Client Alerts & Insights
OSHA to Increase Inspections in the Warehousing, Transportation and Healthcare Industries
June 17, 2025
Authored By:
The Occupational Safety and Health Administration (OSHA) recently updated the industries it will focus on, increasing the likelihood of on-site inspections for employers in the warehousing, transportation, and healthcare industries.
The U.S. Department of Labor then issued a press release updating OSHA’s Site-Specific Targeting (SST) inspection program, which OSHA uses to schedule inspections of non-construction workplaces with 20 or more employees.
Employers with 10 or more employees must submit to OSHA the total number of injuries and illnesses that occurred at their workplaces during the previous calendar year. OSHA then selects workplaces for inspection using that injury and illness data. The updated guidance specifies that OSHA may inspect selected employers based on:
- High Days Away, Restricted, or Transferred (DART) rates from the 2023 data;
- Upward trending DART rates based on 2021-2023 data at or above twice the 2022 private sector average;
- DART rates markedly below industry averages, selected randomly; and
- Failure to submit the required data in 2023, selecting randomly to encourage employers to comply with their reporting duties.
OSHA guidance provides that the SST inspections are to be “comprehensive” in scope. The guidance instructs Compliance Safety and Health Officers (CSHOs) to conduct their health or safety inspections based on the “workplace’s potential hazards.” CSHOs are empowered, however, to expand the scope of the inspection according to OSHA’s Field Operations Manual’s specifications.
Due to the increased likelihood and breadth of SST inspections, employers in the warehousing, transportation, and healthcare industries should especially assess their health and safety programs and ensure that they are timely reporting their injury and illness data if required.
If you have any questions, we encourage you to reach out to your Benesch contact or one of the attorneys below.
Joseph N. Gross at jgross@beneschlaw.com or 216.363.4163.
Brad Wenclewicz at bwenclewicz@beneschlaw.com or 216.363.6191.
Latest News
Customs Duty Assists: Regulatory Compliance Overview and FAQ
Customs compliance and enforcement defense are high-profile exercises within U.S.-based importers due to the higher-risk regulatory enforcement environment. One of the more complex hot topics facing compliance and legal professionals within importers of record (IORs) is the degree to which “assists” impact dutiable value, and therefore duty burden, in the eyes of U.S. Customs and Border Protection (CBP).
TSA Authorized Representatives—Emerging Practice of Engaging Freight Brokers and Its Practical Implications
Air transportation safety has long been of critical supply chain importance and geopolitical significance, and that role is growing. Supply chain constraints over this decade have driven a need for adaptation, modal diversification and cost containment. To do so, authorized air cargo providers have increasingly explored new ways to add capacity for regulated surface transportation.
Chameleon Carriers—FMCSA’s “Reincarnated” Rule and Enforcement
As the U.S. DOT and its FMCSA ramp up certain elements of domestic enforcement, regulators are utilizing existing laws and regulations that previously were not often invoked. Enforcement of the English language proficiency requirement is one great example.
What’s Old Is New Again: Broker Liability Insulation from the Case Law in the Post-Montgomery Era
The Supreme Court has spoken in its Montgomery v. Caribe Transport decision, and the brokerage sector, and even shipper and motor carriers, are working toward adapting to this “new liability regime.”