Every year, OSHA conducts thousands of workplace inspections. While some are triggered by employee complaints or catastrophic incidents, many inspections are the direct result of data analysis. Specifically, OSHA uses the injury and illness data you submit electronically through your OSHA 300A Summary to identify high-hazard workplaces that warrant closer scrutiny.

Understanding what raises red flags in your OSHA recordkeeping data can help you avoid becoming an inspection target and, more importantly, identify genuine safety issues before they escalate into serious problems.

How OSHA Uses Your Data

Since 2017, OSHA has required certain employers to electronically submit their injury and illness data. This requirement varies by company size and industry:

Who Must Submit Data Electronically

Establishments with 250 or more employees in industries covered by OSHA recordkeeping requirements must submit:

• Form 300A Summary (annually by March 2)
• Form 300 Log (specific years as required)
• Form 301 Incident Reports (specific years as required)

Establishments with 20-249 employees in designated high-hazard industries must submit:

• Form 300A Summary (annually by March 2)

What OSHA Does With This Data

OSHA doesn't collect this information just to file it away. The agency uses sophisticated data analysis to:

1. Identify high-hazard workplaces with injury and illness rates significantly above industry averages
2. Detect patterns and trends that suggest serious safety issues
3. Target inspections toward employers where intervention is most likely to prevent serious injuries
4. Benchmark performance across industries and geographic regions
5. Track the effectiveness of safety interventions and enforcement actions

This data-driven approach is formalized through OSHA's Site-Specific Targeting (SST) program, which generates inspection lists based primarily on employers' reported injury and illness rates.

Red Flag #1: High Total Recordable Incident Rate (TRIR)

Your Total Recordable Incident Rate is the most scrutinized metric in your OSHA data. This rate reflects the total number of work-related injuries and illnesses per 100 full-time workers.

How TRIR is Calculated

The formula is: (Number of OSHA Recordable Cases × 200,000) ÷ Total Hours Worked by All Employees

The 200,000 represents 100 full-time employees working 40 hours per week for 50 weeks.

Example:

• Your company had 8 recordable cases last year
• Employees worked 400,000 total hours
• TRIR = (8 × 200,000) ÷ 400,000 = 4.0

What's Considered "High"?

"High" is relative to your industry. OSHA compares your rate to:

• Industry national averages (published by the Bureau of Labor Statistics)
• Your specific NAICS code industry classification
• Geographic region averages
• Establishment size peer groups

A TRIR that's significantly above your industry average places you on OSHA's radar. Generally, rates that are 30-50% higher than the industry average make it more likely you'll be selected for inspection through the SST program.

Warning Signs in Your TRIR

• Sudden spikes from one year to the next without clear explanation
• Consistently high rates that don't improve over time
• Rates climbing while industry averages decline
• Much higher rates than comparable establishments in your area

Red Flag #2: High Days Away, Restricted, or Transferred (DART) Rate

While TRIR counts all recordable incidents, the DART rate specifically measures more serious cases that result in:

• Days away from work
• Restricted work activity
• Job transfer to accommodate restrictions

Why OSHA Focuses on DART

DART cases represent injuries and illnesses serious enough to prevent workers from performing their regular duties. A high DART rate suggests:

• Severity issues beyond just frequency
• Inadequate hazard controls allowing serious injuries
• Potential for catastrophic incidents if conditions don't improve
• Higher workers' compensation costs affecting overall business health

The DART Calculation

(Number of DART Cases × 200,000) ÷ Total Hours Worked by All Employees

Like TRIR, this is compared against industry benchmarks. A DART rate significantly above average is a major red flag, often triggering priority inspections.

Critical DART Patterns

• High DART relative to TRIR (suggesting many injuries are severe rather than minor)
• Increasing DART trend over multiple years
• Multiple cases with extended time away (30+ days lost per case)
• Repeat incidents of the same type requiring time away

Red Flag #3: Industry-Specific Concerns

OSHA pays particular attention to certain industries with historically high injury rates. These high-hazard industries face more scrutiny and have different submission requirements.

High-Hazard Industries Under Extra Scrutiny

Industries in NAICS codes that include:

• Construction (various specialties)
• Manufacturing (particularly with heavy machinery)
• Nursing and residential care facilities
• Warehousing and storage
• Agriculture and forestry
• Transportation (trucking, delivery services)
• Waste management and remediation

Industry-Specific Red Flags

Each industry has particular hazards that OSHA monitors closely:

Construction:

• Falls from elevation
• Struck-by incidents
• Electrical injuries
• Trench collapses

Manufacturing:

• Machine-related amputations
• Repetitive motion injuries
• Chemical exposures
• Caught-in/between incidents

Healthcare:

• Musculoskeletal disorders from patient handling
• Needlestick injuries
• Workplace violence
• Infectious disease exposure

Warehousing:

• Forklift-related incidents
• Falls from loading docks
• Repetitive motion injuries
• Struck-by falling objects

Emphasis Programs

OSHA runs targeted "emphasis programs" (both national and regional) focusing on specific hazards or industries. Being in an industry covered by an active emphasis program increases your inspection likelihood, especially if your data shows related incidents.

Current emphasis areas often include:

• Amputations
• Combustible dust
• Crystalline silica exposure
• Fall hazards
• Heat illness
• Lead exposure
• Process safety management
• Powered industrial vehicles

Red Flag #4: Pattern Recognition by OSHA

OSHA's data analysts look beyond simple rate calculations to identify concerning patterns in your injury and illness data.

Types of Patterns That Trigger Concern

Repeat Injuries to the Same Body Part: Multiple incidents affecting hands, backs, or other specific body parts suggest inadequate controls for known hazards.

Similar Incidents Across Different Workers: When multiple employees experience the same type of injury (e.g., multiple back strains, several lacerations, repeated slip-and-falls), it indicates a systemic safety problem rather than individual worker error.

Seasonal Spikes: Dramatic increases during specific times of year may indicate:

• Inadequate training for seasonal workers
• Rushed production schedules compromising safety
• Weather-related hazards not being controlled

Progressive Severity: A pattern of minor incidents escalating to more serious ones suggests hazards are being identified but not corrected.

Clustering at Specific Locations or Departments: When one department, shift, or facility consistently generates more incidents than others, it signals management or procedural failures at that location.

What OSHA's Algorithms Detect

OSHA's sophisticated analysis systems can identify:

• Outlier establishments whose rates don't match their industry profile
• Negative trends showing deteriorating safety performance
• Inconsistencies suggesting possible underreporting
• High-impact potential where serious incidents seem likely based on patterns
• Repeat violators with persistent safety issues despite previous interventions

Red Flag #5: Comparison to Peer Performance

OSHA doesn't just compare you to broad industry averages. The agency conducts more nuanced comparisons considering:

Size-Adjusted Comparisons

Injury rates often vary by establishment size. OSHA compares your performance to establishments of similar size within your industry, not just to the overall industry average.

Small establishments (20-49 employees) often have different risk profiles than large facilities (500+ employees), so OSHA uses appropriate peer groups for fair comparison.

Geographic Considerations

Regional factors can affect injury rates:

• Climate variations affecting heat stress or cold exposure
• Local workforce characteristics and experience levels
• Regional economic conditions affecting safety investment
• State-specific regulations that may be more stringent than federal OSHA

If you're significantly worse than regional peers facing similar conditions, it suggests correctable deficiencies in your safety program.

Establishment Type Within Industry

Not all manufacturing is the same. OSHA distinguishes between:

• Heavy manufacturing vs. light assembly
• Automated facilities vs. labor-intensive operations
• 24/7 operations vs. single-shift facilities
• Union vs. non-union workplaces

Your comparison group consists of truly comparable establishments, making high rates harder to explain away.

Red Flag #6: Year-Over-Year Changes

Sometimes it's not the absolute rate but the change from previous years that raises concerns.

Concerning Trends

Dramatic Increases: A sudden spike in incident rates from one year to the next demands explanation. Did you:

• Change operations or processes?
• Experience rapid growth with many new workers?
• Have a significant equipment failure?
• Undergo organizational changes affecting safety oversight?

Without documented explanations, OSHA may suspect:

• Deteriorating safety culture
• Inadequate training
• Deferred maintenance catching up
• Previous underreporting being corrected

Sustained High Rates: Consistently elevated rates over multiple years without improvement suggest:

• Ineffective safety programs
• Lack of management commitment
• Inadequate hazard identification
• Insufficient corrective action implementation

Improvement Followed by Regression: If rates dropped after an intervention but then climbed again, it suggests:

• Temporary fixes rather than lasting solutions
• Loss of safety focus
• Inadequate reinforcement of safe practices
• Management attention elsewhere

Red Flag #7: Specific Incident Types

Certain types of incidents automatically trigger enhanced OSHA attention regardless of your overall rates.

Automatic Reporting Events

Some incidents require immediate (8-24 hour) reporting to OSHA:

• Any workplace fatality
• Any amputation
• Any loss of an eye
• Any hospitalization of an employee

These events virtually guarantee an inspection will follow.

High-Concern Injury Types

Even if not immediately reportable, patterns of certain injuries raise red flags:

Amputations (even minor): Suggest inadequate machine guarding or lockout/tagout procedures

Burns (chemical or thermal): Indicate potential process safety issues

Falls from elevation: Point to inadequate fall protection systems

Struck-by incidents: Suggest poor traffic control or material handling procedures

Respiratory illnesses: May indicate inadequate exposure controls or PPE

Hearing loss: Suggests noise exposure program deficiencies

Repeated musculoskeletal disorders: Point to ergonomic hazards not being addressed

Red Flag #8: Recordkeeping Violations

Sometimes the red flag isn't what happened, but how you documented it.

Common Recordkeeping Errors That Invite Scrutiny

Suspiciously Perfect Records: Establishments with zero incidents year after year despite being in high-hazard industries may face audits to verify accuracy. While zero injuries is possible with excellent safety programs, OSHA may want to confirm you're not underreporting.

Inconsistent Data:

• 300 Log totals not matching 300A Summary
• Electronic submission data differing from posted forms
• Employee counts or hours worked that don't align with business operations
• Missing incident details or vague descriptions

Delayed Recording: Recording incidents long after they occurred may suggest:

• Intentional delay to avoid reporting in current year
• Poor incident investigation processes
• Lack of employee awareness about reporting requirements

Classification Errors:

• Recording reportable incidents as "first aid only"
• Misclassifying DART cases as "other recordable"
• Failing to count temporary workers or contractors
• Excluding entire categories of employees inappropriately

Missing or Incomplete Forms:

• Unsigned 300A Summary
• Missing 301 Incident Reports for recorded cases
• Incomplete descriptions of how injury occurred
• No physician/healthcare provider information

How Your Data Actually Compares

Understanding where you stand requires knowing your industry benchmarks and calculating your rates correctly.

Finding Your Industry Benchmarks

The Bureau of Labor Statistics publishes annual injury and illness data by industry. You can find your specific NAICS code benchmarks at:

• BLS Injuries, Illnesses, and Fatalities program website
• OSHA's establishment search tool
• Industry association safety benchmarking reports

Calculating Your Rates Correctly

Many employers miscalculate their incident rates, which can make them appear worse (or better) than reality.

Common Calculation Errors:

• Using estimated rather than actual hours worked
• Excluding overtime hours
• Not counting all employees (including part-time)
• Including non-work hours (vacation, sick leave)
• Using wrong number of incidents (including non-recordable cases)

What "Good" Looks Like

Industry-leading companies typically demonstrate:

• Rates 50% or more below industry average
• Declining trends year over year
• Low severity (DART significantly lower than TRIR)
• Strong near-miss reporting (showing active hazard identification)
• Detailed root cause analysis for all incidents
• Documented corrective actions with verification

What Happens When You're Targeted

Being selected for an OSHA inspection through the SST program doesn't mean you've done anything wrong, but it does mean OSHA believes your data indicates higher risk.

The SST Inspection Process

1. Notification: OSHA compliance officers arrive (usually unannounced) for an inspection
2. Opening Conference: Officer explains the inspection reason and scope
3. Walkaround: Physical inspection of workplace conditions
4. Document Review: Examination of OSHA 300 Logs, training records, safety programs
5. Employee Interviews: Private conversations with workers about safety conditions
6. Closing Conference: Preliminary findings discussion
7. Citations: Issued if violations found (can arrive weeks after inspection)

Common Citation Areas

When OSHA inspects based on high incident rates, they commonly find violations related to:

• Inadequate hazard communication
• Missing or improper machine guarding
• Insufficient fall protection
• Lockout/tagout deficiencies
• PPE program gaps
• Inadequate training documentation
• Recordkeeping violations
• Respiratory protection program issues

Penalties Can Be Substantial

OSHA violations carry significant penalties:

• Other-than-serious: Up to $16,131 per violation
• Serious: Up to $16,131 per violation
• Willful or repeated: Up to $161,323 per violation
• Failure to abate: Up to $16,131 per day beyond the abatement date

Avoiding the Red Flags

The best way to avoid OSHA's targeting is to genuinely improve workplace safety, but there are specific strategies that help:

1. Benchmark Your Performance

Regularly compare your incident rates to:

• Industry averages for your NAICS code
• Regional averages
• Your own historical performance
• Best-in-class performers in your industry

If you're significantly above average, investigate why and take corrective action.

2. Analyze Your Data for Patterns

Don't wait for OSHA to identify patterns. Conduct your own analysis:

• Which departments have highest rates?
• What types of injuries occur most frequently?
• Are there seasonal variations?
• Which body parts are most commonly affected?
• What activities or tasks generate most incidents?

3. Address Root Causes

When patterns emerge, dig deeper:

• Conduct thorough incident investigations
• Identify systemic issues, not just immediate causes
• Implement engineering controls first, then administrative controls, then PPE
• Document your analysis and corrective actions
• Verify that solutions are effective

4. Maintain Accurate Records

Proper recordkeeping is essential:

• Record incidents within 7 days of learning about them
• Use consistent classification criteria
• Complete all required fields accurately
• Have a qualified person (with training) make recordability determinations
• Review records periodically for accuracy and completeness
• Ensure consistency between 300 Log, 300A, and electronic submissions

5. Focus on Leading Indicators

Don't just track injuries after they happen. Monitor:

• Near-miss reports
• Safety observation completions
• Corrective action closure rates
• Training completion percentages
• Safety audit findings
• Employee safety suggestion implementation

6. Invest in Prevention

Proactive safety investments pay dividends:

• Comprehensive training programs (not just new hire orientation)
• Regular equipment maintenance and upgrades
• Ergonomic assessments and improvements
• Engineering controls to eliminate hazards
• Strong safety culture with management commitment
• Employee involvement in hazard identification

7. Get Expert Help

Consider working with:

• Insurance carriers who provide loss control services
• Safety consultants who can assess your programs objectively
• Industry associations offering safety resources and benchmarking
• OSHA consultation services (confidential, no citations, separate from enforcement)

The Role of Technology in Staying Off OSHA's Radar

Modern safety management technology can help you identify and address red flags before OSHA does.

Real-Time Monitoring

Advanced platforms like OSHAlogs provide:

• Automatic rate calculations comparing your performance to benchmarks
• Trend analysis identifying concerning patterns early
• Dashboard alerts when rates exceed thresholds
• Predictive analytics highlighting departments or operations at risk

Accurate Recordkeeping

Technology eliminates common recordkeeping errors:

• Guided data entry ensuring all required information is captured
• Automatic form generation preventing transcription errors
• Consistency checks flagging discrepancies between forms
• Audit trails documenting when and how data was entered

Proactive Intervention

Rather than discovering problems during annual review, you can:

• Monitor rates in real-time throughout the year
• Identify emerging patterns after just a few incidents
• Implement corrective actions before rates become problematic
• Track improvement to verify interventions work

The Bottom Line

OSHA's use of data to target inspections isn't meant to trap employers. It's designed to focus limited enforcement resources where they'll have the most impact: workplaces where workers face the highest risks.

Understanding what triggers OSHA's attention helps you:

1. Identify genuine safety issues before they escalate
2. Benchmark your performance objectively against peers
3. Focus improvement efforts where they're most needed
4. Demonstrate your commitment to worker safety
5. Avoid costly inspections and potential citations

The good news is that reducing red flags and improving safety are the same thing. By focusing on genuine hazard reduction, accurate recordkeeping, and continuous improvement, you simultaneously build a safer workplace and reduce your likelihood of becoming an OSHA target.

Need Help Analyzing Your OSHA Data?

Winter-Dent can help you understand where you stand and what steps to take to improve your safety performance and avoid OSHA targeting.

Our safety experts can:

• Calculate your incident rates accurately and compare them to industry benchmarks
• Analyze your injury patterns to identify systemic issues
• Review your recordkeeping for compliance and accuracy
• Recommend specific interventions based on your data
• Help you prepare for potential OSHA inspections
• Implement proactive safety programs that reduce incidents

Don't wait for OSHA to identify problems. Take control of your safety data and use it to drive real improvements.

Want Tools That Help You Stay Ahead?

Ask Winter-Dent about OSHAlogs, the comprehensive recordkeeping platform that:

• Automatically calculates your TRIR and DART rates
• Compares your performance to industry benchmarks
• Identifies concerning patterns before they become red flags
• Ensures accurate, audit-ready recordkeeping
• Provides real-time visibility into your safety performance

Schedule a complimentary safety data review with Winter-Dent today. We'll analyze your incident rates, compare them to your peers, identify potential red flags, and recommend specific actions to improve safety and reduce your inspection risk.