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- IDENTIFICATION OF PARTNERS
This strategic partnership will heighten the visibility of OSHA at Structure
Tone Organization (STO) projects, as well as continue to nurture a cooperative
relationship. The partners in this program include:
Participants will also include Structure Tone subcontractors while performing
work at the projects listed in Appendix A.
- Structure Tone Organization (STO) companies:
Structure Tone, Inc. / Affiliate Companies
Pavarini (NE), Inc.
Pavarini (SE), Inc.
Constructors and Associates, Inc.
- The Occupational Safety and Health Administration (OSHA)
- PURPOSE AND SCOPE
The hazards associated with the construction industry are well documented. These
hazards increase in complexity in typical multi-story or large complex interior
renovation type projects. The Structure Tone organization (STO) supports the
efforts of OSHA towards the reduction and/or elimination of these hazards and
recognizes the importance and value of leadership commitment in this regard. To
facilitate OSHA's goal of reducing occupational-related fatalities and serious
injuries in the construction industry, OSHA and STO agree to the joint
implementation of this partnership at all projects named in Appendix A.
The Structure Tone organization is a worldwide construction services leader
delivering a wide range of projects on time, within budget at the highest levels
of safety and quality. With over 1,450 construction professionals on staff in
offices throughout the United States and abroad, Structure Tone provides its
clients with a uniform standard of performance and quality regardless of a
project's location. Primary projects include but not limited to core and shell
base building, mission critical data centers, education facilities and financial
institutions. These projects typically impact hundreds of sub-contractors and
thousands of workers annually.
- GOAL, STRATEGIES AND MEASURES
Through this partnership, STO will strive to reduce injuries and illnesses for
STO and subcontractor employees at participating project sites through the
effective implementation and use of a safety and health management system (SHMS)*.
- Reduce Total Case Incidence Rate (TCIR) and Days
Away Restricted, Transfer Case Incidence Rate (DART) by 3% each year.
- Develop a system to track and address incidences related to falls, electrical, caught-between
and struck by hazards.
- Implement a SHMS consistent with Appendix B.
NOTE: STO will utilize 2007 year-to-date data as initial baseline for
- Total employers and employees hours (STO and subs).
- Total case injury and illness rates.
- % of participating sites with an effective SHMS based on criteria in Appendix B.
- Improve SHMS for sub- contractors at partner sites
- Develop criteria for a model contractor SHMS
- Provide safety and health training and educational materials to all on-site contractors.
- Number/% of contract employees trained.
- Number of training sessions per site.
- Total training hours per site.
- Number/% of subs (per project) that implemented or improved their SHMS.
- Develop safety and health outreach tools and/or hazard awareness material for Hispanic
- Develop tools to include but not limited to: bi-lingual project signage, bi-lingual
orientation, bi-lingual tool box talks and subcontractor support utilizing bi-lingual foreman and
- Number of training sessions in Spanish.
- Total training hours in Spanish.
- Summary of training evaluations prepared by sub contractors.
- PARTNERSHIP EVALUATION
An annual evaluation will be conducted by OSHA, with input from its partners, to
assess progress toward the partnership goals. The evaluation shall be conducted
on the anniversary date of the signing, and will address the goals, strategies,
and measures listed in Section 3. The evaluation will be consistent with the
latest annual partnership evaluation format provided in Appendix C of the OSPP
Directive, CSP 03-02-002.
- PARTNERSHIP BENEFITS
OSHA will provide benefits to STO and participating subcontractors for worked
performed where STO has control over the work environment, i.e., STO serving as
the general contractor. Work performed at projects listed in Appendix A that
receive an OSHA onsite enforcement verification will receive the following
- In an instance where a citation is issued and when calculating initial
penalty reduction, OSHA may provide an additional 10% reduction for good faith
beyond the reductions provided in the FIRM where STO, in implementing the OSP,
has taken specific significant steps beyond those provided in the FIRM to
implement the Act and achieve a high level of employee protection (see FIRM,
Chapter IV.C.2.i.5 [b]). This additional reduction will not apply to high
gravity serious, willful, failure to abate or repeat citations. In cases where
STO's total penalty reduction is 100 percent or more, the minimum penalty
provisions of the FIRM will apply (see FIRM, Chapter IV.C.2.b).
- Upon completion of a comprehensive OSHA onsite enforcement verification
visit, the STO projects listed in Appendix A may be deleted from the
programmed inspection list for up to one year. This deletion from inspection
will not apply to work at projects not specifically identified in the
- Technical assistance and guidance as resources allow.
- Project sites listed in Appendix A will be given priority consideration
for technical assistance and guidance as resources allow.
- VERIFICATION AND OSHA INSPECTIONS
Onsite Enforcement Verification
For those project sites listed in Appendix A, the appropriate OSHA Area Office
will conduct an inspection of each participating project in an enforcement
capacity and may issue citations and penalties. Enforcement inspections are
performed in accordance with the applicable sections of the FIRM. In addition to
traditional enforcement issues, the inspection should assess the partner's
progress in meeting the requirements of the Partnership agreement. During
verification enforcement inspections, OSHA will follow the guidelines for a
focused inspection as found in the "Guidance to Compliance Officers for Focused
Inspections" of August 22, 1994 and Revision 2 of September 20, 1995.
As resources allow, OSHA will attempt to conduct enforcement verification
inspections within 90 days of the effective date of this Partnership Agreement
and annually thereafter.
Projects considered for offsite verification visits will be performed by the
local OSHA Area Office, at their discretion, through the Partnership Management
Team (PMT). Without actual entry to the worksite, offsite verification will
include a review of partnership data, reports, and records. Documentation will
be reviewed to determine whether partners are implementing the provisions of the
Partnership agreement. The documentation for review will be selected by the PMT
and will relate to the goals, objectives and stated measures of the agreement.
Examples include injury and illness data, training course agendas and rosters,
results of surveys, or results of self-audits. This review will be conducted to
coincide with the annual partnership evaluation (Section 4).
OSHA Unprogrammed Activities
This Partnership Agreement does not diminish OSHA's authority to conduct
unprogrammed inspections of fatalities, catastrophes, complaints or referrals.
If citations are issued as a result of an inspection, OSHA may conduct a
follow-up to verify abatement.
- PARTNERSHIP MANAGEMENT
A Partnership Management Team (PMT) will be formed to facilitate the direction
and management of the Partnership. The PMT will consist of the following STO and
Other representatives may be asked to participate as needed to provide
- OSHA National Office representation from the Directorates of Cooperative
and State Programs and Construction
- OSHA Regional and/or Area Office staff
- STO corporate and field representatives
The PMT will perform a variety of activities to facilitate the success of the
Prior to enrolling a new project into the partnership:
- Determine Partnership procedures
- Hold quarterly conference calls
- Track, analyze, and share information on Partnership activities and
- Meet at least annually to jointly evaluate the effectiveness of the
Partnership. The evaluation will be due annually on the effective date of the
Partnership, and will follow the written format listed in the OSHA Directive
on Strategic Partnerships, Appendix C
- Add future participant sites with at least 12-months remaining before
- Ensure that issues and concerns, as well as best practices and successes,
are appropriately communicated
- Notify the National OSHA Office and the Partnership Implementation Team of
an upcoming construction project.
- Review subcontractors' safety and health plans/program.
- Document subcontractors' safety / designated competent person.
- Inform subcontractors of the OSHA Strategic Partnership.
- Inform all subcontractors of the project safety and health management
system requirements, roles, and responsibilities.
- For project sites listed in Appendix A, the appropriate Area Office will
conduct an onsite enforcement verification inspection and will provide
resources, when available.
- For project considered for offsite verification (to be determined
locally), the appropriate Area Office will conduct an initial "Meet and Greet"
via conference call where no prior contact with the site has been made;
participate, as needed and as resources allow, in initial site safety and
- The Area Office will communicate any issues or concerns with the
Partnership Management Team for quick resolution.
- ROLES AND RESPONSIBILITIES
- Provide technical assistance, including interpretations of OSHA standards,
both on and off site, as resources allow, in reviewing the STO site-specific
safety and health management system.
- Help identify, through the review of OSHA 300 data and/or site accident
reports, the primary causal factors in injuries and illnesses, in particular
the four top hazards and provide technical assistance as required to assist in
the hazard correction.
- Provide access to training, as resources allow, including available OSHA
Training Institute Courses and information on other available sources for
- Participate in STO training sessions and meetings, as resources allow.
- Provide, as required and available, outreach information and assistance
during initial implementation, as resources allow.
- Take steps to ensure OSHA staff who conduct inspections of partnership
sites are familiar with the terms and scope of this Partnership.
- Promote the partnership and recognize successful completion of milestones
Contractually Obligated Participating Subcontractors will:
- Provide OSHA with opportunities to announce and publicize agency
information related to construction safety and health.
- Prepare a monthly safety report that will include information as outlined
in the partnership goals, strategies, and measures. Results will be forwarded
to OSHA on a quarterly basis.
- Ensure that each participating project is staffed with a safety and health
representative that will also be the primary partnership contact for that
project. This individual shall ensure that the site is following the
requirements of the partnership agreement.
- Ensure that project-specific safety and health orientation training is
given to employees and new hires to fit each subcontractor's particular
circumstances and situations. Appropriate training will also be provided to
all supervisors to ensure proper implementation of the project(s) safety and
health management system.
- Document evaluations and provide to OSHA upon request.
- Provide leadership, guidance and a positive example to subcontractors, and
- Encourage employee involvement in the day-to-day implementation of work
site safety and health programs through the project safety and health
- Conduct and document safety and health training by, or under the direction
of, a competent or qualified person. Training will integrate safety and health
requirements with upcoming tasks. This shall be accomplished through "toolbox"
meetings and "Job Safety Hazard Analysis" (JSHA).
- Periodically assess the results of training conducted to ensure
- Where workers do not speak English, provide training in the language
understood by the worker.
- EMPLOYER AND EMPLOYEE RIGHTS
This partnership does not preclude employees and/or employers from exercising
any rights provided under the OSH Act, nor does it abrogate any responsibility
to comply with rules and regulations adopted pursuant to the Act.
This partnership agreement fully endorses and recognizes the value of employee
participation. The opportunity for employees to exercise their rights, which are
guaranteed under the OSH Act, will not be infringed upon by this partnership
- TERM OF AGREEMENT
This Agreement will terminate on February 19, 2010, which is two years from the
date of the signing. If either STO or OSHA withdraws their participation in this
partnership prior to the established termination date, written notice of the
intent to withdraw must be provided to the other signatories and the agreement
OSHA may also terminate an individual partnership project participation at any
time with written notice to both the site and STO. Additionally, the project may
withdraw their participation from the partnership at any time with a written
notice to OSHA of the intent to withdraw.
Signed this day, February 19, 2008
Name: Edwin G.
Title: Assistant Secretary
Name: Robert Mullen
Title: CEO, Structure Tone, Inc.
Amended / Approved 11/17/08
|Appendix A: Participating STO Sites
||Name of Project
|Structure Tone, Bos
||Bank of America
|Structure Tone, NY
|Pavarini (SE), Fla.
|| January, 2008
|Pavarini (SE), Fla.
||State School QQQ-1
||Bank of America (Data)
Each participating STO partnership project site will develop and/or implement a
safety and health management system, following the requirements of 29 CFR 1926 as well as the OSHA 1989
Safety and Health Program Management Guidelines. Additional STO safety management requirements will be
followed and include:
| Appendix B: SAFETY AND HEALTH MANAGEMENT SYSTEM
- A fall protection program will be implemented for employees exposed to fall hazards greater
than six (6) feet above the lower level. However, exceptions may be made by STO when standards
- The use of GFCI's will be mandatory on all line-voltage electric tools and equipment.
- A site specific emergency action plan shall be developed for each participating partnership
project. Periodic drills may be conducted to assure that the plan is effective.
- STO shall develop a comprehensive Safety and Health Management System which assures the
dedication of adequate resources. The System shall contain hazard control programs, adopt the
hierarchy of controls and stress the evaluation and use of engineering and administrative controls
to control worksite hazards.
- STO will appoint a safety representative at partnership projects.
- STO will evaluate subcontractor safety and health performance prior to selection and
periodically while on project sites to ensure that they meet established criteria. Each
subcontractor will provide STO with their records of occupational injury and illness. Each
subcontractor will comply with the Safety and Health Management System. Within 30 days of entering
the Partnership, each project will conduct a meeting with all subcontractors to explain
performance expectations and assure commitment. OSHA will be invited to attend this meeting.
Positive reinforcement and assistance will be provided if a subcontractor is found to be
deficient. STO and OSHA will provide resources as necessary and available to assist subcontractors
with safety and health issues.
- At the end of each project phase, or not less frequent than annually, STO shall compile a
report that audits and measures the successes of the Safety and Health Management System, makes
recommendations and documents opportunities for improvement.