OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

July 18, 2002



Directorate of Compliance Programs
SUBJECT: Site-Specific Targeting: Clarification


A couple of regions have asked us to clarify the date when an establishment is considered to have "received a comprehensive safety and health inspection." This concerns the Deletion section of the SST-02 directive for those establishments that have received a comprehensive safety and health inspection after January 1, 2000 (for SST-01 the date would be after January 1, 1999).

For deletion purposes the opening conference date will be used; not the closing conference date nor the citation issuance date. For example, if the opening conference date occurred after January 1, 2000 the establishment will be deleted from the list (for SST-02 inspections). The opening conference date is used because the Office of Management Data Systems' (OMDS) IMIS identifies an inspection by its opening conference date.

If the inspection is a combined inspection, conducted by a safety CSHO and a health CSHO, there will be two OSHA-1s. The 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.

This memorandum applies to inspections under all SST programs. If you have any questions, please contact the [Office of General Industry Enforcement at (202) 693-1850].

[Corrected 10/22/2004]