ARIZONA DIVISION OF OCCUPATIONAL SAFETY AND HEALTH POLICY AND PROCEDURE
September 21, 2006
OSHA CPL 02-00-141
Programmed Construction Inspection Targeting
TABLE OF CONTENTS
IV. DESCRIPTION OF THE CONSTRUCTION TARGETING PLAN
V. HEALTH CONSTRUCTION INSPECTIONS
VI. RECORDING AND TRACKING
APPENDIX A: C-TARGETING APPLICATION
APPENDIX B: SELECTION CRITERIA OPTIONS
APPENDIX C: SITE SELECTION DESCRIPTION
This policy implements ADOSH’s programmed inspection plan for the construction industry.
This program does not include general industry worksites.
This policy applies to planned construction inspections conducted by all ADOSH compliance
sections. The policy does not apply to construction inspections conducted in response
to an accident, complaint, referral, Local Emphasis Program (LEP) or National Emphasis
- Due to the mobility of the construction industry, the transitory nature of construction
worksites and the fact that construction worksites frequently involve more than
one construction employer, inspections are scheduled from a list of construction
worksites rather than construction employers. The OSHA contractor will provide to
ADOSH a randomly selected list of construction projects from all known covered active
projects. This list contains the projected number of sites the ADOSH compliance
sections plan on inspecting in the next month.
- OSHA's Construction Inspection Targeting System is required to comply with court
decisions on OSHA’s process of selecting worksites for inspection. The system is
designed to provide timely information on known active construction projects, including
the project's location and the name of the owners, project managers and contractors
working on the projects. Since resources limit ADOSH programmed inspections to a
small percentage of construction projects started each year, this targeting plan
is designed to be a broad-based system that selects projects in a way to establish
a presence in the entire construction industry.
- The construction inspection system relies upon a statistical abstract of information
available on construction project starts from F.W. Dodge and on estimated construction
project durations derived from econometric modeling. The system is designed to get
CSHOs on-site at neutrally-selected projects when they are between 30 percent and
60 percent complete, the time when the greatest number of employees and contractors
are expected to be on the construction site.
- OSHA’s contractor adds to the Dodge data a time period when each project is active
and maintains a file containing all active construction projects. From active construction
projects, a randomly selected construction inspection list will be generated for
ADOSH office on a monthly basis. This selection is done without employer identifiers
to ensure neutrality. The list is based upon:
- Counties located within office boundaries;
- Estimated number of worksites to be inspected during the monthly scheduling period
(to be determined by the supervisors);
- The selection criteria are to be determined by the ADOSH Director and/or supervisor
based on local conditions. (Note: “Supervisor”, as used in this policy, refers to
the office supervisor in charge of managing the construction targeting plan, unless
- Description of the Construction Targeting Plan.
- Inspection List Selection Criteria. ADOSH will use the Construction Inspection
Targeting Application located at OSHA’s construction targeting website to set specific
selection criteria and to access the monthly site inspection lists and associated
construction inspection reports (“Dodge” reports). The selection criteria will be
determined by ADOSH administration and safety compliance section supervisors. Only
ADOSH administration and safety compliance section supervisors will be able to access
- Selection of Projects. This targeting plan is designed to be a broad based
system that selects projects in a way to establish a presence in the entire construction
industry. The Construction Inspection Targeting Application includes a function
that allows supervisors to make minor adjustments by excluding categories of projects
from the next monthly random sample of inspection sites. These categories are end-use,
construction type, dollar value, number of stories, and type of owner (i.e. Federal
government, State, municipality, military or private). ADOSH can use these options
to exclude areas of construction that have had a significant amount of focused activity
in recent months. For example, if ADOSH is conducting an LEP focusing on bridge
construction, the supervisor can use the end-use option to exclude bridge building
for the targeting lists generated under this instruction. These options must be
used in a manner which retains the program’s overall objective of establishing a
presence in the entire construction industry. Supervisors who exercise one or more
of the options will also ensure that the generated targeting lists are not limited
in a way that compromises the random selection component of the targeting system.
If the selected options take away the random selection component, the supervisor
must modify the options in a way that generates a randomly selected list.
- Each option within the Construction Inspection Targeting Application is set to a
default. On occasion, the director must review these defaults to determine if they
are appropriate for the local conditions. If any changes are necessary, the director
or supervisor must set the desired deletion or inclusion criteria for the inspection
site list or special emphasis site list, respectively. Examples are: excluding or
including projects with specific dollar values (less than 1 million dollars); or
excluding or selecting projects with specific end-uses (high-rise offices or bridges).
- Another option to facilitate inspection planning is to request projects in a cluster
of counties, so that monthly inspections can be focused in selected areas each month.
This may result in reducing travel time to remote locations or in saturating counties
where an office wants to make ADOSH’s presence felt. However, the supervisor must
ensure that all counties with the office’s jurisdiction will be covered within a
reasonable time period.
- The supervisor will set the current sample size (i.e., the number of inspection
sites that will be provided each month). The office will not receive a list if a
sample size of zero is indicated.
- Scheduling Cycle. The scheduling period (cycle) for construction inspections
is one calendar month. Each month, each office will access its programmed construction
inspection list on the Construction Targeting website. Each office will also access
the Dodge Reports corresponding to the sites on the inspection list. The inspection
list will be dated the following month. It can be used when received and should
be completed by the end of the month it is dated. The use of the current list is
important because conditions change rapidly and the lists become outdated. The best
planning strategy is to receive the required number of sites for the month to ensure
that the most current list is always being used.
- All sites on the inspection list must be inspected, and the sites can be scheduled
in any order to make efficient use of resources.
- Complaints and referrals must be treated in accordance with the Complaint &
Referral Handling policy (ADOSH policy 2006-01).
- ADOSH supervisors are not authorized to make any deletions from that month’s inspection
list prior to its completion, except where the supervisor documents that:
- Little or no construction activity at a worksite on the list has begun or construction
activity has already been substantially completed before an inspection can be made.
- A worksite has become ineligible for any legitimate reason; e.g., where a substantially
complete inspection of the worksite has been conducted as a result of a complaint
investigation. (If in doubt whether a worksite has become ineligible, the supervisor
is to contact the director.)
- A worksite has been approved for exemption from inspection through participation
in the Voluntary Protection Program. (Note: This is not yet a viable reason for
ADOSH to delete a site from an inspection list.)
- Any deletion from a monthly inspection list must be fully documented in accordance
with X.F., below.
- If a new list is posted for the following month and it is anticipated that it will
not be used at all because of a large number of sites remaining on the current list,
the supervisor should reject the list using the Construction Inspection Targeting
Application as soon as practicable so that the unused sites may be restored to be
eligible for possible selection on the next list.
- If it appears that all sites on the list will have been inspected by the end of
the third week of the month, the supervisor may request a supplemental inspection
list through the Construction Inspection Targeting Application.
- If a supplemental list is requested and received, it is to be treated in the same
manner as a list received at the beginning of the month, i.e., once started, it
must be completed.
- The supervisor should consider increasing the sample size if supplemental sites
are repeatedly requested. Similarly, if the lists are not routinely completed by
the end of the month, consider decreasing the sample size.
- Limitation on Frequency of Selection. Normally, no site will be selected
for inspection more frequently than once per trimester. Therefore, any project selected
for an inspection will be removed from the master file for a period of four months
and reentered in the fifth month if it is still active.
- Completion of Inspection List. By the middle of each month, the supervisor
shall assess progress in inspecting all sites on the list in order to plan resources
for the following month.
- If it appears that not all sites on the list will have been inspected by the end
of the month, the supervisor may request a shortened list for the following month
by adjusting the sample size through the Construction Inspection Targeting Application.
- Consecutive months' lists may be combined and used concurrently. However, all sites
from the first month of a combined list must be inspected before worksites from
the second month's list are combined with a third month, except when a site is carried
over as described at X.F., below. That is, lists for two consecutive months can
be combined to form one combined cycle; but the first month's list must be completed
or classified as carryover before the second month's list can be combined with the
third month's list, and so on.
- Carryovers. Worksites on one inspection list may be carried over to the next
cycle only under the following circumstances:
- A worksite may be carried over to the next cycle if it is not operating normally
at the time of the inspection because of personnel strikes, environmental conditions
or other factors.
- A worksite may be carried over to the next cycle if necessary equipment or personnel
with experience and qualifications to perform the inspection are not presently available.
- A worksite may be carried over to the next cycle in the interest of efficient use
of resources. Any worksite carried over in this manner may not be carried over a
- A worksite may be carried over to the next cycle if conditions (construction activity
at the site) have not changed substantially since a prior inspection.
- A worksite may be carried over to the next cycle if the inspection must be deferred
because the employer has requested a full-service comprehensive consultation visit
and that visit has been scheduled.
- A worksite may be carried over to the next cycle if the inspection must be deferred
because the employer has submitted a VPP application for the site. (Note: This is
not yet applicable to ADOSH operations).
- Approval for carrying over a worksite for reasons not listed above must be requested
from and approved by the director).
- Supervisor Administration of Inspection List. The supervisor is responsible
for maintaining documentation necessary to demonstrate that the construction inspection
lists have been properly utilized in accordance with the requirements of this policy
and that selection criteria are current and appropriate.
- The monthly construction inspection lists must be maintained in the office for a
period of two (2) years after completion of the cycle, whether they are used or
- New modifications to the offices’ selection criteria must be determined jointly
by the director and the designated office supervisor. Such modifications will be
effective the month following entry into the computer if they are received by the
23rd of the month. Note: Ongoing changes to the selection criteria, such as sample
size, do not need the director’s approval for each monthly change.
- Deletions from a monthly inspection list must be documented by using the “Archive
Site” function within the Construction Inspection Targeting Application. The appropriate
reason for deletion will be chosen from the drop down menu located in the function.
- Compliance Officer Responsibilities. Compliance officers are responsible
for ensuring compliance with these policies, to the extent applicable to their work.
In general, compliance officers must ensure the following:
- Compliance officers will obtain all programmed planned construction assignments
from the programmed construction inspection supervisor (currently Katherine Gosiger
- Phoenix and Gilbert Bracamonte – Tucson). A programmed construction inspection
will not be conducted at a construction site unless the CSHO has obtained a copy
of the Dodge report from the supervisor.
- The CSHO will conduct an inspection of the site prior to the end of the month for
which the Dodge is dated.
- If the CSHO does not anticipate being able to conduct an inspection of the site
prior to the end of the month, the Dodge shall be returned to the supervisor so
that it may be reassigned.
- Upon completion of a site inspection, the CSHO will provide a copy of the Dodge
to the scheduling supervisor, noting on it the date of the inspection, the inspection
number and the CO ID number
- When completing the Form 1’s for all inspections associated with the site, the CSHO
will enter in Field #42 (Optional Information) the Type, ID and PID, as specified
in XII below.
- Health Construction Inspections.
No separate scheduling method is applied for programmed construction health inspections.
Rather, the supervisor is to determine which construction inspections are to be
conducted as a joint inspection where serious health hazards are likely to exist
at the site. A local emphasis plan may be submitted and approved for scheduling
health construction inspections.
- Recording and Tracking.
The Project Identification Number (PID) must be recorded into the IMIS for each
construction project inspected under this policy. The PID is entered on all of the
ADOSH 1’s generated for the general contractor and the subcontractors at the worksite.
The PID number is the unique six-digit number that identifies each project on the
monthly programmed construction inspection list provided through the Construction
Inspection Targeting Application. The PID is coded as follows in Item 42, Optional
Information of the OSHA-1 Form:
PID (six-digit PID Number)
Note: The PID is also referred to as the Dodge Number.
- APPENDIX A: C-Targeting Application
What is the Construction Inspection Targeting Application?
The OSHA Construction Inspection Targeting Application is an efficient, electronic
way to provide authorized personnel detailed information on construction projects
in your area that have been selected for a programmed inspection and projects that
meet criteria established for any construction special emphasis programs. The application
consolidates and facilitates timely access to information on the selected project
sites in a secure database that authorized personnel can access via the Internet
anywhere and at anytime.
What functions are available in Construction Targeting?
The following functions are available:
- View each of the five lists (Inspection Sites, Supplemental Sites, Special Emphasis
Sites, Early Warning Sites, and Archived Sites).
- View detailed data on a project/site, multiple sites, or all sites from a list.
- View or change deletion criteria for the Inspection Site list.
- Change the number of inspection sites that are requested each month.
- Request additional supplemental inspection sites to inspect.
- View or change selection criteria for the Special Emphasis Site list.
- Print lists and detailed data on a project/site, multiple sites, or all sites from
- Archive a site that has been inspected, completed prior to inspection, or canceled.
- Re-sort a list based on any of the data in the list.
- Search the database using specified data fields.
What worksites do I have access to?
OSHA Area Offices, Regional Offices, and State Plan States can only view project
sites that have been selected in their area. Nonauthorized users will not be able
to see any of this information.
How do I archive inspected sites?
When an inspection is completed for a project that is on the Inspection Site List,
the Supplemental Site List, or the Special Emphasis Site list, enter in the IMIS
Activity Number (OSH1) of the inspection in the designated field on the detailed
display for the site. This removes the project site from the Inspection Site List
to the Archives.
If a project was completed prior to an inspection, enter the word “completed” into
the activity number field. If a project was canceled, enter the word “canceled”
into the activity number field. Entering “completed” or “canceled” into the activity
number field moves the project site to the Archives. Early Warning sites are automatically
removed from the database each month when the new sites are posted to the application.
Project sites will stay in the archives indefinitely. For large projects, inspection
lists may include what appear to be duplicate entries for the same site. This occurs
when a separate bidding process was used for different portions of a project. What
options does the Area Office/State Plan State have to focus the inspection lists
on particular categories of construction? The construction inspection system is
designed to be responsive to the needs of Area Offices/State Plan States. Options
are built in to help target the different categories (end-use, type, dollar value,
number of stories, and type of owner (i.e. Federal government, State, municipality,
military or private)) of construction projects. An Area Office/State Plan State
can specify or update criteria to exclude categories of projects from the monthly
random sample of inspection sites or obtain all sites meeting specified criteria
for special emphasis programs by clicking on the Options tab. Click on 'view or
change' criteria and then on 'Update'. Use the check boxes to indicate the desired
deletion or inclusion criteria for the inspection site list or special emphasis
site list, respectively. Examples are: excluding or including projects with specific
dollar values (less than 1 million dollars); or excluding or selecting projects
with specific end-uses (high-rise offices or bridges). The deletion and inclusion
criteria focus inspection lists on particular categories of construction projects.
Another option to facilitate inspection planning is to request projects in a cluster
of counties within an Area Office/State Plan State jurisdiction, so that monthly
inspections can be focused in selected areas each month. This may result in reducing
travel time to remote locations or in saturating counties where a jurisdiction wants
to make OSHA's presence felt. Indicate this choice by selecting 'other' and typing
a description of desired county rotation in the text box. How can the size of the
monthly inspection site list be managed? The Options page indicates the current
sample size; i.e., the number of inspection sites that have been requested for a
month. Click on 'change' to increase or decrease that sample size. The Office will
not receive a list if a sample size of zero is indicated.
If the Office has inspected all listed sites before the end of the month, the user
can click on 'request' under Supplemental Sites to obtain more sites. An Office
should consider increasing the sample size if it repeatedly has to request supplemental
sites. Similarly, if the Office is not completing its lists by the end of the month,
it should consider decreasing the sample size.
When do I have to make changes for the next month's list?
Supplemental lists can be requested any time during the month. The request for additional
sites will be filled and posted to the database as soon as possible. Changes to
sample size and deletion criteria for the inspection site list and changes to selection
criteria for the special emphasis site list must be made by the 23rd of the month
(or first business day after a weekend or holiday) to be processed for the next
- APPENDIX B: Selection Criteria Options
The sample size is the number of construction project sites requested each month.
The sample size can be changed as frequently as needed, based on an office's current
Request Supplemental Sites
If an office completes all of its listed inspections, authorized personnel may request
additional supplemental sites to inspect.
Request Special Emphasis Sites
An office may request a list of construction project sites for its own construction
targeting initiatives. Note that these targeting initiatives need to be approved
by the National Office.
Inspection Site Deletion Criteria
The Inspection Site Deletion Criteria are used to exclude categories or types of
construction project sites from being selected for inspection. These criteria can
be viewed or changed to meet the needs of the office.
Special Emphasis Selection Criteria
The Special Emphasis Selection Criteria are used to select categories or types of
construction project sites for your office's construction targeting initiatives.
These criteria can be viewed or changed to meet the needs of the office.
- APPENDIX C: Site Selection Description
What is the legal basis for the OSHA Construction Inspection Targeting System?
Due to several court challenges to the worksite selection process for inspections,
OSHA developed the current Federal programmed construction inspection system. The
project selection process which drives the system meets the legal requirement that
projects be selected pursuant to an administrative plan containing specific neutral
criteria. Projects are randomly selected from a file representing the universe of
active construction projects that contains no contractor identifiers.
In addition, the Office of Inspector General (OIG) requires documentation of the
project selection procedures for construction inspections that Area Offices follow.
However, since preparation and maintenance of such documentation would be impracticable
and unduly burdensome on Area Offices, the current system serves as the documentation.
How are sites selected?
A computer-based methodology is used to select projects for inspection on a random,
statistical basis. Selected sites represent a broad range of construction projects:
residential (excluding single-family housing); nonresidential buildings, such as
commercial, manufacturing, transport, industrial, educational, leisure, & public
buildings; heavy construction, such as cogenerators, nuclear power, sewage treatment,
communications, shoreline maintenance; and highway and highway-related construction,
including bridges, tunnels.
Each month, F.W. Dodge provides CIRPC with the names of projects that have entered
the start stage (about 18,300 projects per month), based upon the date of the award
of a general contract or the date when project decisionmakers state that "work is
to start on a particular date". Using a sophisticated construction duration model
that factors in the start date of the project, estimated duration of the project,
type of construction project, dollar value, type of owner (i.e. Federal government,
State, municipality, military or private), number of stories, and a seasonal adjustment,
projects are identified that are estimated to be at some stage of construction,
i.e., active. Accurate start date information is critical to estimates of when projects
will be prime for inspection (30 percent to 60 percent complete).
Projects are randomly selected to obtain the number requested by the Area Office/State
Plan State. Initially, only projects $950,000 and more which are estimated to be
between 30 percent and 60 percent complete are considered for selection. If the
requested quota cannot be met using these criteria, the “percent complete” criterion
is expanded to 25 percent to 65 percent and then to 25 percent to 70 percent complete,
if necessary. If more projects are still required, the value criterion is lowered
to $500,000 (30 percent - 60 percent complete). The final step to meet a sufficient
number ofprojects reduces the value criterion to $250,000 with a 30 to 60 percent
Projects are identified by project identification numbers (PID). Once selected,
the PIDs are used to order an OSHA Construction Report for each project from F.W.
Dodge. Each report contains the following information: project identification number
- unique to each project; project title; project address (or site location information
when address not applicable); project owner's name, business address, & telephone
number; estimated contract value; estimated square footage of buildings; number
of units (on residential projects); number of buildings; estimated construction
start date; type of ownership (i.e. Federal government, State, municipality, military
How accurate are the data on the projects?
The information source on construction projects for the construction inspection
targeting system is F.W. Dodge, Inc., the most extensive construction news gathering
operation in the world. Dodge employs 400 full-time reporters and more than 1,000
correspondents to collect information from a large network of news sources, including
permit offices. After the information is collected, individual project reports are
created. To ensure coverage of as much construction activity as possible, Dodge
maintains 100 branch offices around the country. Reporters make personal visits
and phone calls, daily, to about 55,000 private firms, permit offices, municipal,
state, and government offices to obtain information pertaining to approval, design,
development, and construction of all types of construction projects over $50,000,
including new construction, additions and alterations. Coverage is not restricted
to bid contracts but includes negotiated contracts and major force account work
(use of owner's employees rather than contractor's) as well.
F.W. Dodge files represent the best available universe of active construction projects.
An independent study funded by OSHA found that the Dodge database covers over 90
percent of the universe of all construction projects over $50,000, excluding single-family
housing. Farm construction and small force account projects were areas with less
In an ideal world, all construction projects would be known, each project would
start in the month it was planned to start, each project would remain active the
number of months estimated by econometric models, and each project would proceed
along an orderly path of construction operations that would accurately estimate
in advance the day that excavation, steel erection or landscaping, would begin and
However, actual construction activity is less orderly. Construction plans are constantly
changing; project duration is not available from construction permits or other sources;
each project is unique; the scheduling of construction operations and their duration
differ from project to project, even of the same type, and schedules are rarely
met. Construction schedules for similar end-use projects, such as office buildings,
highways, bridges or schools of equal contract value may vary dramatically in duration
due todifferent design features, site conditions and the owner's cost of delayed
occupancy (use). Even assuming that scheduled duration of projects were available
from owners or contractors, project duration errors would still exist because of
schedule interruptions due to such things as litigation among contractors/owners,
industrial relations disputes, financial problems, or unforeseen construction problems,
which are all common events on construction projects. Given the uncertainties, some
of the projects expected to be 30 percent to 60 percent complete will be in an earlier
stage (or not even started) or at a later stage (or even completed). On the other
hand, the systematic process of identifying projects and estimating their status
using the best available data increases the likelihood that inspections will occur
at all stages of construction.
What are Early Warning Sites?
In addition to the random selections of project sites for inspection each month,
high-value projects at the start stage (month the project is planned to start) are
identified. The purpose of the Early Warning Site (EWS) List is to alert Area Offices/State
Plan States to the initiation of major construction projects, so that their progress
might be followed to ensure a timely inspection of specific phases. Each Early Warning
Site will appear on the Inspection Site List for the month the project is estimated
to be 30 percent complete.
The value threshold to qualify as an Early Warning Site varies by Area Office/State
Plan State, ranging from $5 million to $20 million, depending upon the five-year
historical pattern of project values in the respective area office jurisdiction.