OSHA Notice

ABSTRACT

By and Under the Authority of

David Michaels, PhD, MPH
Assistant Secretary

Executive Summary

This Notice describes the Federal Agency Targeting Inspection Program (FEDTARG). It defines key terms, describes the development of FEDTARG inspection lists, outlines scheduling and inspection procedures for FEDTARG, and provides information on IMIS coding. The Appendix provides a checklist for Compliance Safety and Health Officers.

Significant Changes

The revised directive adds a definition for lost time case, updates OSHA recordkeeping violation policy, and adds guidance for the inspection of a federal worksite with multiple operations.


 

Table of Contents

1. Purpose
    
2. Scope
    
3. References
    
4. Cancellations
    
5. Expiration Date
    
6. Federal Program Change
    
7. Background
    
8. Significant Changes
    
9. Action Required
    
   1. Responsible Office
   2. Action Offices
   3. Information Offices
       
10. Definitions
     
    1. Certified Safety and Health Committee
    2. Comprehensive Inspection
    3. Deferral
    4. Establishment
    5. Federal Agency
    6. Lost Time Case
    7. OWCP Data
    8. Partial Inspection
    9. Partnership
        
11. Description of the Establishment-Specific Targeting Plan
     
    1. Scope
    2. Primary Inspection List
    3. Secondary Inspection List
    4. Site with Multiple Operations
    5. Office Only Sites
        
12. Scheduling
     
    1. General
    2. Maintaining Inspection Lists/Cycles and Documentation
    3. Deferrals
    4. Inspection Priority
    5. Security Clearance
        
13. Deletions
     
    1. Previous Inspections
    2. OSHA Strategic Partnership
    3. Voluntary Protection Programs
        
14. Inspection Procedures
     
    1. Scope
    2. Notices of Unsafe or Unhealthful Working Conditions
    3. Recordkeeping Violations
    4. Compliance Safety and Health Officers
        
15. Relationship to Other Programs
     
    1. Unprogrammed Inspections
    2. Special Emphasis Program Inspections
    3. Inspections under Both FEDTARG and NEP/LEP
        
16. Recording and Tracking
     
    1. FEDTARG11-Only Inspections
    2. FEDTARG11-Combined with Unprogrammed Inspections
    3. FEDTARG11-Combined with NEP or LEP Inspections
    4. FEDTARG11-Combined with Unprogrammed and Other Programmed Inspections
    5. Strategic Management Plan
        
    APPENDIX A - Compliance Safety and Health Officer Checklist
     

1. Purpose. The OSHA Federal Agency Targeting Inspection Program (FEDTARG) is a fiscal year (FY)-based programmed inspection program designed to focus on specific federal agency worksites experiencing a high number of lost time cases (LTCs). This Notice implements FEDTARG for FY 2011. FEDTARG11 continues OSHA's nationwide inspection targeting program for federal worksites. This Notice outlines the procedures for carrying out programmed inspection activity at some of the most hazardous federal workplaces.
    
2. Scope. This Notice applies OSHA-wide.
    
3. References.
    
   1. Occupational Safety and Health Act of 1970, Section 19: Federal Agency Safety Programs and Responsibilities.
       
   2. Executive Order 12196, February 26, 1980.
       
   3. 29 CFR Part 1960, Basic Program Elements for Federal Employee Occupational Safety and Health Programs and Related Matters, October 21, 1980 and as amended.
       
   4. 29 CFR Part 1960, Subpart I – Recordkeeping and Reporting Requirements; 69 FR 68793-68805, November 26, 2004.
       
   5. 29 CFR Part 1904, Recording and Reporting Occupational Injuries and Illnesses.
       
   6. Directives
      • ADM 03-01-005, OSHA Compliance Records, OSHA Instruction, August 3, 1998.
         
      • CPL 02-00-025, Scheduling System for Programmed Inspections, OSHA Instruction, January 4, 1995.
         
      • CPL 02-00-135, Recordkeeping Policies and Procedures Manual, OSHA Instruction, December 30, 2004.
         
      • CPL 02-00-148, Field Operations Manual (FOM), November 9, 2009.
         
      • CSP 03-01-003, Voluntary Protection Programs (VPP): Policies and Procedures Manual, OSHA Instruction, April 18, 2008.
         
      • CSP 03-02-002, OSHA Strategic Partnership Program for Worker Safety and Health, OSHA Instruction, December 9, 2004.
         
      • FAP 01-00-003, Federal Agency Safety and Health Programs, OSHA Instruction, May 17, 1996.
         
4. Cancellations. This Notice cancels OSHA Notice FAP 01-00-006, Federal Agency Targeting Inspection Program (FEDTARG10), dated February 22, 2010.
    
5. Expiration Date. This Notice expires on September 30, 2011, unless replaced earlier by a new Notice. Upon the expiration or replacement of this Notice, inspection cycles already underway must be completed as provided in paragraph XII.D of this Notice.
    
6. Federal Program Change. This Notice applies solely to federal agency worksites. It does not impact State Plan programs.
    
7. Background.
   
   Executive Order 12196 – Occupational Safety and Health Programs for Federal Employees, Paragraph 1-401(i) requires Federal OSHA to "[c]onduct unannounced inspections of agency workplaces when the Secretary determines necessary if an agency does not have occupational safety and health committees; or in response to reports of unsafe or unhealthful working conditions...".
    
8. Significant Changes. The revised directive adds a definition for lost time case, updates OSHA recordkeeping violation policy, and adds guidance for the inspection of a federal worksite with multiple operations.
    
9. Action Required.
    
   1. Responsible Office. The Directorate of Enforcement Programs (DEP), through its Office of Federal Agency Programs (OFAP), coordinates the development of FEDTARG, oversees the overall program, and advises the Assistant Secretary concerning FEDTARG issues.
       
   2. Action Offices. All National Office Directorates and Offices, Regional Offices, and Area Offices involved in the design, approval, and implementation of this inspection targeting program must adhere to this Notice.
       
   3. Information Offices. The OSHA Training Institute, Voluntary Protection Programs Managers and Coordinators, OSHA Strategic Partnership Coordinators, Compliance Assistance Coordinators, Compliance Assistance Specialists, Federal Agency Program Officers, and Regional Enhanced Enforcement Program Coordinators must be aware of this inspection targeting program.
       
10. Definitions.
     
    1. Certified Safety and Health Committee. An agency safety and health committee that meets the provisions of section 1-3 of Executive Order 12196, and of 29 CFR Part 1960, as listed and attested to by the head of each agency, in writing to the Secretary. The following federal agencies have certified safety and health committees: Central Intelligence Agency, Department of Labor, General Services Administration, Securities and Exchange Commission, Tennessee Valley Authority, and the U.S. International Trade Commission.
        
    2. Comprehensive Inspection. Consistent with the Field Operations Manual (FOM), Chapter 3, paragraph III. A., Comprehensive, the term "comprehensive inspection" is a

       [S]ubstantially complete inspection of the potentially high hazard areas of an establishment. An inspection may be deemed comprehensive even though, as a result of the exercise of professional judgment, not all potentially hazardous conditions, operations, and practices within those areas are inspected."

    3. Deferral. For purposes of this Notice, the term "deferral" means a delay of an inspection of a specific federal agency due to its participation in an OSHA Strategic Partnership (OSP) or application to a Voluntary Protection Programs (VPP). Deferrals will be inspected at the end of their deferral period.
        
    4. Establishment. Consistent with 29 CFR 1960.2, Defintions, and as applied to federal agencies, the term "establishment" means a

       [S]ingle physical location where business is conducted or where services or operations are performed. Where distinctly separate activities are performed at a single physical location, each activity will be treated as a separate establishment and inspection. Typically, an establishment refers to a federal agency's field activity, regional office, area office, installation, or facility.

    5. Federal Agency. Consistent with 29 CFR 1960.2, Definitions, the term "federal agency" means an Executive Department, as identified in U.S. Code Title 5, Part 1, Chapter 1, §101, or any employing unit, or authority of the Executive Branch of the Government. For the purposes of this Notice, it does not include the United States Postal Service (USPS).
        
    6. Lost Time Case. A lost time case is defined as a worker's compensation case reported to the OWCP wherein an employee looses time from work beyond the date of the injury.
        
    7. OWCP Data. The Office of Workers' Compensation Programs (OWCP) is an agency within the Department of Labor that administers the Federal Employees' Compensation Program, providing benefits for federal and USPS employees with employment-related injuries or occupational illnesses. The data generated through the OWCP claims process, specifically the number of lost time cases experienced by federal agencies, is used to generate the primary inspection list for FEDTARG.
        
    8. Partial Inspection. Consistent with the FOM, Chapter 3, Inspection Scope, B. Partial, a "partial inspection" is an inspection "...whose focus is limited to certain potentially hazardous areas, operations, conditions, or practices at the establishment." A partial inspection may be expanded based on information the compliance safety and health officer (CSHO) gathers during the inspection process. The CSHO, in consultation with the Area Director, must use professional judgment to determine the necessity for expanding the inspection's scope, based on information gathered during the records or program review and walkaround inspection. For OSHA Strategic Partnership Program (OSPP) participants, CSP 03-02-002, paragraph XIV.B.4. refers to this type of inspection as a programmed inspection with a limited scope.
        
    9. Partnership. For this Notice, the term "partnership" refers only to those agreements in which:
        
       1. The establishment participates in an OSP in accord with OSHA Instruction CSP 03-02-002; and, for which
       2. There is an active partnership agreement.
           
11. Description of the Establishment-Specific Targeting Plan for FEDTARG11.
     
    1. Scope. This program is directed toward federal agency establishments that experienced high numbers of lost time injuries during fiscal year 2010. Establishment-specific lost time claims data was obtained from the OWCP to implement this Program.
        
    2. Primary Inspection List. For each of the OSHA Regions, a primary inspection list, also known as the inspection cycle, will be developed using a random numbers table. Each OSHA Region's primary inspection list will include 100% of the establishments within the Region's jurisdiction reporting 100 or more lost time cases (LTCs) during FY 2010, 50% of the establishments reporting 50 to 99 LTCs, and 10% of the establishments reporting 20 to 49 LTCs. All sites on the primary list must be inspected.
        
    3. Secondary Inspection List. The National Office recognizes that resources available for conducting FEDTARG inspections will vary among the Regional and Area Offices. Those offices that have the ability to conduct more targeted federal agency inspections than are provided on their primary inspection lists may develop additional inspection cycles from the secondary inspection lists. Once any cycle is opened, it must be completed.
       
       On request, OFAP will provide the Federal Agency Program Officers (FAPOs) with secondary lists of sites within their Regions that fall within the scope of FEDTARG. The lists will provide basic information about each site, as well as the random number designation assigned to each site. After determining the number of additional inspections desired, the FAPO will use the lists to create a secondary inspection cycle on either a Regional or Area Office basis. To create an Area Office cycle, the FAPO will identify all establishments within the coverage of a particular Area Office. These establishments will remain in the same order as on the "master list" since they have already been subject to random selection and ranking. For each cycle that is developed, and assuming that the requisite numbers of sites are available, 60% of the sites will come from the list of worksites with 50-99 LTCs, and 40% will come from the list with 20-49 LTCs.
        
    4. Site with Multiple Operations. A Federal agency establishment can house multiple operations, such as may exist at a Federal Correctional Complex (FCC). A FCC can include multiple Bureau of Prisons institutions at one location, such as a high security prison with other lower security institutions [such as a single or multiple UNICOR facility(ies)]. Therefore, if a CSHO arrives at an establishment and discovers multiple operations present at the Federal agency, the CSHO will need to review the injury and illness logs to identify a limited number of the establishment's physical locations experiencing LTCs. The Area Director will determine the appropriate number and location of on-site inspections necessary to adequately address the safety and health issues, but at least one site must be inspected. If the Area Director determines that more than one location needs to be inspected, the sites may be chosen either randomly or based on the highest number of LTCs.
        
    5. Office Only Sites. The FEDTARG inspection program does not focus on establishments that are office environments only. Therefore, if a CSHO arrives at an establishment and discovers an office at the site, has reason to believe that the establishment is the "clearinghouse" for OWCP purposes, or the address does not reflect where the LTCs are occurring, the CSHO must determine if other work locations were included as part of the "establishment" for OWCP purposes. For example, a human resources office may be listed with a large number of LTCs when in actuality those cases were associated with smaller workgroups at various locations.
       
       The CSHO will need to review the injury and illness logs to identify a limited number of the establishment's physical locations experiencing LTCs. The Area Director will determine the appropriate number and location of on-site inspections necessary to adequately address the safety and health issues, but at least one site must be inspected. If the Area Director determines that more than one location needs to be inspected, the sites may be chosen either randomly or based on the highest number of LTCs. In the event that a high number of LTCs are occurring in the office environment, the office will be inspected.
        
12. Scheduling.
     
    1. General.
       
       The National Office will provide each Region with a list of establishments within its coverage area meeting the criteria for the primary inspection list. On request, the National Office will provide each Region with lists of establishments which reported 50-99 and 20-49 LTCs during FY 2010, to be used in generating secondary inspection cycles. These supplemental lists will include the agency name, number of claims, and limited establishment location information.
       
       An Area Office must complete the inspections on the primary targeting list prior to initiating cycles from the secondary inspection list. If needed, a secondary inspection cycle may be opened before completion of the primary list to:
       1. Improve the efficiency of the Area Office, or
       2. Continue federal agency inspection activity if inspections at some of the primary sites have been deferred.
           
       Once any inspection cycle is opened, whether primary or secondary, it must be completed.
        
    2. Maintaining Inspection Lists/Cycles and Documentation.
       
       The Area Director is responsible for maintaining documentation necessary to demonstrate that the FEDTARG11 inspection lists and cycles have been used in accord with the requirements of this Notice. Documentation should include a rationale for all deletions, deferrals, or other modifications, such as a reason for expanding specific inspection(s) to cover health hazards, based on either:
        
       1. The prior inspection history of the establishment, or
       2. Current knowledge concerning the industry in which an establishment is classified.
           
       In accord with CPL 02-00-025, paragraph B.1.b.(1)(c)3., the Area Office must maintain all inspection lists, cycles, and documentation for a period of three years after completing all the inspections conducted under the current FEDTARG directive. For a records disposition schedule, see ADM 03-01-005, Appendix D, Compliance Records Disposition Schedule.
        
    3. Deferrals.
        
       1. OSHA Strategic Partnerships (OSPs). According to CSP 03-02-002, OSHA Strategic Partnership Program for Worker Safety, Section XIV. OSPP Benefits, B. OSHA Enforcement Benefits, an establishment participating in an OSP for which there is an active agreement may be deferred from a programmed inspection for up to six months from the signing of the partnership agreement, or the establishment's subsequent entry into the partnership. Contact the Regional Partnership Coordinator/Manager with any questions regarding a specific workplace. See CSP 03-02-002.
           
       2. Voluntary Protection Programs (VPP) Applicant. If an establishment is in the process of applying for OSHA VPP status, the Area Director, upon receiving notification from the VPP Manager that a VPP on-site review has been scheduled, will defer any programmed inspection. If an establishment is a VPP applicant, and a VPP on-site review is scheduled within the next 75 calendar days, programmed inspections will be deferred. See CSP 03-01-003
           
    4. Inspection Priority.
       
       Normally, an Area Office's first inspection priority is to conduct unprogrammed inspections. Area Offices will follow the inspection priorities as described in CPL 02-00-148, with the following additional guidance:
        
       1. Area Offices that have started but have not completed a cycle of federal agency inspections must normally complete that cycle before beginning a new cycle. Carryovers will be handled in accord with CPL 02-00-025, Scheduling System for Programmed Inspections, paragraph B.1.b(1)(e)1, or as outlined in paragraph XII., above.
           
       2. All establishments on the FEDTARG primary inspection list must be inspected unless, in view of resource considerations, the Regional Administrator has received special approval (generally in advance) from the Assistant Secretary. The rationale for the reduction should be documented according to paragraph XII.B., above.
           
       3. Secondary inspection cycles do not have to be completed before the expiration of this Notice. However, if a cycle has been started, all sites must be inspected prior to initiating inspections under a new year's federal agency targeting inspection program.
           
       4. Area Offices will continue to conduct other programmed inspections under the National Emphasis Program (NEP) or the Local Emphasis Program (LEP) initiatives, as the Area Office and Regional goals dictate.
           
    5. Security Clearance.
       
       In general, the CSHO is not required to obtain a security clearance prior to entering a federal agency to conduct a FEDTARG inspection. However, given the security concerns of some federal departments, the CSHO may be required to obtain a specific security clearance(s) for the federal agency being inspected. This requirement may necessitate special planning by the Area Office and, in some cases, may delay the opening of the inspection.
        
13. Deletions.
    
    Area Offices will be responsible for making appropriate deletions from the inspection list as indicated below.
     
    1. Previous Inspections. Only establishments that received a comprehensive safety inspection within the previous 24 months prior to the creation of the current inspection cycle will be deleted from the inspection list. This timeframe will be calculated using the previous inspection's opening conference date.
        
    2. OSHA Strategic Partnership (OSP). If an establishment is participating in an OSP, it may be deleted from the inspection list if it meets the terms outlined in CSP 03-02-002, paragraph XIV.B.5.a.i., and paragraph XIII.A., above.
       
       In accord with CSP 03-02-002, paragraph XIV.B.5.a.ii., the Area Director, with the approval of the Regional Administrator, may extend the deletion of an establishment from the inspection list for another year if the partner continues to meet the conditions of the partnership agreement and demonstrates improved performance in areas measured by the partnership.
        
    3. Voluntary Protection Programs (VPP). If the establishment is an approved VPP participant, it is to be deleted from the inspection list. See CSP 03-01-003
        
14. Inspection Procedures.
     
    1. Scope. Inspections conducted under FEDTARG will be comprehensive safety inspections. Health inspections (comprehensive or partial) will be limited to CSHO referrals and Area Director discretion based on industry experience or the history of the individual establishment. Ergonomic hazards will be addressed in consultation with the Regional ergonomics coordinator.
       
       When an Area Director orders a health inspection (comprehensive or partial) at an establishment, the Area Director must document his/her rationale for the inspection. If an Area Director orders a health inspection at an establishment based on experience or knowledge concerning an industry, similar health inspections must also be considered at all other establishments within that industry classification that are on the Area Office's Federal Agency Targeting Inspection Program List. The Area Director also has the discretion to initiate a health inspection based solely on individual establishment criteria or history. Inspections will be conducted in accord with the procedures described in CPL 02-00-148 and other guidance documents.
       
       Where the CSHO observes contractors performing other work, such as construction or maintenance activity that is not being supervised by the site's federal agency, the CSHO may open another inspection if he/she observes hazards. The inspection will be expanded to include resident contractors providing services such as security, food service, or housekeeping only when the CSHO observes obvious hazards that need to be addressed.
       
       An inspection at any partnership site will normally be a comprehensive safety inspection. However, if the establishment has undergone a necessary on-site non-enforcement verification inspection, a limited scope inspection may be conducted in accord with CSP 03-02-002, paragraph XIV.B.4. See paragraph XII.C., Deferrals, above. The justification for any limited scope inspection must be documented in the file.
        
    2. Notices of Unsafe or Unhealthful Working Conditions. Notices will be issued in accord with 29 CFR 1960.26 and CPL 02-00-148.
        
    3. Recordkeeping Violations. Whenever the CSHO identifies OSHA recordkeeping violations, OSHA will propose the appropriate notices and provide supporting documentation, in accord with the policies and procedures found in CPL 02-00-135 and CPL 02-00-148 or successors.
        
    4. Compliance Safety and Health Officers (CSHOs).
       
       When the Area Director has authorized a health inspection in conjunction with a safety inspection, the safety and health inspections may be conducted as:
        
       • One combined safety and health inspection by a cross-trained CSHO (as established through specific training or demonstrated ability), or
       • Separate safety and health inspections, or
       • Joint safety and health inspections.
          
       1. Joint Safety and Health Inspection. If the inspection is a joint inspection, conducted by both a safety CSHO and a health CSHO, there will be two OSHA-1 Forms. The two 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 FEDTARG inspection plan. If the inspection is conducted by a cross-trained CSHO, there will be one OSHA-1 Form and one opening conference date.
           
       2. FEDTARG Compliance Safety and Health Officer Checklist. Refer to Appendix A of this Notice for a checklist of items that CSHOs need to accomplish during FEDTARG inspections.
           
15. Relationship to Other Programs.
     
    1. Unprogrammed Inspections. Unprogrammed inspections will be conducted according to CPL 02-00-148 and/or other OSHA policies and procedures. If the occasion for an unprogrammed inspection arises, such as a complaint or fatality, with respect to an establishment that is also in the current inspection cycle under the current FEDTARG inspection list, the two inspections may be conducted either concurrently or separately. See also paragraph XVI.B. of this Notice.
        
    2. Special Emphasis Program Inspections. Some establishments may be selected for inspection under the current FEDTARG inspection list and also under one or more other OSHA initiatives (NEP or LEP). Programs based on particular hazards, such as silica, lead, amputations, etc., or on particular industries, can be run concurrently with the current FEDTARG inspection list. CSHOs will apply all applicable IMIS codes to the inspection. See also paragraph XVI.C. of this Notice.
        
    3. Inspections under Both FEDTARG and NEP/LEP. In the case of an establishment scheduled for inspection under both FEDTARG and a NEP/LEP, the CSHO may conduct an inspection limited in scope to the safety and health issues targeted by the NEP/LEP program if, after reviewing the OSHA-300 Logs, the CSHO determines that the particular NEP/LEP addresses the serious hazards. Justification for the limited scope inspection must be documented in the file.
        
16. Recording and Tracking.
     
    1. FEDTARG11-Only Inspections. The OSHA-1 Form must be marked as "programmed planned" in Item 24. In addition, the "NEP" box is to be checked and the value "FEDTARG11" recorded in Item 25d.
       
       NOTE 1:    The FEDTARG11 inspections are being coded under the NEP for ease of tracking.
       
       NOTE 2:    Health inspections conducted in accord with this Notice are to be coded as
                       FEDTARG11 inspections.
        
    2. FEDTARG11-Combined with Unprogrammed Inspections. For all unprogrammed inspections conducted in conjunction with a FEDTARG11 inspection, the OSHA-1 Forms must be marked as "unprogrammed" in Item 24 with the appropriate unprogrammed activity identified. In addition, the "NEP" box is to be checked and the value "FEDTARG11" recorded in Item 25d.
        
    3. FEDTARG11-Combined with NEP or LEP Inspections. For all programmed inspections, such as NEPs and LEPs, conducted in conjunction with a FEDTARG 11 inspection, the OSHA-1 Forms must be marked as "programmed planned" in Item 24. In addition, the "NEP" box is to be checked and the value "FEDTARG 11" recorded in Item 25d along with all NEP and LEP IMIS codes applicable to the inspection.
        
    4. FEDTARG11-Combined with Unprogrammed and Other Programmed Inspections. If a FEDTARG11 inspection is combined with an unprogrammed inspection, such as an inspection generated through a complaint, and a programmed inspection, such as a NEP or LEP, then Item 24 must be marked "unprogrammed."
        
    5. Strategic Management Plan. Enter all applicable Strategic Management Plan hazard/industry codes in Item 25f. Some examples of entries may include amputations, ergonomics, lead and silica.
       
       
        

APPENDIX A

FEDTARG
Compliance Safety and Health Officer Checklist

VPP sites

If the CSHO discovers that the establishment is a Voluntary Protection Programs (VPP) Merit or Star site, exit the site without conducting an inspection. These sites must be deleted from the inspection list. See paragraph XIII.C. of this Notice.

If an establishment is a VPP applicant, and a VPP on-site review is scheduled within the next 75 calendar days, programmed inspections will be deferred. See paragraph XII.C.2. of this Notice.

Strategic Partnership Sites

If the CSHO discovers that the establishment is a participant in OSHA's Strategic Partnership Program and has a signed agreement, the site may be deferred for up to six months from the date of the partnership agreement or from the establishment's subsequent entry into the partnership. Check with the Area Director for further guidance. See paragraph XII.C.1. of this Notice, and CSP 03-02-002, paragraph XIV.B.3.

If the establishment is a participant in the OSHA Strategic Partnership Program, the inspection may be of limited scope if the establishment has had an on-site non-enforcement verification inspection. See CSP 03-02-002, paragraph XIV.B.4.

IMIS

Enter Agency Code

      Use the "F7" search feature to locate the appropriate code.

Enter Inspection Type

      For FEDTARG11-Only Inspections = Programmed Planned

      For FEDTARG11-Combined with Unprogrammed Inspections = Unprogrammed

      For FEDTARG11-Combined with LEP Inspections = Programmed Planned

      For FEDTARG11-Combined with Unprogrammed and Other Programmed = Unprogrammed

Enter Inspection Classification

      Inspection classification:    NEP = "FEDTARG11"

Enter all applicable NEP and LEP Program codes

      In Item(s) 25c and 25d when a federal agency targeting inspection was conducted
      and the inspection also meets the protocol for other program(s).

Enter all applicable Strategic Management Plan hazard/industry codes

      In Item 25f, (such as amputations, ergonomics, lead and silica).