OSHA Strategic Partnership Program > Johnson and Johnson

OVERVIEW

This OSHA Strategic Partnership (OSP) is entered into by the United States Department of Labor, Occupational Safety and Health Administration (OSHA), and Johnson & Johnson (J&J). Additional partners from State Plan States may sign onto the partnership through addendum agreements.

The OSP will serve as a roadmap to help achieve OSHA’s and J&J’s common goal – the enhancement of occupational safety and health for J&J and America’s employees. The major focus of the OSP is the reduction in incidence and severity of musculoskeletal disorders (MSD’s). The OSP is consistent with J&J’s corporate goal to effect injury and illness free workplaces.
SCOPE OF PARTNERSHIP AGREEMENT

This Partnership will initially cover the J&J operating company facilities identified in Attachment I. The intent of the agreement is to eventually cover all of the J&J operating company facilities in the United States, including facilities in Puerto Rico.
PURPOSE OF PARTNERSHIP

This OSP is formed to establish a cooperative effort to develop policies, practices, and processes designed to reduce the incidence and severity of musculoskeletal disorders (MSDs) that are associated with the performance of work tasks posing ergonomic risk factors. J&J enters this OSP to work with OSHA to identify best practices for the development and implementation of successful ergonomics programs and guidelines. These best practices will be shared among all J&J facilities, employers and employees in related industries and with the public as appropriate.
GOALS OF THE PARTNERSHIP

The OSP is designed to achieve four primary goals:
1. to identify and communicate an effective process (guide) to develop and implement successful ergonomics programs/guidelines;
2. to identify at least three J&J ergonomic best practices and related training materials in each of the following three J&J divisions: pharmaceutical, medical devices and consumer goods.
3. to reduce the incidence and severity of MSDs at J&J operating company facilities; and
4. to share J&J best practices in ergonomics with other J&J facilities, like industries and the public.
STRATEGIES FOR ATTAINING GOALS
1. J&J will develop a written process to address ergonomic hazards in the workplace. The process will cover management commitment and employee involvement; worksite analysis; hazard prevention and control and training. Specifically, the process will include:
  1. methods used to identify problem jobs that result in MSD’s;
  2. methods used to identify control measures for substantially reducing or eliminating ergonomic risk factors associated with work tasks;
  3. successful training techniques and materials;
  4. methods for management to demonstrate commitment;
  5. methods for employee involvement; and
  6. methods or criteria for measuring success.
2. OSHA and J&J will review J&J injury/illness data and other related data to
  identify at least three best practices performed to control ergonomic hazards in
  the following three J&J divisions: pharmaceutical, medical devices and consumer goods. Based on the best practices, J&J will develop/share related training techniques and materials for use in communicating best practices to employers and employees as appropriate.
3. OSHA will cooperate with J&J in developing an ergonomic protocol to assist J&J in assessing its compliance with General Duty Clause requirements.
4. OSHA, with assistance from J&J, will communicate the best practices
  identified in this section through Compliance Assistance tools (e.g., e-tools),
  training (e.g., OTI and Education Center courses), and programs (e.g.,
  Consultation and mentoring). OSHA and J&J personnel also agree to participate
  in the communication of these best practices at safety conferences, in trade
  journals, and through any other effective means.
INCENTIVES

OSHA will offer the following incentives for participating J&J worksites:
1. As resources allow, provide priority ergonomic technical assistance to assist and advice on specific issues.
2. Maximum allowable penalty reductions for ergonomic and other violations abated in a timely manner, as allowed by OSHA’s Field Inspection Reference Manual (FIRM).
3. Six month deferral in programmed inspections at partnering sites from the date of the partnership, as provided by OSHA’s Site Specific Targeting (SST) or other targeting programs.
4. Six month deferral from OSHA programmed inspections for sites that undergo an OSHA onsite verification inspection, provided the site implements the ergonomic control methods in good faith. (Refer to Section VII - Verification).
5. Opportunities to identify mentors from VPP sites that have effective ergonomic programs.
6. OSHA recognition for partnership activities and successes.
VERIFICATION

Verification of good faith by the participants will be effected through both offsite and onsite methods.
- Data compiled and reviewed semi-annually by the Partnership Management Team (PMT) will be the basis for offsite verification.
- Onsite verification will involve onsite evaluations performed by the PMT or their representatives. At least two onsite evaluations will be conducted jointly each year.
- In addition, OSHA will conduct at least two independent verification inspections. These verification inspections will be conducted in accordance with OSHA’s Training and Education Directive (TED) 8.01, OSHA Strategic Partnership Program.
PARTNERSHIP MANAGEMENT

A Partnership Management Team (PMT) will oversee and coordinate the Partnership. The PMT will consist of persons from OSHA national and regional offices, J&J operating companies (at least one from each division), and union representation, if applicable. Plan States representatives will also participate, as appropriate. The roles and responsibilities of the PMT are as follows:
1. holding regular meetings/conference calls to ensure the OSP remains on track to meet OSP goals;
2. collecting and analyzing data, including the development of annual written OSP evaluations;
3. ensuring effective communication among the partners; and
4. resolving disagreements that arise during the course of the OSP.
MEASUREMENT OF PROGRESS

The PMT will develop appropriate criteria to measure the progress of the OSP (see Attachment II for minimum progress measures). The PMT will determine the content and frequency of written OSP progress reports to be generated by individual facilities covered by the OSP. These written reports will address, at a minimum, the identification of problem jobs, the control measures attempted and implemented and their cost, the training of affected employees, employee involvement and management commitment to the ergonomics program, and the effect of control measures in the incidence and severity of MSD cases. The OSP progress reports will be reviewed and discussed by the Implementation Team at least twice a year.

Adjustments to the ways that the OSP functions will be identified and implemented based on the reports.

The Implementation Team will also prepare annual written evaluations of the OSP consistent with the OSHA OSP Policies and Procedures document (TED 8-0.2).
CONFIDENTIALITY

J&J states that it intends to provide confidential commercial information to OSHA under this agreement of a kind not customarily made public by J&J. OSHA will protect any confidential commercial information J&J submits from public disclosure to the fullest extent permitted under the Freedom of Information Act (5 U.S.C. 552).

In the event of an OSHA inspection at a covered facility, OSHA may request any information that is relevant and normally available during such an inspection, and J&J may raise any legal objection that would normally be available in response to such a request.
EMPLOYEE AND EMPLOYER RIGHTS

Nothing in this Partnership Agreement shall be construed to preclude any J&J operating company or any J&J operating company employee from exercising any right provided under the Occupational Safety and Health Act, nor does it eliminate their responsibility to comply with any provision of the Act, or any Standard or Regulation promulgated pursuant to the Act.
TERM OF PARTNERSHIP

This Partnership shall be in effect for three (3) years from the date of signature by the partners unless J&J or OSHA notifies the other partner in writing of its intent to withdraw from the Partnership, in which case the Partnership will terminate in thirty (30) days following the receipt of such written withdrawal notice. The Partnership shall remain in effect after the initial three-year period unless either J&J or OSHA gives the other partner thirty (30) days written notice that the Partnership is terminated.

___________________________________
John L. Henshaw, Assistant Secretary
Occupational Safety and Health Administration

___________________________________
Ather Williams, Vice President, Worldwide
Safety & Industrial Hygiene
Johnson & Johnson

Attachment I

Participating Johnson & Johnson Sites

Company	City	State
Cordis USA	Warren	NJ
DePuy Orthopaedics (Joint) USA	North Brunswick	NJ
Ethicon USA	Somerville	NJ
J&J Consumer Products USA	Skillman	NJ
J&J Consumer Products USA	North Brunswick	NJ
J&J HCS USA	Piscataway	NJ
J&J Pharmaceutical R&D (PRD)	Raritan	NJ
J&J World Headquarters USA	New Brunswick	NJ
Janssen Ortho-McNeil (FDC & BDC)	Somerset	NJ
Janssen USA	Titusville	NJ
Ortho Clinical Diag USA	Raritan	NJ
Pharmaceutical Supply Group - Americas (PSGA) Raritan	Raritan	NJ
Ortho Clinical Diag USA	Rochester	NY
DePuy Orthopaedics (Joint) USA	Las Piedras	PR*
Ethicon USA	San Lorenzo	PR*
LifeScan USA	Cabo Rojo	PR*
McNeil Consumer Healthcare USA	Las Piedras	PR*
Pharmaceutical Supply Group - Americas (PSGA)/Janssen	Gurabo	PR*
Pharmaceutical Supply Group - Americas (PSGA)/OBI	Manati	PR*
Pharmaceutical Supply Group - Americas (PSGA)/OMJ	San German	PR*
Pharmaceutical Supply Group - Americas (PSGA)/OMP	Manati	PR*

* Future site, pending addendum agreement with Puerto Rico State Plan, which is administered by the Puerto Rico Occupational Safety and Health Office (PROSHO)

Attachment II

Johnson & Johnson Partnership Measurements

Goal	Strategy	Measures/Products
1) Identify and communicate an effective process to develop and implement successful ergonomic programs and guidelines	A) Develop a written process to address ergonomic hazards in the workplace.	i) Number of J&J sites where ergonomic process has been effectively implemented ii) Number of training courses/people trained in process iii) Awareness survey of employees
2) Identify at least three J&J ergonomic best practices and related training materials in the pharmaceutical, medical devices, and consumer goods divisions.	B) Review J&J data to identify at least three best practices in the pharmaceutical, medical devices and consumer goods divisions; develop/share related training techniques and materials.	iv) Identification and documentation of nine best practices and related training materials
3) Reduce the incidence and severity of MSD's at participating facilities	C) Develop an ergonomic protocol to assist J&J in assessing its compliance with General Duty Clause requirements.	v) Baseline of MSD cases vi) MSD cases involving day(s) of restricted work activity vii) MSD cases involving day(s) away from work viii) The number of MSD-related surgeries, ix) An annual comparison of these incidence and severity criteria to the baseline numbers.
4) Share J&J best practices in ergonomics with other J&J facilities, like industries, and the public	D) Communicate the best practices through Compliance Assistance tools (e.g., e-tools), training (e.g., OTI and Education Center courses), and programs (e.g., Consultation and mentoring); use safety conferences, trade journals, and any other effective means.	x) Log or summary of outreach activity xi) Number of J&J sites where best practices have been implement


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