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Strategic Partnership Agreement

between the

Occupational Safety and Health Administration
Pittsburgh Area Office

and

Graycor Industrial Constructors Inc.

for

USS Clairton “C” Coke Battery Project

Partnership - An OSHA Cooperative Program
 
I. Scope/Background

To facilitate OSHA's goal of reducing occupationally related fatalities by 3% each year, and reducing the total Rate of Days Away from Work by 4% each year, Region III of the Occupational Safety and Health Administration (OSHA) and Graycor Industrial Constructors Inc. have agreed to the joint implementation of the partnership during construction of the USS Clairton ”C” Coke Battery Project. The Project consists of the construction of a new 84 oven Coke Battery and associated ancillary systems. Work includes removal of existing foundations and quench towers; installation of a new battery foundation, pusher pad, waste heat canal, stack, refractory block, control press system, collecting main, standpipes, off-takes, waste heat valves, and reversing mechanism; installation of new coal bunker bins, gates, offices, electrical room, break room, and elevator; modification to the coal conveyor system; installation of the quench system concrete and wooden tower structure; erection of the PEC emission control system consisting of erection of a new baghouse and collection duct; and installation of associated machinery.

Mobilization began October 2008. Complete turnover and commissioning is scheduled for June 2011, resulting in a scheduled duration of 33 months.

The goal of this program is to develop a contractor/government partnership that will encourage construction employers to improve their safety and health performance, assist them in doing that, strive for the elimination of serious accidents in the construction industry, and recognize those contractors/subcontractors with exemplary safety and health programs. Under the partnership, contractors/subcontractors expect that OSHA will acknowledge superior performance by providing timely responses to requests for information and requests for clarification of OSHA standards as resources allow.

This agreement between Graycor Industrial Constructors Inc. and OSHA is expected to result in decreased serious injuries and illnesses and fatalities for the site and improve existing safety and health programs. It provides incentives to construction contractors/subcontractors that voluntarily participate in the USS Clairton Coke Battery Project partnership and demonstrate implementation of effective safety and health programs, for example, opportunities for limited scope inspections and reductions in penalties. This agreement will not in any way affect employees' ability to exercise rights under the OSH Act and OSHA regulations, including walk-around rights.

Therefore, OSHA and Graycor Industrial Constructors Inc. are entering into this partnership to foster a safe and healthful workplace for employees by having joint cooperation as prescribed within the terms and conditions set forth in this agreement.

II. Identification of Partners

The primary participants in this Partnership are,
  1. Occupational Safety and Health Administration, Pittsburgh Area Office (OSHA)
  2. Graycor Industrial Constructors Inc.
The following organizations pledge to support the Partnership:
  1. United States Steel Corporation (USS)
  2. Pittsburgh Regional Building Trades Council
By pledging support, the organizations agree to encourage all workers at the site to follow all safety and health regulations, policies, and procedures applicable to their work. In addition, the organizations agree to maintain open communications with the signatory partners and participate, when applicable and as resources permit, in project meetings and training.

III. Project Overview

Over the life of the project up to 10 contractors will employ approximately 600 individual construction tradespersons at peak construction. The complete work will include: site construction, concrete, excavation work, pile, foundation, and rebar installation, structural steel and miscellaneous metal work, refractory installation, electrical, mechanical/piping, roofing/siding, cranes and lifts use, fire protection, and painting.

IV. Goals, Strategies, Measures

The partnership's goal is to reduce injuries and illnesses and fatalities through a cooperative relationship between Graycor Industrial Constructors Inc. and OSHA. This goal will be accomplished by implementing and following the plan outlined below and evaluating these actions as indicated:
  1. Develop, implement and maintain effective and comprehensive safety and health programs in accordance with OSHA's 1989 Safety and Health Program Management Guidelines or its equivalent.
     
      Graycor Industrial Constructors Inc. agrees to complete a self-audit and an evaluation of contractors/subcontractors’ safety and health programs in accordance with OSHA's 1989 Safety and Health Management Guidelines or its equivalent.

      OSHA will evaluate Graycor Industrial Constructors Inc. and contractors/subcontractors’ safety and health programs prior to and during the OSHA verification inspection using Appendix B (or equivalent) and will observe whether the safety and health management systems in place are adequately protecting employees.
       
  2. Achieve participant recordable illness and injury rates below the national average for the construction industry. A partnership goal is to keep the DART rate (cases with days away from work, job-transfer, or restriction) below the national average for the most recent year published for the construction industry as a whole which was 2.8 for the year 2007. The partnership goal is to further reduce this level of recordable injuries annually by at least 4% for the duration of the partnership.
     
      Identify and correct primary causal factors in worker injuries and illnesses.

      Establish systems to identify and correct accidents and nears misses.

      OSHA will meet at least quarterly with Graycor Industrial Constructors Inc. to examine the injury and illness experience of the partnership's participants and to make corrections and adjustments as needed.

      DART rates and injury and illness experience will be evaluated through review of the OSHA 300 log and any other relevant accident reports.
V. Statement of Agreement

OSHA agrees to:
  1. Help identify programmatic needs at this site by reviewing the documented safety and health management system and providing practical guidance for implementation. The review will be performed by the project Safety and Health Manager and an OSHA Compliance Specialist (CAS or CSHO).
  2. Help identify, through the review of OSHA 300 logs, accident or near miss reports, primary causal factors in injuries and illnesses, in particular the top hazards at this site, and recommend the appropriate corrective actions.
  3. Provide information on training resources including available OSHA Training Institute courses and information on other available sources of training.
  4. Assist partners in understanding OSHA interpretations and clarifications as to the meaning and application of OSHA standards and policy.
  5. Participate in training sessions and meetings as resources permit.
  6. Designate an experienced safety and health specialist to serve as a resource and liaison person for the partnership.
  7. Meet with Graycor Industrial Constructors Inc. quarterly to review partnership issues and to examine updated DART rates and the injury and illness experiences of its contractors/subcontractors at this site. OSHA shall provide feedback on any noted incident trends and patterns.
  8. Grant contractors/subcontractors, if participating in this partnership, a twelve-month inspection deletion from programmed inspections at this site, following a successful onsite verification inspection.
  9. Not issue penalties to participating contractors/subcontractors for other-than-serious violations, provided the violations are immediately abated.
Graycor Industrial Constructors Inc. agrees to:
  1. Serve as a safety resource in support of all of the project's contractors and subcontractors.
  2. Provide notice to all contractors and subcontractors that the USS Clairton “C” Coke Battery Project is subject to this strategic partnership with OSHA. All employees will be informed of the partnership and provided a fact sheet during orientation. (Appendix A).
  3. Administer the overall partnership program including, but not limited to, the initial contact and evaluation of contractors/subcontractors’ applications to determine whether the subcontractor meets the criteria specified within this partnership initiative under Section VI, Contractor Eligibility.
  4. Notify the Pittsburgh OSHA Area Office on a regular and recurring basis of the names of contractors/subcontractors that have met the partnership criteria.
  5. Maintain a dedicated competent Site Safety and Health Coordinator available to assist contractors and subcontractors with all safety and health issues.
  6. Act as liaison for contractors/subcontractors with OSHA.
  7. Offer on-going information on safety or health topics of importance for contractors, especially on the focused four construction hazards.
  8. Maintain a site injury and illness log of all injuries and illnesses reported by all contractors and subcontractors.
  9. Meet with OSHA quarterly to examine the injury and illness experience of the partnership's participants and to make corrections and adjustments as needed.
  10. Manage the following site safety or health issues to reduce the potential for injury or illness in accordance with this partnership agreement:
    • emergency action plan
    • hazard communication plan and inventory of site chemicals reported by contractors and subcontractors
    • fall protection plan and perimeter guards
    • personal protective equipment
Graycor Industrial Constructors Inc. and its contractors and subcontractors agree to:
  1. Apply all relevant components of their respective comprehensive safety and health programs to the USS Clairton “C” Coke Battery Project. These programs shall include:
    1. Analysis of all new and acquired work, materials, chemicals, and equipment before construction activity begins to determine potential hazards and to plan for their prevention or control.
    2. Routine examination and analysis of hazards associated with individual jobs, processes, or phases of construction.
    3. Routine self-inspections and hazard abatement.
    4. A system for project workers to notify management, without fear of retaliation, about conditions that appear hazardous.
    5. A system for investigating accidents and near-misses, including procedures for guidance, reports of findings and the tracking of hazard correction to completion.
    6. A system to analyze trends through a review of site injury and illness data, and the hazards identified through inspections so that patterns of common causes can be identified and eliminated.
  2. Comply with all current OSHA standards.
  3. Comply with the current U.S. Steel Contractor Safety Standard Specification No. S-001.
  4. Implement and enforce a 4 foot fall protection policy.
  5. Implement an effective Drug and Alcohol Substance Abuse Program.
  6. Have supervisors provide visible leadership in implementing the safety and health program. This includes:
    1. Supervisors establishing clear lines of communication with project workers.
    2. Supervisors setting an example of safe and healthful behavior.
    3. Creating an environment that allows project workers access to their top management and for contractor management to have access to the prime contractor's management, and;
  7. Report all site injuries and illnesses to Graycor Industrial Constructors Inc. immediately so that the site injury and illness log may be accurately maintained.
  8. Reporting all site safety and health deficiencies, including but not limited to site fall protection, immediately upon discovery and taking appropriate protective measures for protection of their employees. These reports would be processed by the Graycor site Safety Manager.
  9. Contractors and subcontractors will submit to Graycor Industrial Constructors Inc., initial and updated records of their site recordable injuries and illnesses initial, days away from work rates, restricted workdays, and the contractor's OSHA history.
  10. All contractors and subcontractors must have a person on site that is responsible for, possesses the authority over, and is capable of effectively implementing the overall site safety and health program.
  11. All contractors and subcontractors must complete a successful assessment of their site safety and health program. This assessment shall consider:
    1. the comprehensiveness of the program
    2. the degree to which it has been implemented
    3. the presence of competent persons as required by relevant standards
    4. the means by which the program is enforced
  12. Ensure that their policy and procedures hold supervisors and workers accountable for the following established safety and health rules and OSHA regulations.
  13. Ensure that employee training covers applicable site hazards and the means to correct them, as well as pertinent standards and regulations.
  14. Ensure that within one year after obtaining acceptance into this partnership program that a designated safety representative or other person serving in the capacity as a competent person on the project will have completed the OSHA 30-hour course for the construction industry (or its equivalent).
VI. Contractor Eligibility

Contractors/subcontractors wishing to take advantage of this opportunity to partner with OSHA must:
  1. Sign a letter of agreement with Graycor Industrial Constructors Inc. indicating their intent to participate in this partnership initiative and to take steps to adopt into their safety program all of the provisions of the partnership agreement, Appendix C.
  2. Verify that a comprehensive written safety and health program exists or will be implemented within 30 days of signing which is based on the OSHA 1989 Safety and Health Program Management Guidelines (or their equivalent), and has site specific safety plans for all of the contractor's work sites.
  3. Certify that their company has not been cited by the Pittsburgh OSHA office within the past three (3) years for alleged violations classified as “willful” or “failure to abate”. (See Appendix C, Letter of Intent to Participate in Safety Partnership).
  4. Ensure that their policy and procedures hold supervisors and workers accountable for established safety rules and OSHA regulations.
  5. Provide the level of training required by OSHA regulations to their workers either through their own training personnel or other consultants or trainers.
  6. Ensure that as soon as possible, but not longer than one year after obtaining acceptance into this partnership program, all supervisory personnel or other personnel serving in the capacity of competent person will have completed the OSHA 30-hour course for the construction industry (or its equivalent). Records of training certification will be provided to Graycor Industrial Constructors Inc. and made available for review.
  7. Provide periodic safety-related statistics (man hours worked, lost workday injuries, accident records and OSHA inspection results). Graycor Industrial Constructors Inc. is to provide a summary and analysis for review by OSHA to track the progress of the partnership in meeting its goals to reduce injury and illness rates and to prepare an annual report to evaluate the merits of the partnership.
VII. On-Site Verification Inspection and Benefits
  1. Verification

    In order to assist in measuring the success of this partnership, an initial enforcement verification inspection will be conducted after the signing of this agreement, and annually thereafter. The onsite enforcement verification may be conducted as a focused inspection if the site meets the criteria outlined in OSHA's current enforcement guidelines (See OSHA Memorandum on the Focused Inspection Initiative, September 20, 1995). Annual verification inspections will be timed to adequately evaluate employee exposure to jobsite hazards.

    The top causes of injuries and illnesses will be determined by all parties prior to and during the initial OSHA verification inspection. Corrections will be identified by all parties and implemented by Graycor Industrial Constructors Inc. Injury and illness incidence in targeted areas will be evaluated through the OSHA 300 log and any other relevant accident reports.

    Additionally, OSHA will meet with Graycor Industrial Constructors Inc. quarterly to review partnership issues and to examine updated DART rates and the injury and illness experience of Graycor Industrial Constructors Inc. and its contractors at this site. OSHA shall provide feedback on any noted incident trends and patterns.
     
  2. Benefits

    Contractors/subcontractors, if participating in this partnership, will be granted a twelve-month inspection deletion from programmed inspections at this site, following a successful onsite verification inspection.

    OSHA will not issue penalties to participating contractors/subcontractors for other-than-serious violations, provided the violations are immediately abated. OSHA reserves the right to issue penalties for regulatory violations for which mandatory penalties are established pursuant to the policy set forth in the Field Inspection Reference Manual (FIRM).

    When calculating initial penalty reductions, OSHA may provide an additional 10% penalty reduction for good faith to participating contractors/subcontractors provided they have taken steps to adopt into their safety program all of the provisions of the partnership agreement. This additional reduction will not apply to high gravity serious, willful, failure to abate or repeat citations. In cases where a contractor’s/subcontractor’s total penalty reduction is 100 percent or more, the minimum penalty provisions of OSHA's FIRM will apply.
VIII. OSHA Inspections

This partnership provides for the immediate response to each allegation of a safety or health hazard brought to its attention by any person. Upon a finding that an allegation is valid, the employer shall promptly abate the hazard.
  1. Non-formal Complaints:

    OSHA agrees that a copy of each non-formal complaint related to the work at the site and filed with OSHA will be forwarded by fax or mail to Graycor Industrial Constructors Inc. at the USS Clairton “C” Coke Battery Project site office. In accordance with applicable law, the identity of a complainant requesting confidentiality will not be revealed. Graycor Industrial Constructors Inc. agrees to investigate these complaints, regardless of the employer involved and provide OSHA with a written response as follows:
     
    • non-formal complaints/referrals alleging a hazard: 24 hours
    Failure to meet this time frame, or providing a response determined by OSHA to be inadequate, will place the complaint/referral outside the scope of this partnership and OSHA will respond as it would to any complaint of a similar nature.
     
  2. Formal Complaints and Other Investigations:

    OSHA personnel will continue to conduct investigations resulting from formal complaints, referrals, fatalities, catastrophes, other accidents or significant events. OSHA will also investigate contractors/subcontractors whose employees are exposed to or are creating plain view hazards at this partnering worksite. These investigations will be conducted outside of this partnership agreement in accordance with established OSHA enforcement policy. Violations identified during such investigations may result in the issuance of citations and penalties.
IX. Employee Rights

This Partnership does not preclude employees and/or employers from exercising any right provided under the OSH Act (or, for federal employees, 29 CFR 1960), nor does it abrogate any responsibility to comply with rules and regulations adopted pursuant to the OSH Act.

X. Leveraging

This partnership seeks to leverage the resources of both, Graycor Industrial Constructors Inc. and OSHA by encouraging contractors/subcontractors to develop safety and health programs, implement them in an effective manner, complete self inspections, and evaluate worksite conditions and near misses to prevent accidents. By combining resources, OSHA expects to have a greater and more positive impact on safe working conditions at this site than could be achieved otherwise.

XI. Evaluation

A joint evaluation of the partnership will be prepared annually by the partners using Appendix D. The evaluation will review the success of the partnership, lessons learned, and changes that will be made to meet the goals of the partnership.

XII. Termination

This agreement will terminate three years from the date of the signing or upon completion of the USS Clairton “C” Coke Battery Project. If either OSHA or Graycor Industrial Constructors Inc. wishes to withdraw its participation prior to the established termination date, the agreement will terminate upon receiving a written notice of the intent to withdraw from either signatory.

OSHA will terminate the partnership if any employer on site is issued a citation related to workplace hazards which resulted in a fatality.

Paperwork Reduction Act Notice
Form Approved
OMB# 1218-0244 Expires 01-31-2009
Public reporting burden for the time needed to develop
the Partnership requirements, craft agreement language,
and conduct an internal review process is estimated to
be an average of 11 burden hours per respondent.

XIV. Partnership Contacts

OSHA:
Robert Szymanski, Area Director, Pittsburgh OSHA Office, 412-395-4903

Graycor Industrial Constructors Inc.:

1. Jack Carlson
Director, Safety and Quality
Graycor Services LLC
708.206.3622

2. Jeff Walden
Director, Safety
Graycor Services LLC708.906.4301

3. Tony Fortuna
Safety Manager
Graycor Services LLC
412.287.9370

Signature Page: USS Steel Clairton “C” Coke Battery Project Strategic Partnership Agreement between OSHA and Graycor Industrial Constructors Inc.
 
All undersigned Parties mutually agree to the terms and conditions of this document and commencement of this Partnership Agreement on this day of January 13, 2008.



 
Robert Szymanski
Area Director
Pittsburgh Area Office
USDOL/OSHA
 


 


 
Thomas Muchesko
Senior Vice President
Graycor Industrial Constructors Inc.
 


 



 


 


 
George Welch
Project Director
Graycor Industrial Constructors Inc.
 


 
   


 
Jack Carlson
Director, Safety and Quality
Graycor Services LLC
 


 


APPENDIX A

Partnership Fact Sheet

A strategic partnership agreement has been developed jointly by the United States Department of Labor, Occupational Safety and Health Administration Pittsburgh Area Office (OSHA), and Graycor Industrial Constructors Inc. The common objective and goal of the program is to develop a contractor/government partnership that encourages all construction employers to improve their safety and health performance, assist them in doing that, strive for the elimination of serious accidents in the construction industry, and to recognize those contractors with exemplary safety and health programs. The specific impetus behind the agreement is to provide a safe and healthful work environment for workers engaged in construction activities for the project.

Expected outcomes of this partnership include: developing criteria for a model multi-employer worksite safety and health program which specifically identifies the responsibilities of each contractor/subcontractor; making safety and health materials available to all contractors/subcontractors onsite; planning for safety and health in all aspects of the project; providing visible safety and health leadership; achieving participant recordable illness and injury rates below the national average for the construction industry; and focusing OSHA enforcement activity on those contractors and subcontractors who have little or no regard for the safety and health of their workers.

The agreement provides incentives to contractors and subcontractors who voluntarily improve their safety and health performance. Incentives will include special recognition from OSHA and opportunities for focused enforcement efforts by OSHA and consideration for additional good faith penalty reductions.

This agreement is consistent with OSHA's long-range effort to develop a contractor/government partnership approach to safety management. It allows for better use of OSHA resources and for innovation in safety management, and it encourages more participation in the safety process by each stakeholder.


  
_______________________________
Robert Szymanski
Area Director
Pittsburgh Area Office
USDOL/OSHA		 ___________________________ 
Thomas Muchesko
Senior Vice President
Graycor Industrial Constructors Inc.


Appendix B

Safety and Health Program Evaluation
  1. Contractor/subcontractor has implemented a comprehensive written safety and health program based on ANSI A10.38-1991 or the OSHA 1989 Safety and Health Program Management Guidelines, and has site specific safety plans for all of the contractor's work sites.
     
  2. Contractor/subcontractor maintains a copy of its specialty contractor's safety and health plan, hazard communication plan, and enforces a fall protection policy that is consistent with this Agreement..
     
  3. Contractor/subcontractor has designated safety personnel at the project site who conduct documented safety inspections of all work on the contractor's projects, and through training and experience, can recognize hazards and have authority to take prompt corrective action. Training equivalent to the OSHA 30-Hour Construction Outreach Course is satisfactory.
     
  4. Contractor/subcontractor has trained all field supervisory personnel and has provided additional training for competent persons in such areas as scaffolding, excavation, fall protection, crane operations, etc. (This additional training will be dictated by the type and scope of the work the contractor routinely conducts).
     
  5. Contractor/subcontractor provides a safety and health program orientation for all new employees and trains employees for hazard recognition specific to the contractor's work sites.
     
  6. Contractor/subcontractor has evidence of employee involvement and participation in safety and health such as, but not limited to, participation in self-audits, site inspections, job hazard analyses, safety and health program reviews, safety training and mishap investigations.
     
  7. Contractor/subcontractor conducts and documents weekly employee safety meetings.
     
  8. Contractor/subcontractor conducts and documents self-audits.
     
  9. Contractor/subcontractor uses a four-foot fall protection policy.
     
  10. Contractor/subcontractor has a written enforcement program.
     
Appendix C

Letter of Intent to Participate in Safety Partnership


We have read the requirements to participate in the USS Clairton “C” Coke Battery Project Safety Partnership and agree with all aspects of the program, including the submission of the required information. Specifically, we recognize the need to meet the following requirements:
  1. Establishment of a written safety and health program including the following elements: management leadership, worker involvement, worksite analysis, hazard prevention and control, and safety and health training.
     
  2. Compliance with all current OSHA standards.
     
  3. Provision of visible leadership by supervisors in implementing the safety and health program including, but not limited to, having a representative complete the OSHA 30 hour construction training program.
     
  4. Planning for safety and health as part of the overall management planning process, including appropriate job hazard analyses.
     
  5. Establishment and communication of all safety and health program responsibilities to all project workers.
     
  6. Evaluation of safety and health programs at least annually.
     
  7. Reporting all site injuries and illnesses (records of site recordable injury and illness rates, days away from work rates, restricted workdays, etc.) so that a site log may be maintained.
     
  8. Reporting all site safety and health deficiencies, including but not limited to site fall protection, immediately upon discovery and taking appropriate protective measures for protection of their employees. These reports would be processed by the Graycor site Safety Manager.
     
  9. Certify, by signing this Letter of Intent, that our company has not been cited by the Pittsburgh Area Office with the past three (3) years for alleged violations classified as “willful” or “failure to abate”.
We understand the agreement provides incentives to participating subcontractors who undertake these actions to voluntarily improve their safety and health performance. Incentives will include special recognition from OSHA, opportunities for focused enforcement efforts by OSHA and consideration for additional good faith penalty reductions.

Based upon the mutual interest to protect construction workers at the USS Clairton “C” Coke Battery Project, we agree to the terms of the OSHA Partnering Agreement.


Contractor/Subcontractor: __________________________________________________________

Authorized Representative (Print/Type): ________________________________________________

Title: __________________________________________________________________________

Signature: : ______________________________________________________________________

Date: __________________________________________________________________________

 
Appendix D
OSHA Strategic Partnership Program Annual Partnership Evaluation Report
Partnership ID#  

Cover Sheet
 
Partnership Name


 
 
Purpose of Partnership



 
Goals of Partnership
Goal Strategy Measure
     
     
     
     
Anticipated Outcomes




 
Strategic Management Plan Target Areas (check one)
Construction   Amputations in Manufacturing  
General Industry      
Strategic Management Plan Areas of Emphasis (check all applicable)
Amputations in Construction   Oil and Gas Field Services  
Blast Furnaces and Basic Steel Products   Preserve Fruits and Vegetables  
Blood Lead Levels   Public Warehousing and Storage  
Concrete, Gypsum and Plaster Products   Ship/Boat Building and Repair  
Ergo/Musculoskeletal   Silica-Related Disease  
Landscaping/Horticultural Services      
 
Section 1 General Partnership Information
 
Date of Evaluation Report  
Evaluation Period
Start Date   End Date  
Evaluation Contact Person  
Originating Office  
Partnership Coverage
# Active Employers   # Active Employees  
Industry Coverage (note range or specific SIC and NAICS for each partner)
Partner SIC NAICS
     
     
     
     
     
     
     
     
 
Section 2 Activities Performed
 
Note whether an activity was provided for by the OSP and whether it was performed
  Required Performed
a. Training    
b. Consultation Visits    
c. Safety and Health Management Systems Reviewed/Developed    
d. Technical Assistance    
e. VPP-Focused Activities    
f. OSHA Enforcement Inspection    
g. Offsite Verifications    
h. Onsite Non-Enforcement Interactions    
i. Participant Self-Inspections    
j. Other Activities    
2a. Training (if performed, provide the following totals)
Training sessions conducted by OSHA staff  
Training sessions conducted by non-OSHA staff  
Employees trained  
Training hours provided to employees  
Supervisors/managers trained  
Training hours provided to supervisors/managers  
Comments/Explanations (briefly describe activities, or explain if activity required but not performed)





 
2b. Consultation Visits (if performed, provide the following total)
Consultation visits to partner sites  
Comments/Explanations (briefly describe activities, or explain if activity required but not performed)





 
2c. Safety and Health Management Systems (if performed, provide the following total)
Systems implemented or improved using the 1989 Guidelines as a model  
Comments/Explanations (briefly describe activities, or explain if activity required but not performed)





 
2d. Technical Assistance (if performed, note type and by whom)
  Provided by OSHA Staff Provided by Partners Provided by Other Party
Conference/Seminar Participation      
Interpretation/Explanation of Standards or OSHA Policy      
Abatement Assistance      
Speeches      
Other (please specify)      
Comments/Explanations (briefly describe activities, or explain if activity required but not performed)





 
2e. VPP-Focused Activities (if performed, provide the following totals)
Partners/participants actively seeking VPP participation  
Applications submitted  
VPP participants  
Comments/Explanations (briefly describe activities, or explain if activity required but not performed)





 
2f. OSHA Enforcement Activity (if performed, provide the following totals for any programmed, unprogrammed, and verification-related inspections)
OSHA enforcement inspections conducted  
OSHA enforcement inspections in compliance  
OSHA enforcement inspections with violations cited  
Average number of citations classified as Serious, Repeat, and Willful  
Comments/Explanations (briefly describe activities, or explain if activity required but not performed)





 
2g. Offsite Verification (if performed provide the following total)
Offsite verifications performed  
Comments/Explanations (briefly describe activities, or explain if activity required but not performed)





 
2h. Onsite Non-Enforcement Verification (if performed provide the following total)
Onsite non-enforcement verifications performed  
Comments/Explanations (briefly describe activities, or explain if activity required but not performed)





 
2i. Participant Self-Inspections (if performed provide the following totals)
Self-inspections performed  
Hazards and/or violations identified and corrected/abated  
Comments/Explanations (briefly describe activities, or explain if activity required but not performed)





 
2j. Other Activities (briefly describe other activities performed)





 
 
Section 3 Illness and Injury Information*
 
Year Hours Total Cases TCIR # of Days Away from Work Restricted and Transferred Activity Cases DART
2009          
2010          
2011          
Total          
Three-Year Rate (2008-2011)      
BLS National Average for 2007     2.8
Baseline         2.8
Comments








 
*Sample Chart – not required format

 
Section 4 Partnership Plans, Benefits, and Recommendations
 
Changes and Challenges (check all applicable)
  Changes Challenges
Management Structure    
Participants    
Data Collection    
Employee Involvement    
OSHA Enforcement Inspections    
Partnership Outreach    
Training    
Other (specify)    
Comments





 
Plans to Improve (check all applicable)
  Improvements N/A
Meet more often    
Improve data collection    
Conduct more training    
Change goals    
Comments





 
Partnership Benefits (check all applicable)
Increased safety and health awareness  
Improved relationship with OSHA  
Improved relationship with employers  
Improved relationship with employees or unions  
Increased number of participants  
Other (specify)  
Comments





 
Status Recommendation (Check one)
Partnership Completed  
Continue/Renew  
Continue with the following provisions:  




 
Terminate (provide explanation)  




 

 
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