OSHA Strategic Partnerships Program > Region III

Lehigh Career & Technical Institute

PA/OSHA Consultation at Indiana University of Pennsylvania

USDOL/OSHA – Allentown Area Office

and

Warehousing, Storage & Transportation Employers

Warehousing Logistics and Material Handling Safety Partnership

Agreement Establishing a Partnership
Between
Occupational Safety and Health Administration
The U.S. Department Of Labor
Allentown, Pa Area Office
The Lehigh Career & Technical Institute – Materials Handling/Logistics Technology Department
Warehousing, Storage, Distribution and Transportation Employers
And
PA/OSHA Consultation Program at Indiana University of Pennsylvania

Background, Purpose and Scope:

In a cooperative effort to foster safe and healthful worksites and meet OSHA’s strategic goal of improving the safety, health and well-being of the nation’s workforce, the USDOL/OSHA Allentown Area Office, the PA/OSHA Consultation Program at Indiana University of Pennsylvania, the Lehigh Career & Technical Institute Materials Handling/Logistics Technology Department, and Warehouse, Storage, Distribution and Transportation Industries and their employees (See Appendix A) agree to establish a partnership program to reduce the number of injuries and illnesses resulting from events or exposures within the workplace, assure compliance with the most frequently cited OSHA standards for their industry, promote the integration of occupational safety and health training through vocational-technical school instruction, and encourage companies interested in pursuing participation in the Safety and Health Achievement Recognition Program (SHARP) of the PA/OSHA Consultation Program at IUP and/or OSHA’s Voluntary Protection Program (VPP).

The primary purpose of the agreement is to prevent accidents, injuries, and fatalities resulting from work activities within the warehousing storage distribution and transportation industry. In an effort to achieve this goal, this partnership will (1) develop an initiative to improve safety and health performance by reducing the Total Case Incident Rate (TCIR) and Days Away Restricted and Transferred (DART) rate of participating employers over the life of the partnership, (2) identify within the participating members worksites if anything other than the primary causal factors, contact with objects, overexertions and falls are contributing to injuries and illnesses, and if so, develop a strategy to control or eliminate those hazards, (3) aid in the development of a workplace Motor Vehicle safety program or facilitate in a mentoring process for those who have not yet developed such a program, (4) promote and encourage employer usage of the PA/OSHA Consultation Program to assist in workplace hazard recognition, and (5) recognize partnering employers with a certificate of participation.

Over the last several years, there has been tremendous growth in the warehouse, storage, distribution and transportation industry, and as such this office began reviewing local and national data to identify what issues, if any, were occurring within this industry. In review of injury and illness data, the Bureau of Labor Statistics (BLS) has identified several “events” or “exposures” which were clearly at the forefront: industrial truck incidents, falls to lower levels and on the same level, overexertion involving ergonomic stressors and hazards primarily attributed to lifting, and finally transportation accidents.

This program is aimed at developing an employer/academia/government partnership that will encourage all members to improve their safety and health performance, assist them in doing that, strive for the elimination of serious accidents within the industry, and recognize those employers with exemplary safety and health programs.

This Partnership will be available to any employer in the Allentown OSHA Area Office jurisdiction with a North American Industrial Classification System (NAICS) Code which falls within the major group of 484 - Truck Transportation or 493 – Warehousing and Storage.

(NOTE: Although OSHA’s jurisdiction does not include over-the-road motor vehicle safety and does not currently have any standards to address motor vehicular safety/training, this partnership will attempt to address, to the extent feasible and applicable, this increasing hazard in an educational and outreach manner. Review of occupational injury and illness data has shown that within the trucking and warehousing industry, transportation accidents are the third leading cause of nonfatal occupational injuries involving days away from work .

This Partnership is consistent with OSHA’s long-range efforts to develop a business, labor, and government partnership approach to safety management. It will enable OSHA to leverage its resources more efficiently in promoting safety and health through a cooperative effort involving the participating employers and consultation services sharing their experiences and successes. This Partnership will have an increased impact on the partners by reaching a greater number of employers and employees and should achieve improved worker protection through a reduction of job related injuries and illnesses sooner than by traditional means. Additionally, this Partnership will provide the opportunity for some of its members to create a safety and health management system that will insure its employees are protected from injuries and illnesses and will encourage companies to submit application to VPP or SHARP.
Identification of Partners:
1. The U.S. Dept. of Labor - Occupational Safety and Health Administration - Allentown Area Office;
2. Lehigh Career & Technical Institute – Materials Handling/Logistics Technology Department;
3. PA/OSHA Consultation Program at Indiana University of Pennsylvania;
4. Warehouse, Storage Distribution and Transportation employers and their employees (See Appendix A) for members).
Goals and Measurements:
1. Reduce the number of injuries and illnesses resulting from “contacts with objects” (hazards associated with unsafe operation of powered industrial trucks), from “overexertion” (hazards associated with ergonomic issues, including unsafe lifting activities), and from “falls” (same level falls and fall hazards to a lower level), within this industry group.
  
  The number of injuries occurring in the focus areas for each participant will be reviewed annually for a reduction from their baseline Additionally, each participant’s TCIR and DART rates which will be analyzed for an overall reduction in injury and illness rates.
  
  Upon entry into this partnership, and annually, thereafter, each participating employer will provide the number of OSHA recordables which involve “contacts with objects” (hazards associated with unsafe operation of powered industrial trucks), “overexertions” (hazards associated with ergonomic issues, including unsafe lifting activities), and from “falls” (same level falls and fall hazards to a lower level). Data will be used to establish a baseline for each participant and to measure annual progress toward reaching the partnership’s goals.
2. Develop a system for the early identification and correction of the focused hazards which have resulted in or had the potential for serious injuries, illnesses and fatalities within these industries.
  
  This goal will be measured by the utilization of hazard identification checklists, the Warehouse Self-Inspection Safety Audit Forms (Appendix B) , developed by the Warehouse Education Research Council (WERC), which specifically focus on those hazards within this industry group. Summary data will be collected by the Allentown OSHA Area Office to be used as the basis for safety and health training for all of the participants and as part of the annual offsite review process.
3. Reduce the number of serious hazards within this industry group.
  
  This goal will be measured by the employers abatement of hazards identified through self-administered hazard identification checklists, JSA’s, SOP’s, etc., as noted in item no. 2 and through tabulation of any OSHA inspection data, OSHA interventions, as well as any workplace recommendations that may be made during an OSHA inspection.
4. Provide safety and health training and technical assistance on existing and new OSHA regulations, focusing on the primary cause(s) of injuries within the industry.
  
  This goal will be measured by the number of presentations, speeches or training sessions provided to the partnering members. Information such as the topics, the number of attendees and the number of affected employees will also be gathered for tracking this goal.
5. As resources permit, improve the site’s safety and health program to become qualified and eligible to participate in the Safety and Health Achievement Recognition Program (SHARP) of the PA/OSHA Consultation Program at IUP and/or OSHA’s Voluntary Protection Program (VPP).
  
  This goal will be measured by the implementation or enhancement of programs, as identified by the PA/OSHA Consultation Program, such as the number of companies requesting an on-site consultation visit, the number of companies receiving a full service visit, or the number of companies applying for participation in the Deferral Program or Safety and Health Achievement Recognition Program (SHARP) (Appendix C) of the PA/OSHA Consultation Program at IUP.
  
  (NOTE: Due to the confidentiality of the PA/OSHA Consultative service this information will be provided by IUP as blanket statements that conditions (if any) have been noted, and they’ve been adequately abated by the employer in accordance with specified time frames.)
  
  This goal may also be measured by (1) the number of application requests received by OSHA from partners to participate in OSHA’s Voluntary Protection Program (VPP) or (2) the number of partners who commit to the Partnership to VPP Mentoring Opportunity as outlined in Appendix D. To be considered for the Partnership to VPP Mentoring Opportunity, an employer must submit to the Allentown OSHA office a self-assessment of their safety and health management system according to the Challenge Stages at a Glance for General Industry (Appendix D).
Employer’s Commitment/Role:
1. Develop, implement and communicate an effective comprehensive safety and health program specific to the warehouse, storage and distribution industry.
  1. Employers agree to implement safety and health programs with a commitment that routinely extends beyond what is required by OSHA regulation. Effective safety and health programs include the following elements:
    1. Management Leadership
    2. Employee Participation
    3. Identification of Hazards through Worksite Inspections
    4. Hazard Prevention and Control
    5. Employee and Supervisory Training
    6. Enforcement of the Safety Program
    An assessment of the safety and health program will be conducted and may be accomplished by utilization of such tools as the OSHA-33 (Safety and Health Program Assessment Worksheet – Appendix E), the OSHA Challenge Program Stages for General Industry (Appendix D), or an equivalent form reviewed by OSHA.
2. Provide to OSHA, the TCIR and DART rates, as written into this agreement, needed to prepare the annual evaluation and complete the offsite verification required to measure the implementation and success of the partnership.
3. Manage the site’s occupational safety and health program to reduce the number of injuries, accidents and near misses resulting from “contacts with objects” (hazards associated with unsafe operation of powered industrial trucks), from “overexertion” (hazards associated with ergonomic issues, including unsafe lifting activities), and from “falls” (same level falls and fall hazards to a lower level).
4. Assure that a company representative (hourly or management) is in attendance at each of the partnership’s meetings and/or training sessions held every other month.
5. Develop a system for the early identification and correction of the focused hazards (contacts with objects, overexertion, and falls) which have resulted in serious injuries and fatalities within their workplace.
6. Unless obtained during an OSHA inspection, any site-specific information provided to OSHA, by any of the participating employers of this Partnership shall be considered privileged, confidential, and protected from disclosure to outsiders, to the extent allowed by law, other than as necessary to accumulate industry-wide data, and shall not be relied on by OSHA to prove the existence of a citable violation of OSHA standards or the Section 5(a)(1) (General Duty Clause) of the OSH Act.
New Membership:

Annually, on or around the anniversary signing date of this partnership, new companies can be added as signatories to this agreement. Interested companies are encouraged to attend partnership meetings in the interim.
Employee Rights:

This partnership does not preclude employees and/or employers from exercising any right provided under the OSH Act, nor does it abrogate any responsibility to comply with rules and regulations adopted pursuant to the Act.
Lehigh Career & Technical Institute’s Commitment/Role:
1. LCTI will provide safety and health technical assistance in the area of forklift safety through instruction and will continue to provide support in reviewing and updating OSHA’s Powered Industrial Trucks (Forklifts) eTool.
2. LCTI agrees to occasionally facilitate, broker and/or host technical safety and health meetings and training sessions at their site if space is available and there are no conflicts with school activities.
PA/OSHA Consultation Program Commitment/Role:
1. The PA/OSHA Consultation Program will give participating employers a high priority for scheduling on-site consultation visits. They will also provide the employer with a report summarizing their findings and will assess the impact on workplace safety and health.
2. The PA/OSHA Consultation Program will provide resources to assist in the training and education of participating employers and their employees as resources permit.
OSHA’s Commitment/Role:
1. Help identify (offsite), through the collection of OSHA 300 data or site accident reports, the primary causal factors in injuries and illnesses, in particular the top hazards within this industrial group and develop feasible and useful countermeasures for correcting those hazards. Individual employers are not required, by virtue of this Agreement, to adopt or implement such countermeasures.
2. Provide information on training resources including attendance at available OSHA Training Institute courses, offered locally, and information on other available sources of training.
3. Provide interpretation or clarification as to the meaning and application of OSHA standards and policy.
4. Assure OSHA’s participation in the partnership’s meetings and/or training sessions conducted every other month.
5. Designate an experienced safety and health specialist (CAS or CSHO) to serve as a resource and liaison for partnership participants.
Verification:

Annually, OSHA will conduct an offsite review of the written program elements of this agreement to insure that participants are carrying out their commitments under the partnership. The review may include documents such as the most current annual report, OSHA Form 300 data or its equivalent, completed hazard identification checklists and abatements.
Benefits:

OSHA will provide technical assistance and training, under the terms of this agreement, to help participants understand, find and fix hazards at their worksites and improve their safety and health management systems. Partnering employers will be recognized with a certificate of participation.
Rights of the Parties and Employees:

All partners remain subject to normal OSHA inspection procedures. The provisions of this agreement identified herein, shall not modify any legal or contractual rights and remedies. OSHA’s Partnerships provide groups of employers, employees and employee representatives, an opportunity to participate into an extended, voluntary, cooperative relationship with OSHA in order to encourage, assist, and recognize their efforts to eliminate serious hazards and achieve a high level of worker safety and health. Partnerships have proved to be valuable tools for both OSHA and its participants. By entering into a Partnership with a party, OSHA is not endorsing any of that party’s products or services; nor does the Agency enter into a Partnership with the purpose of promoting a particular party’s products or services.

Participation in this Partnership does not obligate an employer to implement any work practice, install or modify any equipment, or hire any individual as an employee or consultant. Actions taken by an employer in respect to its local workplace and operations, in furtherance of its participation in this Partnership, shall not necessarily be binding on or required by that employer in respect to workplaces and/or operations maintained elsewhere by that employer.
Evaluation:

In cooperation with its partners, OSHA will prepare the required annual evaluation of this partnership using Appendix F. The evaluation will review the implementation of the agreement, lessons learned, and changes that need to be made to meet the goals of the agreement.
Termination:

This agreement will terminate three years from its signing date. Any signatory member may terminate their participation at any time upon written notification to OSHA. If OSHA chooses to withdraw its participation, the entire agreement is terminated. This agreement may be modified at any time with the concurrence of all of the signatories.
Paperwork Reduction Act Notice:

Paperwork Reduction Act Notice Form Approved OMB# 1218-0244 Expires 06-30-2009. 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.

(Signature)_____________________________________ (Date) ________________________________________ Jean G. Kulp Area Director USDOL/OSHA – Allentown Area Office		(Signature)_____________________________________ (Date) ________________________________________ Dr. Clyde Hornberger Executive Director Lehigh Career and Technical Institute
(Signature)_____________________________________ (Date) ________________________________________ David Rubright Workforce Education Coordinator Lehigh Career and Technical Institute		(Signature)_____________________________________ (Date) ________________________________________ David Rhodes Program Manager PA/OSHA Consultation Program Indiana University of Pennsylvania
(Signature)_____________________________________ (Date) ________________________________________ Mark Reardon Distribution Center Manager Bridgestone Firestone N.E. Dist. Center		(Signature)_____________________________________ (Date) ________________________________________ Philip R. Parks Distribution Center Manager Walgreens Company
(Signature)_____________________________________ (Date) ________________________________________ James Watts Branch Manager BlueLinx Corporation		(Signature)_____________________________________ (Date) ________________________________________ John Hudak Plant Safety Coordinator The Lehigh Group
(Signature)_____________________________________ (Date) ________________________________________ Dave Packenham General Manager Nestlé USA – Allentown Distribution		(Signature)_____________________________________ (Date) ________________________________________ Carla Day Human Resources AmeriCold Logistics
(Signature)_____________________________________ (Date) ________________________________________ John Petrella Distribution Center Supervisor Grundfos Pumps, Corp.		(Signature)_____________________________________ (Date) ________________________________________ Bill Barker Administrative/Safety Manager OCS Logistics
(Signature)_____________________________________ (Date) ________________________________________ Mark Ofenlock VP - COO Nexus Distribution Corp.		(Signature)_____________________________________ (Date) ________________________________________ Tony Reede Human Resource Manager AmeriCold Logistics – Dry Distribution Center

Appendix A – Participating Members

USDOL/OSHA – Allentown Area Office Allentown, PA
Lehigh Career & Technical Institute
PA/OSHA Consultation Program at Indiana University of Pennsylvania,
Indiana PA
Walgreens Company
AmeriCold Logistics
Bridgestone/Firestone NE Dist. Ctr.
The Lehigh Group
BlueLinx Corporation
Nestlé USA
Orefield Cold Storage & Dist (OCS Logistics)
Nexus Distribution Corp.
Grundfos Pumps, Corp.


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