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PHOEBE SUMTER COUNTY HOSPITAL PROJECT
STRATEGIC PARTNERSHIP
BETWEEN
OCCUPATIONAL SAFETY and HEALTH ADMINISTRATION
SAVANNAH AREA OFFICE
AND
The Georgia Tech Research Institute’s Occupational Safety and Health
Programs Office
AND
BRASFIELD & GORRIE, LLC
- PURPOSE/SCOPE
This partnership was developed jointly by Occupational Safety and Health
Administration (OSHA), the Georgia Institute of Technology Onsite Safety and
Health Consultation Program (Georgia Tech) and Brasfield & Gorrie. The common
objective and goals of the Partnership are to reduce injuries and illnesses,
increasing safety and health training, sharing of best work practices and
increasing the number employers with safety and health management systems.
This Partnership is consistent with OSHA’s long-range efforts to develop a
contractor/ government partnership approach to safety management. It allows
for better use of OSHA resources and innovation in safety management and
encourages more participation in the safety process from the construction
community.
This partnership will cover the construction of the Phoebe Sumter County
Hospital. The hospital was completely destroyed by a tornado in 2007. The new
hospital will be four stories and include 190,000 sq. ft, which will consist
of a Women’s and Family Health Building (16,000 sq. ft.), a Surgery and
Oncology Center (20,000 sq. ft.), and a Wellness and Education Center
(18,000sq.ft.). The entire skeleton will be made of steel, the outside will be
modular-sized brick, and the roof will be shingle or a standing green roof.
To facilitate the goal of reducing occupational related fatalities and serious
injuries within the construction industry OSHA, Georgia Tech Research
Institute (GTRI) and Brasfield & Gorrie will implement an agreement under the
OSHA Strategic Partnership Program (OSPP). By combining its efforts, skills,
knowledge and resources OSHA, Brasfield & Gorrie and Georgia Tech expect to
reduce exposure to hazards and thereby decrease the possibility of serious
injuries and fatalities at the Phoebe Sumter County Hospital Construction
Project.
- IDENTIFICATION OF PARTNERS
The Partnership will include:
- OSHA
- Brasfield & Gorrie, LLC
- Georgia Tech
- GOALS AND MEASUREMENTS
The primary objective of this partnership is to create a working relationship
that focuses on preventing work-related fatalities, controlling or eliminating
serious workplace hazards, and establishing a foundation for the development
of an effective safety and health program. The goals employed to achieve these
results will include the following:
|
GOALS |
STRATEGIES |
MEASURES |
|
Reduce the total number of injuries and illnesses cases by 10 percent,
thereby providing a safe and healthful work environment for employees at the
project. |
a) Reviewing the OSHA 300 data of the partnership participants.
b) Calculating the employer’s TCIR and Days away from work, restricted, or
job transferred (DART) rates.1
c) Comparing this data with the baseline rates for the agreement. |
a) This goal will be measured by the number of companies participating in
the partnership, which reduce their TCIR and DART rates below the baseline
for the partnership.
b) Baseline will be based on the current BLS data for the industry.
c) The DART rate will also be identified for the three different levels of
participation (RED, WHITE and BLUE). |
|
Effectively control workplace hazards by increasing the number of
construction companies with safety and health management systems. |
Methods to evaluate the partner’s performance in this area will include the
implementation of comprehensive safety and health management systems,
employers that establish effective safety and health management systems |
Measure the number of participants that develop and implement effective
safety and health management systems as a result of participating in the
partnership, compared to the baseline for the agreement. The baseline will
be established during the initial year of the agreement. |
|
Increase the number of employees, employers and supervisors that are
provided effective safety and health training, such as the OSHA 10-hour
course. |
a) Evaluation of the employers that establish effective safety and health
training programs.
b) Evaluation of the employers that provide employees with OSHA 10-hour/
OSHA 30-hour training. |
a) Measure the number of employers with effective safety and health training
programs.
b) Measure the number of managers, supervisors and employees provide with
OSHA 10-hour/ OSHA 30-hour training, compared to the baseline for the
agreement. The baseline will be established during the initial year of the
agreement. |
|
Continually improve safety
and health at the worksite by ensuring that best practices are shared with
all subcontractors.
|
a) OSHA will evaluate the number of inspections and types of violations
issued to partnership members.
b) Brasfield & Gorrie will continuously monitor worksites by conducting
audits identifying and correcting serious hazards. |
Measured by monitoring the number of participants that experience OSHA
enforcement inspections, which result in citations with penalties. A
comparison will be made between the number of previous OSHA inspections and
hazards identified. |
- MANAGEMENT AND OPERATION
- Brasfield & Gorrie, LLC will:
- Establish a jobsite safety walk team, consisting of a representative of all
contractors on site, implement the safety committee’s Zero Injury Philosophy,
in that all accidents are preventable and unnecessary, and a comprehensive
safety and health management system, which includes:
- Management commitment and employee involvement;
- Hazard analysis;
- Hazard control; and
- Arrangement of training assistance for other stakeholders on site.
- Mentor subcontractors in safety and health management systems.
Subcontractors shall include all multi-tiered subs that arrive for work on the
site.
- Where the potential for airborne silica exposure exists, require the use of
wet cutting, or soft cutting techniques and/or dust collection system, and
when needed, the mandatory use of approved respiratory protection. To the
extent feasible, personal air monitoring will be conducted to assess employee
exposure levels. Where the potential for other health issues exist (i.e.,
carbon monoxide, lead, or large-scale use of chemicals in the building
interior during floor finishing), Brasfield & Gorrie will coordinate with the
subcontractor responsible for creating the hazard and ensure that air
monitoring is accomplished to assess employee exposure levels. Sampling
results will be compiled and tracked by Brasfield & Gorrie.
- Have the authority to enforce safety rules and regulations. This authority
will include provisions to hold contractors and employees accountable and, if
necessary, remove contractor employees, supervision from the job site.
- Ensure that a risk assessment is performed by a competent person on all
fall hazards. The probability and severity of occurrence for each identified
hazard will be evaluated to eliminate or reduce the risk through engineering
or administrative controls to a level as low as possible.
- Critical risk will not be tolerated. No work will be performed until action
is taken to reduce the level of risk to as low as reasonably feasible.
- Bricklayers performing overhand bricklaying and related work above lower
levels must be adequately protected. No monitor system will be allowed.
- Workers on the face of formwork or reinforcing steel must be protected from
falling by personal fall arrest systems, with the use of a positioning device,
and/or lanyards.
- To the extent feasible, serious ergonomic hazards will be identified and
corrected.
- Ensure that ground fault circuit interrupters (GFCI) are used to protect
all electrical circuits that are installed for work. All contractors will
ensure that employees are protected by the use of a GFCI at all times.
- The Superintendent and Safety Director for Brasfield & Gorrie will to serve
as a point of contact, monitor safety and health at the site and its progress
toward achievement of the partnership goals.
- Brasfield & Gorrie’s Superintendent and Safety Director will ensure that
daily Safety Audits are conducted (since this is a multi-employer worksite and
all workers are to work together on safety issues). Brasfield & Gorrie, upon
request, will review subcontractors daily log books, note any hazards found,
and then review them with all committee members at the weekly
coordination/Subcontractor meeting.
- Conduct and document job site safety meetings/toolbox talks on a weekly
basis.
- Submit monthly accident reports to the partners, including first aid,
injury, property damage and near miss reports.
- Coordinate and conduct a comprehensive site audit twice each month led by Brasfield & Gorrie’s Superintendent. Safety Committee and Subcontractor
Members will participate in the site safety audit. If non-compliant activity
or hazards are discovered, immediate correction is required. Brasfield &
Gorrie will document the corrective action taken and share this information
with OSHA and the Georgia Tech Research Institute during the quarterly update
meetings.
- Continually audit the partnership’s effectiveness and make recommendation
for improvement.
- Establish an Employee Safety committee that will meet on a monthly basis
to share the results of jobsite inspections, information concerning accidents
and near misses, suggestions for improvement and recommendations for training
for the general workforce. Near misses and daily safety audits will be
continued to be discussed during Tool Box Talks.
- Ensure that no employees are allowed to work directly below a suspended
load except for: employees engaged in the initial connection of steel;
employees necessary for hooking or unhooking the load. The following criteria
must be met when employees are allowed to work under the load: materials being
hoisted shall be rigged to prevent unintentional displacement; hooks with
self-closing safety latches or their equivalent shall be used to prevent
components from slipping out of the hook; all loads shall be rigged by a
qualified rigger. Appropriate use of tag lines will be utilized to prevent
work below suspended loads.
- Require the use of appropriate personal protective equipment. Hardhats are
mandatory. Employees exposed to or working with heavy equipment and all
flagmen on site shall wear high-visibility reflective clothing. A 100 percent
eye protection program will be implemented.
- Ensure that all signs and warnings will be posted in English and Spanish,
as well as any other appropriate languages.
- Implement a 100 percent Fall Protection Plan for all work preformed 6 feet
or more above lower surfaces.
- Subcontractors will:
- Appoint a representative to the site Safety Committee responsible for
resolving job safety matters and serving as a liaison to Brasfield & Gorrie’s
Superintendent. Every prime subcontractor will have a person available to
participate in the safety committee. Participation in this committee will
consist of, but will not be limited to, participation in the Project Team
Safety Walkthroughs and monthly safety meetings.
- Conduct jobsite safety inspections for those employees under their control.
This will be in addition to the general inspections that are to occur daily.
If non-compliant activity or hazards are discovered, immediate correction is
required. Documentation of abatement methods and verification must be
submitted to Brasfield & Gorrie’s Safety Director.
- Participate in the weekly Safety Committee/Subcontractor meetings and
safety audits. If non-compliant activity or hazards are discovered, immediate
correction is required. Abatement methods and verification must be submitted
to Brasfield & Gorrie’s Safety Director who will document the correction taken
and share this information during the monthly update meetings.
- Share the results of jobsite inspections with all workers by posting them
in the project office.
- OSHA will:
- Participate, to the extent resources permit, in the quarterly Partnership
Committee/Subcontractor meetings, but will not participate in the walk around
inspection, except that the verification visits may be scheduled as part of
the weekly walk around inspection.
- Serve as a resource and liaison for partnership participants and also
assist with safety and health training, as resources permit.
- Give priority to the construction project when technical assistance is
needed.
- Audit the monthly reports/documents and make recommendations for
improvements in the meeting Partnership goals.
- Conduct inspections in accordance with section VIII of this partnership.
- Conduct the annual partnership evaluation report in accordance with section
VI of this Partnership.
- Georgia Tech’s On-site Consultation Program will:
- Perform quarterly jobsite inspection.
- Give priority consideration to requests for services to small contractors
who are engaged in work at the project.
- SAFETY AND HEALTH MANAGEMENT SYSTEM
Brasfield & Gorrie use its system to collect and analyze injury and illness
trends (including near-miss incidents) by all contractors performing work at
the site. This data will be used as a tool to ensure continual safety and
health improvement at the site. The management of this agreement will be
accomplished by Brasfield & Gorrie implementing a comprehensive jobsite safety
and health management system which includes:
- Brasfield & Gorrie will complete a risk assessment prior to exposing
employee to potential safety and health hazards. This will be accomplished by
the use of the Brasfield & Gorrie Job Hazard Analysis (JHA) form (attached)
- Work with OSHA, Georgia Tech and committee members to provide the resources
to conduct initial monitoring for ALL toxins, carcinogens, or hazardous
substances currently emphasized by OSHA and which present inhalation hazards,
such as silica, lead, cadmium, and/or isocyanates. Employee exposures will be
assumed and respiratory protection worn until the results of the initial
monitoring studies are received and demonstrate no exposure problems or prior
surveys show no hazard exists. Brasfield & Gorrie will endeavor to ensure that
no work with these materials will occur, thus preventing any exposure.
Brasfield & Gorrie will request periodic evaluation visits by its insurance
company’s Industrial Hygienist and Georgia Tech.
- Daily audits will be performed by all contractors on site. In addition,
twice each month, a comprehensive audit of the jobsite will be performed. A
representative of the subcontractors will be a safety audit participant in the
jobsite areas where their employees may be exposed to hazards. Any hazards
found during the audits will be corrected promptly. Items noted on the audit
will be annotated on a daily log. When hazards cannot be corrected immediately
they will be tracked until abatement is completed. Employees exposed to these
hazardous conditions will be informed of the hazard and an effective interim
control measures will be implemented. A record will be kept of all hazards
found during the comprehensive audits and the number of hazards corrected as a
result. (See Brasfield & Gorrie Daily Safety Log attached for an example)
- Implement an aggressive Fall Protection Plan to include fall protection in
all cases where work is being preformed 6 feet or more above lower surfaces.
- Ensure employees receive training as follows:
- Supervisory personnel will possess an OSHA 10-hour card or its equivalent. Brasfield & Gorrie will work with all subcontractors to provide their safety
designee with an OSHA 10-hour card, or its equivalent.
- All employees will receive a site-specific construction safety orientation
covering jobsite safety and health issues, procedures relative to the work
being performed, as well as the requirements outlined in the Partnership
Agreement. In addition, employees shall receive training on the content of the
Risk Assessment for operations they will encounter. This may require periodic
retraining of employees on the content of the Risk Assessment as they become
relevant due to entering new phases of construction. This material will be
provided by Brasfield & Gorrie to the Subcontractor’s designated safety
representative for completion.
- Safety and health training will be provided to all workers in a language
they understand. Bi-lingual Instructors will be contracted to perform this
training. A list of instructors will be provided by Brasfield & Gorrie to all
subcontractors to ensure that all workers are effectively trained.
- Other hazard-specific training will be conducted on an as-needed basis.
- Subcontractors can utilize other instructors as long as they can show a
valid certification card showing completion of the course. Brasfield & Gorrie
Contractors have primary responsibility for coordinating this training;
however, as resources allow Georgia Tech will also provide assistance.
Brasfield & Gorrie plans to hold 10-hr Safety Training Sessions every 4 months
to help train all personnel as schedule allows.
- Subcontractors with written safety and health management systems must
submit them to Brasfield & Gorrie for evaluation. Companies without safety and
health management systems may adopt Brasfield & Gorrie’s, or develop an
adequate safety and health management system with the assistance of the
Georgia Tech Research Institute Onsite Consultation Program.
- Ensure health-related issues which occur during the course of the project
are adequately addressed by Brasfield & Gorrie and/or the affected
subcontractors, with the assistance of OSHA as its resources permit and
Georgia Tech. All health-related issues will be discussed monthly during the
partnership meetings.
- An effective hearing conservation program, including noise monitoring and
engineering controls, where possible, will be implemented by Brasfield &
Gorrie Safety Department.
- An effective environmental monitoring program will be implemented to
control airborne hazards, such as silica, and will include personal
monitoring, employee training, implementation of engineering controls where
possible, and the use of respiratory protection when necessary. Previous
site-based data will be considered acceptable.
- Ensure compliance with the NFPA 70E when working on live electrical
equipment, including training and the availability and use of personal
protective equipment. A permit system will be implemented whenever work around
live electrical systems will be done to ensure the implementation of
appropriate protective measures prior to exposure. The permit form includes
requirements for pre-task review and lock out/tag out procedures to be
followed.
- Ensure all equipment capable of amputations is adequately guarded.
- Brasfield & Gorrie will explore the possibilities of extending training
opportunities to hospital personnel and area contractors based on relevance of
the topics and availability of space.
- ANNUAL EVALUATION
The program will be evaluated on an annual basis through the use of the
Strategic Partnership Annual Evaluation Format as specified in Appendix C of
OSHA Instruction CSP 03-02-002, OSHA Strategic Partnership Program for Worker
Safety and Health.
It will be the responsibility of Brasfield & Gorrie’s Contractors to gather
required participant data to evaluate and track the overall results and
success of the Partnership Program. This data will be shared with OSHA. It
will be the responsibility of OSHA to write and submit the annual evaluation.
- BENEFITS
Participant benefits from OSHA may include:
- Maximum penalty reductions allowed in the OSHA Field Operations Manual
(FOM) for good faith and history. When calculating the initial penalty
reduction, OSHA may provide an additional 10% reduction for good faith; beyond
the 25% reductions provided in the FOM where the employer, in implementing the OSP, has taken specific significant steps beyond those provided in the FOM to
implement the OSH Act and achieve a high level of employee protection (see
FOM, Chapter IV.C.2.1.5 (b)). This additional reduction will not apply to high
gravity serious, willful, failure to abate or repeat citations. In cases where
a partner’s total penalty reduction is 100 % or more, the minimum penalty
provisions of the FOM will apply (see FOM, Chapter IV.C.2.b).
- In the event that a citation with penalties is issued, the Area Director
has the authority to negotiate the amount of an additional penalty reduction
as part of the informal conference settlement agreement.
- Upon successful completion of one verification inspection within 4 months
of the implementation of this agreement, the site will be excluded from a
scheduled General Inspection for twelve months.
- Priority Consultation service and assistance for small employers working on
the construction site from the Consultation program.
- OSHA INSPECTIONS AND VERIFICATION
- Verification Inspections: OSHA will conduct the initial verification
inspection no sooner than three months, but within four months after
partnership participants formally enter into this agreement. During this
period participants should develop and implement the safety and health
management systems required under this agreement. After this period, OSHA will
conduct the initial verification inspection and annually thereafter. The
verification inspection will be conducted as a focused inspection, per the
appropriate OSHA guidelines. Compliance officers that are familiar with the
Phoebe Sumter County Hospital Partnership will do verification inspections.
Employee rights under the OSH Act will be afforded. During the verification
inspections, if OSHA personnel identify serious hazards that site management
refuses to correct, the scope of the inspection may be expanded.
- Complaint/Referral 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/referral related to
the work site and filed with OSHA will be forwarded by fax, or by CSHO, to the
Phoebe Sumter County Hospital Project Construction Project Management office
onsite. In accordance with applicable law, the name of the complainant
requesting confidentiality will not be revealed. Brasfield & Gorrie agrees to
investigate these complaints, regardless of the employer involved and provide
OSHA with a written response within 5 working days.
- Accident Investigations: Employers engaged in this partnership recognize
that OSHA fully investigates accidents involving a fatality or serious
physical harm. If during the course of the investigation OSHA determines that
the incident resulted from violations of the OSHA standards, the employer will
not be afforded partnership benefits.
- Once a verification inspection has been conducted at the site, which
reveals that the site has adequately assessed and/or controlled/prevented
employee exposure to hazards at the Phoebe Sumter County Hospital Project,
then the site can be deferred from programmed inspections for twelve months,
in accordance with the current OSHA Instruction CSP 03-02-002, OSHA Strategic
Partnership Program for Worker Safety and Health.
- EMPLOYEE/EMPLOYER RIGHTS AND RESPONSIBILITIES
This Partnership does not preclude employees and/or employers from exercising
any right provided under the OSH Act, nor abrogates any responsibility to
comply with rules and regulations adopted pursuant to the OSH Act.
- TERMINATION
It is understood that this agreement shall be in effect until completion of
construction activities at the Phoebe Sumter County Hospital Project
Construction Site, but in no case longer than three-years. Should any
“signatory” stakeholder choose to withdraw prior to project completion, a
written notice shall be given stating the reason(s) and providing 30 days
notice to the other party(s).
If OSHA chooses to withdraw its participation in the Partnership, the entire
partnership is terminated. Any party may also propose modification or
amendment of the agreement.
Changes to the partnership may be implemented if all parties are in agreement
that it is in the best interest of all members involved.
- PHOEBE SUMTER COUNTY HOSPITAL PROJECT - OSP SIGNATURE PAGE
Partnership Signing Date: _____________________
Robert Vazzi
Area Director
Occupational Safety & Health
Administration (OSHA) |
|
Mike Tate
Brasfield & Gorrie, LLC
Division Manager |
| |
|
|
Daniel J. Ortiz
Program Manager, Georgia Tech
Research Institute’s, Safety,
Health & Environmental
Technology Division |
|
Trey Sanders
Brasfield & Gorrie, LLC
Regional Vice President |
| |
|
|
Danny Pinion
Senior Superintendent
Brasfield & Gorrie, LLC |
|
Lisa Capicik
Safety Director
Brasfield & Gorrie, LLC |
| |
|
|
Brian Smith
Senior Project Manager
Brasfield & Gorrie, LLC |
|
Robert Pope, CHST
Safety Manager
Brasfield & Gorrie, LLC |
| |
|
|
Todd Taylor
Operations Manager
Brasfield & Gorrie, LLC |
|
Kenneth Underwood
General Superintendent
Brasfield & Gorrie, LLC |
1Days Away from work, Restricted, or job
Transferred (DART) rate: This includes cases involving days away from work,
restricted work activity, and transfers to another job. It is calculated based
on (N / EH) x (200,000) where N is the number of cases involving days away,
and/or restricted work activity, and/or job transfer; EH is the total number
of hours worked by all employees during the calendar year; and 200,000 is the
base number of hours worked for 100 full-time equivalent employees. For
example: Employees of an establishment including management, temporary, and
leased workers worked 645,089 hours at this worksite. There were 22 injury and
illness cases involving days away and/or restricted work activity and/or job
transfer from the OSHA 300 Log (total of column H plus column I). The DART
rate would be (22 / 645,089) x (200,000) = 6.8.
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