OSHA's New Weighted System for Inspection Priorities

OSHA’s fiscal year has started and with the new year comes a new system for weighting their priorities for inspections. This OSHA inspection weighting system is aimed to help them track inspection activity and give regional administrators a guide for prioritizing resources.

⚡ TL;DR: OSHA’s weighted system prioritizes complex, high-impact inspections. Criminal cases earn 7 Enforcement Units (EUs), fatalities earn 5 EUs, Focus Four hazards (caught-in, fall, electrical, struck-by) earn 3 EUs, and routine programmed/NEP inspections earn 2 EUs. One-off complaints and technical assistance earn activity points. The system rewards inspectors for depth, not quantity—so if OSHA shows up, they’re planning to spend time and dig deep.

Inspection weighting has been around since 2015. Prior to that, OSHA would use numbers of inspections completed to count activity. This led to some inspectors loading up on shorter inspections in order to gain quantity while not giving as much credit to those who were doing the long, complex inspections. So, in 2015, a weighting system based on time of completion was developed. However, OSHA found that this was not as ideal as needed either.

The new system factors in agency priorities, inspection impact, and the most hazardous workplaces and operations. Each category of inspection is assigned a numerical value. The most time intensive, complex and high priority inspections gain the most points.

⚠️ Why this matters: The weighted system means inspectors are incentivized to find violations once they’re on site. A focused, thorough inspection—especially one triggered by a complaint, incident, or NEP targeting—is more valuable to an inspector’s performance metrics than a quick walkthrough. Facilities should assume that if OSHA arrives, they will spend 4–8 hours and find issues.

The following is the new points system, from highest value inspection to least value inspection. The points are listed in terms of Enforcement Units, or EUs.

Group A: High-Priority, Time-Intense, Complex Cases [7 EUs]

Criminal Cases
Significant Cases

Group B: High-Priority Hazards, More Complex Than Average [5 EUs]

Fatalities and Catastrophes
Chemical Plant National Emphasis Program Inspections
Process Safety Management Inspections

Group C: Focus Four Emphasis Program [3 EUs]

Caught-In Hazards (trenching, equipment operations, oil & gas)
Electrical Hazards (overhead power lines, electrical wiring methods)
Fall Hazards (scaffolds, elevated walking and working surfaces)
Struck-By Hazards (highway work zones, material handling, landscaping)

Group D: Programmed and National Emphasis Program Inspections [2 EUs]

Amputation Hazards
Combustible Dust
Ergonomics
Federal Agency Inspections
Heat Hazards
Non-PEL Overexposures
Workplace Violence
Permit Required Confined Space Hazards
Personal Occupational Exposure Sampling
Site-Specific Targeting

Other Regional/Local Emphasis Programs Not Already Covered (2-3 EUs)
Group E: All Other Inspections Not Listed (1 EU)

Phone/fax/email investigations (e.g., complaints) and rapid response investigations earn “activity points.” Each one of these earn 1 activity unit for every 9 completed, so the equivalent of 1/9 EU. Additional enforcement support activities such as responses to Freedom of Information Act requests, electronic correspondence responses, state plan monitoring and interventions have not gotten units assigned yet.

OSHA has weighted their compliance assistance activities as well. This is the hierarchy from most important to least: 1. Voluntary Protection Program (VPP) evaluations, 2. OSHA Strategic Partnerships activities, 3. OSHA Alliances activities, and 4. Compliance Assistance activities such as making presentations and staffing informational booths.

Please note, that OSHA can and will still add on any program area to an inspection if they are already at your facility for another issue.

Most facilities don’t know they’re vulnerable until OSHA shows up. A fatality investigation, incident-based complaint, or NEP targeting can trigger an inspection that rolls into 4+ other program areas once the inspector is on-site. The weighted system incentivizes investigators to be thorough, which means bundled citations across multiple standards.

💰 Real inspection cost: A manufacturing facility cited for fatality-related fall hazards (5 EUs) that OSHA then expanded to include caught-in hazards, electrical hazards, and machine guarding (Focus Four, 3 EUs), ended up with 12 citations across four standards totaling $195,000. A baseline safety audit that costs $4,000–$6,000 would have prevented most of it.

How would your facility do if it was inspected by OSHA tomorrow?

Let iSi help you find out! We can conduct safety audits and mock/test run inspections and then help you prioritize the list starting with your most critical. Contact us for a price quote!

Frequently Asked Questions

Q: What changed in OSHA’s inspection weighting system in 2020?

A: OSHA shifted from counting inspection quantity to a weighted points system that prioritizes complexity, hazard severity, and agency priorities. Criminal cases and significant cases earn 7 enforcement units (EUs), fatalities earn 5 EUs, Focus Four hazards earn 3 EUs, and routine inspections earn 1 EU. This system rewards inspectors for conducting high-impact, complex investigations.

Q: Which types of hazards are included in OSHA’s Focus Four Emphasis Program?

A: The Focus Four program emphasizes Caught-In Hazards (trenching and equipment operations), Electrical Hazards (overhead power lines), Fall Hazards (scaffolds and elevated surfaces), and Struck-By Hazards (highway work zones and material handling). These inspections receive 3 enforcement units under the weighted system.

Q: What is worth the most points under OSHA’s current inspection weighting system?

A: Criminal cases and significant cases earn the highest value at 7 enforcement units. Fatalities and catastrophes earn 5 units, followed by Focus Four emphasis hazards at 3 units, and programmed or National Emphasis Programs at 2 units. This reflects OSHA’s focus on preventing the most serious and fatal workplace incidents.

Q: Can OSHA add multiple inspection areas to a single facility visit?

A: Yes, OSHA can and will add additional program areas to an existing inspection if they identify relevant hazards while already at your facility for another issue. This means a complaint investigation can expand to include National Emphasis Program areas if the inspector observes applicable hazards during the walk-around.

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