1. Overview and Identification of partners

The primary participants of this Partnership are:

Torcon, Inc.
Occupational Safety and Health Administration, Harrisburg Area Office (“OSHA”)

This partnering agreement was developed jointly by the United States Department of Labor, Occupational Safety and Health Administration Harrisburg Area Office (OSHA) and Torcon, Inc. The common objective of this program is to develop a contractor/government partnership that will encourage all construction contractors to improve their safety and health performance, assist them in doing so, strive for the elimination of serious accidents in the construction industry, and recognize those contractors with exemplary safety and health programs. Specifically, this agreement will provide a safe and healthful work environment for construction workers at the Penn State University Biological Research Laboratory construction site.

Expected outcomes of this program include: developing model criteria for a multi-employer worksite safety and health program which identifies the responsibilities of each subcontractor; making safety and health information available to all subcontractors onsite; achieving participant recordable illness and injury rates below the national average for the construction industry; and focusing OSHA enforcement activity on subcontractors who need to improve their safety and health efforts.

The agreement provides benefits to participating subcontractors who voluntarily improve their safety and health performance. Opportunities for benefits will include an award of participation from OSHA, focused inspections and deferral from programmed inspections for a period of twelve months following a successful OSHA onsite enforcement verification inspection. Non-participants will not be deferred from programmed inspections.

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, innovation in safety management and encourages more participation in the safety process by each stakeholder. Torcon, Inc. has been an active participant in the Strategic Partnership Program, with 13 separate projects recognized in New Jersey, New York, Pennsylvania, and Maryland since 2005.

Therefore, the Occupational Safety and Health Administration, and Torcon, Inc. are entering into this partnership to foster a safer and healthier workplace for workers by having joint cooperation as prescribed within the terms and conditions set forth in this agreement.


2. Background
   
   
Torcon, Inc. is the Construction Manager (CM) for the Penn State Biological Laboratory Project. The Project’s scope of work includes the construction of a Biological Research Laboratory and associated site and utility improvements. The Biological Research Lab will be approximately 20,000 GSF of structure, consisting of three levels. The main floor level will include building functional spaces including main entry, bio-containment zone, BSL-2 lab, office and conference area, loading area and associated spaces. Bio-containment zone includes BSL-3 labs, holding rooms, procedure rooms, airlocks, staging area, shower/entry, and associated spaces. The lower level will consist of a half-basement with grade access loading and will house mechanical and electrical systems and effluent decontamination system (EDS). A full penthouse level will house mechanical and electrical equipment, bio-containment lab support equipment and will allow for bio-containment space to be serviced from outside of containment barrier.

Due to the close proximity to ongoing operations and impact on existing roadways and buildings, all construction activities will require careful planning and coordination so as to prevent potential hazards to University employees and students, as well as the ongoing operations conducted at Penn State University.

In analyzing the activities associated with the construction process for this project, Torcon Inc. and its subcontractors will take a proactive approach in identifying potential hazards.


3. Goals, Strategies, and Measures
   
   
The primary goal of the partnership is to eliminate injuries, illnesses and fatalities through a cooperative relationship between Torcon, Inc. and its subcontractors. This goal will be accomplished by implementing and following the plan outlined below and evaluating these actions as indicated:


1. Torcon, Inc. will develop, implement and maintain effective safety and health programs in accordance with OSHA’s Voluntary Safety and Health Program Management Guidelines and industry best practices.
1. Torcon, Inc. will evaluate the site-specific safety and health programs of participating contractors, who will be expected to enhance these programs as necessary to meet the partnership performance criteria.
2. OSHA will evaluate Torcon’s and the subcontractors’ safety and health programs during the OSHA onsite enforcement verification inspection using Appendix F (or the 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 using the most recent year published in the Bureau of Labor Statistics (BLS), North American Industrial Classification System (NAICS) code 236, “Construction Of Buildings”. A partnership goal is to keep the overall one-year Total Case Incident Rate (TCIR) below the national average for the construction industry, which was 3.5 for 2010, and Days Away, Restricted or Transfer (DART) rate below the national average which was 1.7 for 2010. The partnership goal is to further reduce this level annually by at least 4% for the duration of the agreement. The intent is to reduce worker injuries and illnesses to the lowest possible reasonable level.


1. Primary causal factors in worker injuries and illnesses will be evaluated and corrected. The top causes of injuries and illnesses will be determined by OSHA during the initial OSHA onsite enforcement verification inspection, and may be adjusted based on experience. Injury and illness incidence in the targeted areas will be evaluated through the logs and other relevant accident reports.
2. Systems will be established to identify and correct accidents and near misses.
3. OSHA will meet quarterly with partners to examine the injury and illness experience of participants and to make corrections and adjustments as needed.
4. DART rates and injury and illness experience will be evaluated through the injury logs and any other relevant accident reports.
4. Statment of Agreement


1. OSHA agrees to:
1. Help identify programmatic needs at this site by reviewing the documented safety program and by providing practical help in implementing the program.
2. Help identify, through the collection of injuries data and site accident and near miss reports, the primary causes of injuries and illnesses, in particular the three top hazards at this site, and assist Torcon in developing countermeasures to reduce or eliminate those hazards.
3. Help small business subcontractors establish safety and health programs and training. OSHA will use its best efforts to include small business subcontractors in all applicable small business programs.
4. Provide assistance to training resources including:
1. OSHA Training Institute Courses (OTI)
2. Information on other available sources of training
5. Provide timely interpretation and clarification of OSHA standards and policy.
6. Participate in training sessions and meetings, as resources allow.
2. Torcon, Inc. agrees that it will administer this partnership program, as outlined herein, and will serve as the principal safety resource in support of participating subcontractors, and:
1. rovide notice to all subcontractors that the Biological Research Laboratory Project is subject to a strategic Partnership with OSHA. All employees will be informed of the partnership and provided a fact sheet during orientation. (Appendix A)
2. Work with Penn State University to ensure compliance by all subcontractors and Visitors with applicable campus safety rules and regulations.
3. Act as liaison for subcontractors with OSHA. Subcontractors will be able to contact Torcon, Inc. with questions, who will in turn contact OSHA for responses when necessary.
4. Offer on-going information on safety or health topics of importance to subcontractors.
5. Provide up-to-date occupational safety and health materials and brochures from OSHA and other appropriate sources.
6. Organize and provide to subcontractors OSHA's interpretations of major standards and local interpretations of issues so they can better understand and properly apply OSHA standards in the workplace.
7. Administer the overall partnership program, including but not limited to the initial contact and evaluation of each subcontractor’s safety and health program and documentation to determine whether the subcontractor meets the criteria specified within this partnership initiative.
8. Notify OSHA on a regular and recurring basis of the names of subcontractors that have met the partnership criteria and the status of those who have not.
9. Monitor participating subcontractors to ensure that they carry out their partnership commitments.
10. Monitor subcontractor compliance regarding tool box talks, training, onsite enforcement verifications, pre-planning meetings, various jobsite permits such as hot work permits and aerial lift permits and subcontractor jobsite inspections.
11. Conduct daily worksite inspections to identify work hazards, conduct written weekly inspections, monthly jobsite safety meetings, and encourage employee involvement.
12. Conduct pre-planning meetings for all high risk activities, conduct job hazard analysis and provide documentation of same, and, to the extent possible, maintain awareness of how the site’s safety and health is impacted by job scheduling and sequencing of activities.
13. Establish a jobsite Labor-Management Safety and Health Committee (Site Safety Committee) to discuss issues regarding safety and health, review accidents, and implement corrective actions as required.
14. Meet with OSHA quarterly, to examine the injury and illness experience of participants and to make corrections and adjustments as needed.
15. Maintain a dedicated competent Site Safety and Health Manager available to assist contractors and subcontractors with all safety and health issues.
16. Maintain a site injury and illness log of all injuries and illnesses reported by all contractors and subcontractors.
3. Torcon, Inc. and participating subcontractors agree to:
1. Apply all relevant components of their respective safety and health programs to the project.
2. Incorporate into a written safety and health program, all essential elements of a basic safety and health program including: management leadership, worker involvement, worksite analysis, hazard prevention and control, and safety and health training.
3. Comply with all current OSHA standards.
4. Have supervisors provide visible leadership in implementing the safety and health program. This includes:
1. Establishing clear lines of communication with project workers,
2. Setting an example of safe and healthful behavior,
3. Creating an environment that allows project workers access to their top management and for subcontractor management to have access to Torcon Inc., project management, and,
4. Ensuring that all project workers are provided equally high quality safety and health protection.
5. Plan for safety and health as part of the overall management planning process. This includes pre-job planning and preparation for different phases of construction as the work progresses.
6. Establish and communicate safety and health program responsibilities to all project workers.
7. Permit employees to participate in the Site Safety Committee.
8. Permit employees to participate in Site Safety Committee jobsite inspections.
4. The subcontractors agree to:
1. Provide a representative, if available to:
1. Attend the onsite enforcement verification inspection for the subcontractors.
2. Encourage safety consciousness and safe working behaviors.
2. Encourage all workers on this project to take advantage of communication and training opportunities presented by this partnership agreement.
3. Encourage all workers on this project to follow all safety and health regulations, policies, and procedures applicable to their work.
4. Participate in the project Labor-Management Safety and Health Committee Meetings as needed.
5. Subcontractor Program Participation

All participating site subcontractors shall adopt and comply with the Project Safety, Health & Environmental Program, prepared and issued by Torcon, Inc. for the project site.


• Subcontractors shall adopt an effective overall safety and health program, which shall include the following elements:
• Management Leadership
• Employee Participation
• Identification of Hazards through Worksite Inspections
• Hazard Prevention and Control
• Employee and Supervisory Training
• Enforcement of the Safety Program
• Subcontractors shall have personnel on site that are responsible for, possess the authority and are capable of effectively implementing the overall site safety and health program.
• Eligible site subcontractors must comply with the terms of this agreement in order to participate. OSHA may disqualify a subcontractor if the subcontractor fails to correct a serious hazard or fails to comply with the terms of this agreement.
Subcontractors will be able to take advantage of this opportunity to partner with OSHA. Subcontractors participating in this partnership agreement must:


1. Sign a letter of agreement with Torcon, Inc., indicating their intent to participate in this partnership initiative. (Appendix D)
2. Verify that a comprehensive written safety and health program exists or will be implemented within 30 days of the signing of this agreement which is at least equivalent to the criteria referenced herein, including the subcontractor’s implementation of policies and procedures establishing that safety rules and procedures are enforced at the site.
3. Certify that their policy and procedures hold supervisor(s) and worker(s) accountable for following established safety rules and OSHA regulations.
4. Certify that their company has not been cited by the US DOL OSHA within the past three (3) years for alleged violations classified as “willful”, “high gravity serious”, “repeat” or “unclassified”.
5. Provide employees the level of training required by OSHA regulations either through their own training personnel or other consultant / trainers.
6. Ensure that all competent persons, supervisory personnel or other personnel serving in the capacity as a competent person will have completed the OSHA 10-hour course for the construction industry (or its equivalent) within a year of the signing of this document. Records of training certification will be provided to Torcon, Inc. and made available for review.
7. Provide periodic safety related data or statistics concerning such issues as man-hours worked, lost workday injuries, accident records and OSHA inspection results. Torcon, Inc. will provide a summary of and analysis of pertinent safety related information for review by OSHA.
6. Project Safety Analysis

The parties agree and acknowledge that management of safety and health depends upon an ability to recognize hazards to which workers may be exposed and the ability to correct or control all known hazards as they arise. Accordingly, Torcon, Inc. will ensure that all subcontractors reasonably demonstrate the use or existence of the following:


1. Safety and Health Programs
1. Review 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 or 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. Hazard Prevention and Control
1. The subcontractors must eliminate or control recognized hazards by the following methods:
1. Engineering controls;
2. Administrative controls;
3. Personal protective equipment; and
4. Safety and health rules, including work procedures for specific operations, that are communicated to and understood and followed by all affected workers and their supervisors;
2. Subcontractors must inspect and maintain equipment to prevent or detect the presence of hazardous conditions. The subcontractors shall document its ongoing maintenance activities.
3. Subcontractors must have a system for initiating timely corrective actions and for documenting the completion of the corrective actions.
4. Subcontractors must have a recordkeeping program designed to recognize injuries and illness trends and provide effective and prompt corrective action when necessary on the site.
5. Emergency response procedures must be written and communicated to project workers. The procedures must list emergency telephone numbers, emergency routes, emergency exits, and requirements for personal protective equipment where required and training and evacuation drills.
3. Training
1. Torcon, Inc. will inform all workers on the project during orientation how the partnership agreement operates and the rights of workers under the Occupational Safety and Health Act.
2. All subcontractors must provide safety and health training for their workers, for the activities in which they are engaged.
4. Safety Committee and Meetings
With respect to all site safety or health hazards, Torcon, Inc. agrees to conduct a weekly safety meeting with representatives from subcontractors working on the project.

Torcon, Inc. agrees to form a Site Safety Committee with the required presence of designated safety persons and open to designated representatives, which will meet in conjunction with the Site Safety Audit Meeting. The Site Safety Committee will review all pertinent safety issues on the site, safety observations, anticipated abatement of hazards, upcoming activities requiring additional safety attention, training or inspection and to address any other safety and health related issues.


7. Employee/Employer 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 the Act.

Torcon, Inc. and subcontractors retain all rights guaranteed under the OSH Act, including the right to have informal conferences and/or contest violations issued by OSHA.


8. Inspections


1. Torcon, Inc. Site Inspections
1. Torcon, Inc. agrees to exercise a reasonable duty of care over all site safety or health hazards in any areas of the site and to eliminate the potential for injury or illness in accordance with this partnership agreement. For example, Torcon, Inc. will ensure subcontractors develop and implement: emergency evacuation plans, a hazard communication plan, maintain chemical inventories, a fall protection plan, perimeter guards, ensure compliance with use of personnel protective equipment, including NFPA 70E.
2. With respect to site safety or health hazards, Torcon, Inc. will conduct comprehensive inspections, with subcontractor involvement as warranted, as often as necessary, but not less than once a month.
3. Torcon, Inc. may delegate the task of inspecting part or the entire site to a smaller compliment of representatives, given that the findings and recommendations of each inspection are reviewed at weekly safety and health meetings.
2. Complaint Investigations
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. 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 mailed, to Torcon, Inc. site office. In accordance with applicable law, the identity of a complainant requesting confidentiality will not be revealed. Torcon, Inc. agrees to investigate these complaints, regardless of the employer involved and provide OSHA with a written response according to the following timetable:


• non-formal complaints/referrals alleging a serious hazard:
  24 hours
• non-formal complaints/referrals alleging an other-than-serious hazard:
  48 hours
Failure to meet these time frames, 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.


3. Inspections
1. OSHA will conduct a minimum of one onsite enforcement inspection each year to offer an OSHA Strategic Partnership (OSP) partner a programmed inspection exemption. Torcon, Inc. and subcontractors, if participating in this partnership, will then be granted a twelve month inspection deferral from programmed inspections following a successful onsite enforcement verification inspection, at this site. The exemption will be valid for one year from the date of the last enforcement inspection closing conference.
2. OSHA personnel will continue to conduct investigations resulting from formal complaints, referrals, fatalities, catastrophes, other accidents or significant events. OSHA will also investigate contractors whose employees are exposed to or are creating plain view hazards at partnering worksites. These investigations will be conducted outside of this partnership agreement in accordance with established OSHA enforcement policy. Violations documented during such investigations may result in the issuance of citations and penalties.
3. During OSHA inspections of non-participant subcontractors, participant subcontractors whose program has been previously verified by an OSHA inspection will not be included in the inspection unless the compliance officer verifies that the participant subcontractor is responsible for employee exposure to hazards.
9. OSHA Onsite Enforcement Verification Inspection and Benefits

In order to assist in measuring the success of this partnership, an initial onsite enforcement verification inspection will be conducted (within 90 days) 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: http://intranet.osha.gov/doc/LAP/doc
handbook/ii_memo.html). Annual verification inspections will be timed to adequately evaluate employee exposure to OSHA’s four focus hazards.

The top causes of injuries and illnesses will be determined by all parties during the initial OSHA onsite enforcement verification inspection, and may be adjusted based on experience. Additionally, corrections will be identified by all parties and implemented by Torcon, Inc. Injury and illness incidence in targeted areas will be evaluated through the injuries logs and any other relevant accident reports.

OSHA will meet with signatories quarterly, to mutually review partnership issues and to examine updated DART/TCIR rates and the injury and illness experience at the Penn State University, Biological Research Laboratory jobsite in State College, PA and its contractors at this site. OSHA shall provide feedback on any noted incident trends and patterns.

Torcon, Inc. and subcontractors, if participating in this partnership, will be granted a twelve month inspection deferral from programmed inspections following a successful, annual, onsite enforcement verification inspection.


10. Evaluation
    
A joint evaluation of the partnership will be prepared annually by OSHA in conjunction with Torcon, Inc. using Appendix E. The evaluation will review the success of the partnership, lessons learned, and changes that will be made to meet the goals of the partnership.


11. Termination of Agreement
    
This agreement will terminate two years from the date of the signing or upon completion of the Penn State University Biological Research Laboratory Construction Project. If either OSHA or Torcon 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 the participating employer is issued a citation related to workplace hazards which resulted in a fatality.

For non-signatory participants of the strategic partnership, OSHA may terminate the participant’s involvement at any time with written notice. Additionally, the participant may withdraw their participation at any time with a written notice of the intent to withdraw to OSHA.


12. Paperwork Reduction Act
    
Paperwork Reduction Act Notice Form Approved MB# 1218-022 Expires June 30, 2012. 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.


13. Primary Partnership Contacts
    
Dale Glacken
Compliance Assistance Specialist
49 North Progress Ave
Harrisburg, PA 17109
(717) 782-3902

Leon Baukh, Primary Contact
Corporate Safety Director
Torcon, Inc
328 Newman Springs Road
Red Bank, NJ 07701
Office: (732) 704-9800
Cell: (908) 296-7302

Paul Genereux, Secondary Contact
Senior Project Director
Torcon, Inc Field Office
Penn State University
206 Wiley Lane,
University Park, PA 16802
(814) 954-7550


14. Signature Page

Based upon a mutual interest to protect construction workers at the Penn State University Biological Research Laboratory jobsite, the parties below, on behalf of their respective organizations, agree to the above terms of an OSHA Partnering Agreement.

Signed this __ Day of _______, 2011

PARTIES
For Torcon, Inc. _______________________________ John DeFazio Project Executive Torcon, Inc.	For OSHA _____________________________ Kevin G. Kilp Area Director Harrisburg Area Office
_______________________________ Paul Genereux Project Director Torcon, Inc.	_____________________________ Dale Glacken Compliance Assistance Specialist Harrisburg Area Office
_______________________________          Leon Baukh Corporate Safety Director Torcon, Inc

This partnering agreement was developed jointly by the United States Department of Labor, Occupational Safety and Health Administration (OSHA), Harrisburg Area Office and Torcon, Inc. The common objective of this program is to develop a contractor/government partnership that will encourage all construction contractors to improve their safety and health performance, assist them in doing so, strive for the elimination of serious accidents in the construction industry, and recognize those contractors with exemplary safety and health programs. Specifically, this agreement will provide a safe and healthful work environment for construction workers at the Penn State University Biological Research Laboratory in State College, PA construction site.

Expected outcomes of this program include: developing model criteria for a multi-employer worksite safety and health program which identifies the responsibilities of each subcontractor; making safety and health information available to all subcontractors onsite; achieving participant recordable illness and injury rates below the national average for the construction industry; and focusing OSHA enforcement activity on subcontractors who need to improve their safety and health efforts.

The agreement provides benefits to participating subcontractors who voluntarily improve their safety and health performance. Opportunities will include an award of participation from OSHA, focused inspections and deferral from programmed inspections for a period of twelve months following a successful OSHA verification inspection.

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, innovation in safety management and encourages more participation in the safety process by each stakeholder.

Therefore, the Occupational Safety and Health Administration and Torcon, Inc. and subcontractors are entering into this partnership to foster a safer and healthier workplace for workers by having joint cooperation as prescribed within the terms and conditions set forth in this Agreement.

_________________________	_________________________
John DeFazio	Kevin G. Kilp
Project Executive	Area Director
Torcon, Inc.	Harrisburg, PA Area Office

All subcontractors must complete and submit the following information to the Safety Manager.  Information shall be submitted to the attention of Paul Genereux, Project Director.  Torcon, Inc. Site Specific Safety and Health Program.

1. Submit your Company’s written Project Specific Safety Plan or Program.
2. Submit a written Site Specific Hazard Communication Program.
3. Submit Material Safety Data Sheets (MSDS) and an inventory list for ALL hazardous materials that will specifically be used on this project.
4. Submit name(s) and qualification(s) for your designated on site Safety Representative.
5. Submit name(s) and qualification(s) of your Company’s Corporate Safety Manager and telephone number.
6. Submit emergency telephone numbers for all key personnel. Project Manager, Superintendents, on site designated Safety Representative(s), Corporate Safety Manager. Include 24 hour emergency telephone numbers. Phone numbers should include jobsite trailer number, home phone numbers and cell phone numbers.
7. Submit names and qualifications of all OSHA designated competent and qualified personnel assigned to project.
8. Submit any required safety related permits for job specific operations to be performed on this project.
9. Submit signed weekly tool box safety talks for all workers on site no later than Monday at 3:00 PM.
10. Submit a weekly safety inspection report by no later than Monday at 3:00 PM.
11. Submit a copy of your Company’s OSHA 300A Form by the end of January to be posted in February for work conducted on this project.
12. Submit Accident/Incident Investigation Reports (within 24 hours) for all incidents involving your workers.
13. Participate in Torcon, Inc. Orientation Program. New workers reporting to the jobsite for the first time must report to the Torcon, Inc. trailer to attend a safety orientation prior to working on the jobsite.
14. Conduct OSHA required training. Keep copies on file and make available upon request.
15. Provide fall protection training. Ensure that all employees working on site understand that fall exposure potential greater than six feet (6’) requires 100% fall protection.
16. Provide HAZCOM training to all employees.
17. Provide stairway and ladder training (as required) to all employees.
18. Provide personnel protection equipment training (PPE) and confined space entry training (as required) to all employees. Provide ground fault protection for all temporary electrical power.
19. Provide Job Hazard Analysis (JHA) and/or Safety Task Analysis (STA) for all work activities under your contract.
20. Post the Emergency procedures and emergency telephone numbers in all jobsite trailers. Make available to employees.
21. Attend Safety Committee Meetings held monthly for subcontractors Safety Representatives.
22. Distribute safety-meeting outlines, fatal facts or similar safety data to all employees on a weekly basis.
23. The Safety Manager may at any time issue verbal/ written safety warnings and/or remove subcontractors or their employees from jobsite for non-compliance of safety rules. Correct deficiencies within 24 hours of notice and respond in writing to any Safety Observations. The following reprimands apply to minor safety violations. Immediately Dangerous to Life or Health (IDLH) and fall protection violations are zero tolerance.
Minor Safety Violations
• 1st Time= Verbal Warning
• 2nd Time= Written Warning
• 3rd Time= Two day suspension from jobsite
• 4th Time= Termination or Permanent Removal from jobsite
  
IDLH and Fall Protection
• 1st Time= Two Days suspension from jobsite
• 2nd Time= Termination or Permanent Removal from jobsite
24. Provide employees an opportunity to receive OSHA 10 hour or 30 hour training, Personal Protective Equipment (PPE) training, first aid, Cardio Pulmonary
Resuscitation (CPR) training. Perform on an as needed basis.
25. Inform workers that subcontractor MSDS sheets are available for review at Torcon’s. Field Trailer.
26. Maintain a list of all first aid and CPR trained employees.
27. Provide and maintain first-aid kits for your employees.
28. Provide and maintain fire extinguishers for your work.
29. Provide all employees with your emergency evacuation plan.
30. Maintain copies of all safety documentation on file in the jobsite trailer. All safety documentation and files shall be made available upon request.

Letter of Intent to participate
Penn State University Biological Research Laboratory
Safety Partnership

Name of subcontractor: __________________________________________________________

Subcontractor Site Representative:____________________________________________________

Anticipated Number of Workers:___________________________________________________

We have read the requirements to participate in Penn State University Biological Research Laboratory Safety Partnership and agree with all aspects of the program, including the submission of the required information.  Specifically, we recognize the need to strive 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 10-hour construction training program.
4. Planning for safety and health as part of the overall management planning process, including appropriate Job Hazard Analyses (JHA) and/or Safety Task Analysis (STA).
5. Establishment and communication of all safety and health program responsibilities to all project workers.
6. Evaluation of safety and health programs annually.
7. Reporting of all site injuries and illnesses so that a site log may be maintained.
8. Reporting all deficiencies or damage to site wide programs or protective measures, specifically site fall protection, immediately upon discovery and taking appropriate interim protective measures for protection of their employees.

We understand the agreement provides benefits to participating subcontractors who undertake these actions to voluntarily improve their safety and health performance.  Benefits will include special recognition from OSHA, focused and reduced enforcement efforts by OSHA. 

Based upon the mutual interest to protect construction workers in the Penn State University Biological Research Laboratory, we agree to the terms of the OSHA Partnering Agreement.

Signed this        day of                  , 20__

_______________________________                                        _______________________________
Subcontractor                                                                                Paul C. Genereux
Project Manager                                                                            Project Director
                                                                                                      Torcon, Inc.