I. BACKGROUND
It is the responsibility of management to provide safe working conditions in
all present and future installations and to develop a safe working force, and
for the Unions to cooperate with and assist management to live up to this
responsibility. The United States Postal Service (USPS), National Postal Mail
Handlers Union (NPMHU), and American Postal Workers Union, AFL-CIO (APWU)
recognize the importance of reducing musculoskeletal disorders (MSDs). It is
agreed that entering into an Ergonomic Partnership (ESP) process with the
Occupational Safety and Health Administration (OSHA), the United States Postal
Service, National Postal Mail Handlers Union, and the American Postal Workers
Union, AFL-CIO will enhance ergonomic controls at USPS facilities.
II. GOALS AND OBJECTIVES
The USPS, NPMHU, APWU, and OSHA will work cooperatively to implement an
ongoing process to identify MSDs early, and control the risk factors that can
cause injuries and illnesses to postal employees. To accomplish this will
require management, unions, and OSHA to have meaningful involvement and
participation in the process. Under the direction of the national USPS/NPMHU
Joint Labor-Management Safety Committee and the USPS/APWU Joint
Labor-Management Ergonomic Committee, the Unions at the national level will
evaluate and make recommendations on all aspects of the ESP process to include
program adequacy, field implementation, training and unsafe conditions.
Specifically, the ESP process is designed to accomplish the following goals at
participating USPS worksites:
- Improve the safety and health environment so that OSHA, USPS, NPMHU, and
APWU can work together to reduce MSDs.
- Identify tasks and conditions where MSD incidents occur and develop and
implement ergonomic control processes to reduce or eliminate MSD
incidents.
- Train USPS local managers, supervisors, NPMHU and APWU representatives,
and the local Joint Labor-Management Safety and Health Committees to
ensure comprehension of ergonomic risks and control processes.
- Reduce the number of MSD related incidents thereby reducing the number
of days away from work for both lost workday and restricted duty cases
associated with MSD incidents.
- Develop and evaluate best proven practices to be implemented in other
postal facilities with similar ergonomic issues. Share best proven
practices with applicable USPS operations with similar ergonomic issues.
- Train local employees as appropriate to participate in the ergonomic
risk reduction process.
III. STRATEGIES FOR ATTAINING GOALS
USPS, NPMHU, APWU and OSHA will work in concert employing the following
strategies to achieve the aforementioned goals:
- Establish a national Ergonomic Work Group (EWG) consisting of USPS,
Joint USPS/NPMHU Labor-Management Ergonomic committee, and OSHA
representatives to ensure the consistent implementation and evaluation of
the ESP process.
- To the extent possible, identify one or more sites in each of OSHA's 10
regions covering USPS's 9 areas to participate in the ESP process. The
goal in calendar year 2003 is to start an ergonomics process in 30 sites.
The process will be tested in 10 sites to start. Expansion to additional
sites will be discussed and recommendations made by the USPS/APWU Joint
Labor-Management Ergonomic Committee and the national Joint USPS/NPMHU
Labor-Management Safety Committee. OSHA representative(s) may attend this
meeting.
- As resources allow, OSHA will assist in the implementation of the ESP
process through a variety of means including:
- Technical ergonomic assistance
- On-site support to ensure continued success of ESP process efforts
- Participation in joint safety and health committee meetings
- Participation in training
- Identification of mentoring resources
- Participation on the Ergonomic Work Group
- Participating sites through their respective local Joint
Labor-Management Safety and Health Committees will identify and prioritize
work activities for the development and implementation of ergonomic
control processes to include:
- Management Leadership
- NPMHU and APWU Representative/Employee Participation
- Job Hazard Analysis
- Hazard Prevention and Control
- Training
- Program Evaluation
- USPS, NPMHU (National USPS/NPMHU Joint Labor-Management Ergonomic
Committee) will identify and make available best proven practices to be
shared with other Postal Service facilities with similar risk in a timely
manner.
- USPS, APWU, and NPMHU will provide OSHA with best practices that have
universal application. OSHA may share such information with like
industries.
IV. INCENTIVES
OSHA will offer the following incentives for USPS worksites participating in
the ESP process:
- As resources allow, provide priority on-site ergonomic technical
assistance to assist and advise on specific issues.
- Maximum allowable penalty reduction for ergonomic and other violations
abated in a timely manner, as allowed by OSHA's Field Inspection Reference
Manual (FIRM).
- 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.
- Twelve 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).
- Opportunities to identify mentors from VPP sites that have effective
ergonomic programs.
- OSHA recognition for partnership activities and successes.
V. ESP PROCESS OVERSIGHT
- A national Ergonomic Work Group (EWG) will be formed to facilitate the
implementation and management of the ESP process.
- The EWG will, at a minimum, include up to the number of
representatives from each of the following organizations/offices as
identified below:
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- USPS National Office
- NPMHU National Office
- APWU National Office
- OSHA
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six
three
three
three |
- The EWG will be responsible for:
- Monitoring the ESP process and resolving issues
- Determining the appropriate ESP process measurements
- Receiving and evaluating ESP process data from participating
sites.
- Preparing a written annual evaluation of the ESP process
- The EWG will meet at least semi-annually. The first meeting will be
held within 60 days of agreement signing. In addition, conference
calls may be held as necessary, but at least quarterly.
- Teams will be established for each participating site to facilitate the
progress of the ESP process, to provide an onsite presence at the initial
site implementation, as well as enhance communication between the USPS,
NPHMU, APWU, and OSHA at the local and national levels.
The teams will consist of the following:
- OSHA regional or area office staff representative(s)
- A national representative from each Union
- USPS national representative
VI. MEASUREMENT AND EVALUATION SYSTEM
The EWG will develop and implement appropriate procedures to measure the
progress of the ESP process in terms of meeting its goals. At a minimum,
baseline data will be developed and the following will be evaluated:
- Measures of MSD injury/illness cases at participating sites
- Extent of local joint safety and health committee participation in the
ESP process
- To the extent possible, employees perceptions of the ESP process' impact
on worker safety and health
- Measures of incidence and severity criteria (in comparison with the
baseline numbers)
- Number of managers and employees trained
- Number of best practices shared
- Number of tasks reviewed and correction(s) implemented
These factors and other appropriate information will be provided by the
USPS and presented at the semi-annual EWG meetings for review and comment. In
addition, the EWG will prepare annual ESP process evaluations. The annual
evaluations will be subject to review and discussion by EWG representatives
prior to their publication.
VII. VERIFICATION
Verification of good faith by the participants will be effected through both
off-site and on-site methods.
- Data compiled and reviewed semi-annually by the EWG will be the basis
for off-site verification.
- On-site verification will involve on-site evaluations performed by the
EWG or their representatives. At least two onsite evaluations will be
conducted jointly each year. OSHA will conduct at least two independent
on-site ESP process evaluations.
On-site verification visits will be conducted in accordance with OSHA's
Training and Education Directive (TED) 8.01, OSHA Strategic Partnership
Program.
VII. EMPLOYEE RIGHTS
Nothing in this agreement shall be construed to preclude bargaining unit
employees from exercising any right provided under the OSH 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.
This ESP agreement does not supersede or modify the current National
Agreements and supplements thereto between the US Postal Service and the
Unions.
IX. ENFORCEMENT
Participating USPS sites will remain subject to OSHA enforcement inspections
and sanctions except as specified under Section IV (Incentives) of this
agreement. OSHA will give appropriate consideration to any USPS sites that
have implemented effective ergonomic processes or that are making good faith
efforts to reduce ergonomic hazards.
X. TERM OF AGREEMENT
This agreement will be in effect for a period of three (3) years from the date
of signing. The agreement may be renewed by mutual agreement of all parties.
XI. TERMINATION
Any party to this agreement may, with 30 day written notice to the other
parties, withdraw from the partnership.
SIGNATORIES
___________________________________
John E. Potter
Postmaster General, CEO
United States Postal Service
___________________________________
John L. Henshaw
Assistant Secretary
Occupational Safety and Health Administration
___________________________________
William Burrus
President
American Postal Workers Union, AFL-CIO
___________________________________
John F. Hegarty
National President
National Postal Mail Handlers Union, A Division of Laborers' International
Union of
North America, AFL-CIO
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