties proposed in accordance with the
FOM and other pertinent policy and procedure documents.
C.
Recordkeeping Violations
Whenever OSHA recordkeeping violations are identi­fied, appropriate
citations and penalties will be proposed, and supporting
docu­men­­tation will be provided, in accordance with policies and
procedures in the FOM.
D. Ownership
If the establishment has changed ownership, but is essentially the
same establishment (i.e., same equipment, processes, services, or
industrial operations) the inspection shall continue.
VII.
Relationship to Other Programs
A.
Un-programmed Inspections
Un-programmed inspections will be conducted according to MOSH’s Field
Operations Manual (FOM) or other pertinent policy and procedure
docu­ments. If the occasion for an un-programmed (e.g., complaint,
fatality) inspection arises with respect to an establishment that is
also in the current inspection cycle to receive a programmed
inspection under the SST plan, the two inspections may be conducted
either concurrently or separately. See paragraph VIII.B., of this
Instruction.
B.
Emphasis Programs
An establishment that is on the Primary List may be moved to the
current inspection cycle if it is also on any Emphasis Program
inspection list (that is, any Special, National, Regional or Local
Emphasis Program). If a Regional Office has finished their Primary
List and is working off its Secondary List, the establish­ment can be
added to the current cycle of their Secondary List. Contact the Chief
of Compliance, or designee, to have the establishment placed in the
current SST cycle.
Some establishments may be selected for inspec­tion under the SST plan
and also under one or more other MOSH or OSHA initiatives (Emphasis
Programs). Programs based upon specific hazards (such as amputations,
combustible dust, crystalline silica, lead, or trenching/excavations)
or specific industries (such as logging,) can be run concurrently with
the SST plan.
Whenever an estab­lish­ment is scheduled for inspection on the current
cycle of the SST plan and on the current cycle of an Emphasis Program,
both inspec­tions may be scheduled at the same time. CSHOs will apply
all applic­able IMIS codes (i.e., NEP, LEP, Strategic, Optional
Information) to the inspection. See paragraph VIII.C., Recording &
Tracking – SST Combined with Emphasis Program Inspections, of this
Instruction.
MOSH INSTRUCTION 13-1
January 23, 2013
Page 13
C.
Process Safety Management Inspections
Inspections conducted under the SST plan will address process safety
manage­ment where 29 CFR 1910.119 applies to the establishment being
inspected. Such inspections must be a comprehensive safety inspection.
However, they will not normally be Program-Quality-Verification (PQV)
inspec­tions as defined.
VIII. Recording and Tracking
A.
SST-Only Inspections
The OSHA-1 Form must be marked as “programmed planned” in Item 24. In
addition, the “NEP” box is to be checked and the value “SSTARG12”
recorded in Item 25d (the SST inspections are being coded under the
NEP for ease of tracking).
NOTE: Any health inspections conducted in accordance with this
Instruction as mentioned in paragraph VI.A.1., Inspection Procedures –
Scope, are also to be coded as SST inspections. See also, NOTE for
paragraph VIII.B., below.
B.
SST Combined with Un-programmed Inspections
For all un-programmed inspec­tions conducted in conjunction with an
SST inspection, the OSHA-1 Form must be marked as “un-programmed” in
Item 24 with the appro­priate un-programmed activity identified. In
addition, the “NEP” box is to be checked and the value “SSTARG12”
recorded in Item 25d.
NOTE: Health inspections that are referrals as mentioned in paragraph
VI.A.1., Inspection Procedures – Scope, are “un-programmed.” However,
these inspections are also to be coded as SST inspections; the SST
codes (e.g., SSTARG12) will not be rejected.
C. SST Combined with Emphasis Program Inspections
For all Emphasis program inspections such as NEPs or LEPs conducted in
conjunction with an SST inspection, the OSHA-1 Forms must be marked as
“programmed planned” in Item 24. In addition, the “NEP” box is to be
checked and the value “SSTARG12” recorded in Item 25d along with all­
NEP and LEP IMIS codes applicable to the inspection.
D.
SST Combined with Un-programmed and Other Programmed Inspections
If an SST inspection is combined with an un-programmed (e.g.,
complaint) inspection and a programmed inspection, such as an NEP or
LEP, Item 24 of the OSHA-1 Form must be marked “un-programmed.”
MOSH INSTRUCTION 13-1
January 23, 2013
Page 14
E.
Strategic Management Plan
Enter all applicable Strategic Management Plan hazard/industry codes
in Item 25f of the Strategic Plan Activity.
By and Under the Authority of
__________________________________________ ___/____/_____
Eric M. Uttenreither, Assistant Commissioner Date
Attachment
cc: J. Ronald DeJuliis, Commissioner, Division of Labor and Industry
Jonathan Krasnoff, Assistant Attorney General
Office of Administrative Hearings

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