The United States Department of Labor Occupational Safety and Health Administration (OSHA) and the
Associated Builders and Contractors, Inc., Central Ohio Chapter (ABC Central Ohio) mutually
recognize the importance of providing a safe and healthful work environment for the nation’s
construction workforce. In working together as partners, we are committed to achieving a reduction
of injuries, illnesses and fatalities in the construction industry through means of open
communication, promoting recognition for construction safety excellence, and sharing knowledge of
the best industry technology, innovations and work practices that improve safety and health
performance.
I. Purpose and Scope
This partnership represents a voluntary agreement which affords ABC members with an alternative to
traditional OSHA enforcement. Expected outcomes of this partnership include:
- Reduction of injuries and illnesses in connection with construction activities in Central Ohio;
- Expanded contractor awareness of the value of safety and health management systems through shared
knowledge of the best industry technology, innovations and work practices that improve jobsite
safety and health.
- Enhanced leveraging of OSHA’s resources;
- Greater compliance with Occupational Safety and Health Standards;
- Increased Occupational Safety and Health training for construction workers; and
- Recognition and promotion of construction safety excellence through the ABC Safety Training and
Evaluation Process (STEP) Program.
Amended and Agreed this day, March 13, 2007
Deborah Zubaty
Area Director
U.S. Department of Labor OSHA
Columbus Area Office |
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Mary R. Tebeau
President
Associated Builders & Contractors, Inc.
Central Ohio Chapter |
Jack Kehl
Hilb Rogal & Hobbs
Immediate Past Chair (2006 ABC Chair)
Central Ohio Chapter |
II. Goals and Strategies
ABC has implemented a program to assist its member construction companies in evaluating their safety
performance and safety training programs. The program is known as the Safety Training and Evaluation
Process, or STEP program. The local and national offices of ABC each process all applications, and
in turn, present awards to qualified applicants.
ABC’s National Safety Committee created the STEP program in 1992. The National Safety Committee is
composed of construction safety professionals from ABC member companies throughout the United
States. Along with this national committee, ABC has over 60 safety committees formed in various
chapters across the U. S. and Guam. Safety committee members at these local chapters identify and
provide safety courses and seminars on safety compliance programs pertinent to their geographical
area. These committees convey concerns, stance on issues and other items of construction safety
interest to the National Safety Committee.
The STEP program has four award levels: Bronze, Silver, Gold and Platinum. Awards are given based on
self-evaluation score. Acceptance into the Platinum and Gold levels will require additional
validation of safety program efficacy, but will also confer certain incentives to participants from
OSHA, to be discussed further in this document.
ABC Central Ohio recognizes that the future of excellent construction safety programs is through the
Voluntary Protection Program (VPP) Challenge, and is now striving to promote the VPP construction
program to member firms through educational sessions and news alerts. ABC is currently researching
the feasibility of adding a construction safety expert to the Central Ohio office to assist members
in improving their safety programs. As the VPP Challenge for construction matures nationally, it is
the goal of ABC Central Ohio that a safety expert will be hired by the chapter to qualify for an
Administrator of the VPP Challenge for Construction.
The success of this program will be due in large part to cooperation between ABC and the Columbus
OSHA office, which has already provided numerous resources and assistance to ABC. This partnership
is one more example of the two organizations working together to improve occupational safety and
health in the central Ohio construction community.
Goals of this partnership are:
- Continue to reduce workplace injuries and illnesses annually by developing a comprehensive safety
and health management process approach. This approach consists of a joint employee and management
safety and health committee to develop and administer the following:
- Principals of Commitment;
- Comprehensive written safety and health program based on a task analysis;
- Relevant safety and health training for workers and supervisors;
- Inspections of worksites, documenting hazards and near miss accidents;
- Disciplinary procedure for violation of safety and health rules;
- Reviewing the company program at least annually.
- Provide construction worksites free from exposure to recognized hazards by:
- Conducting frequent and regular inspections and investigations of near-miss accidents;
- Developing and enforcing disciplinary procedures for employees violating safety rules.
- Increased Occupational Safety and Health training for construction workers:
- Training workers on relevant safety and health issues in the workplace;
- Participation in Competent Person Training for supervisor and management;
- Regularly sponsored “safety talks” on near miss accident and relevant task/hazard topics.
III. Performance Measures
Goal 1:
This partnership will attempt to reduce the number of incidents that have potential to result in
worker injury or illness with a goal of zero fatalities and lost time injuries. The company must
have a Days Away, Restricted and Transfer (DART) rate for work in Ohio at least 25 percent below the
Bureau of Labor Statistics national average for the firm’s North American Industry Classification
Code (NAICS).
- The company will submit DART rates for the past three years and will be evaluated on a three-year
average.
- If a company fulfills all other requirements, but does not have a qualifying DART, it may appeal
for inclusion in the partnership. OSHA and ABC will review these appeals on a case by case basis and
may allow the company to participate if improvement can be shown.
Goal 2:
Through frequent and regular inspections conducted by a competent person, all participants will
monitor and submit an Incident Worksheet on all accident and near-misses. Forms will be submitted to
the ABC office on a quarterly basis utilizing the worksheet to be provided. All information will
remain confidential as to company name and employee. The only purpose of this data is to assess
performance and to target specific training requirements.
Goal 3:
Outcome measures will be gathered annually and comprised of data analyzing the number participants
in the safety training, the number of competent persons trained and maintained, number of safety
talks and number of near misses reviewed and discussed amongst employees. Topics for the safety
discussions will include (but are not limited to) subjects of near misses incidents and other safety
concerns that are company-specific. These safety topics can be shared at quarterly safety
partnership meetings as a tool for all partners.
IV. Annual Evaluation
The annual evaluation shall use the Strategic Partnership Annual Evaluation Format measurement
system as specified in Appendix C of CSO 03-02-002, the OSHA Strategic Partnership Program for
Worker Safety and Health Directive.
Annually, each participant will submit to ABC the Safety Training and Evaluation Program (STEP)
evaluation, as discussed under item II, and achieve the Platinum or Gold level.
V. Periodic Inspections
Each participating member shall have one of their worksites inspected at least once per year by an
independent third party Occupational safety and health firm. Said firm must have either a Certified
Safety Professional or Certified Industrial Hygienist supervise the inspection. The results of the
inspection will be factored into the annual evaluation. Criteria for selecting periodic inspection
will be based on active construction sites, only when contractor representatives are available,
coordinated and scheduled with the contractor.
Criteria for Participation:
In order to qualify for participation, all contractors must comply with the terms of the partnership
criteria.
- Contractors will be required to develop and implement a safety and health program which includes
the following elements:
- Management commitment and leadership – provides the motivating force and the resources (time,
expertise, financial) for organizing and controlling activities within an organization. In an
effective program, management regards worker safety and health as a fundamental value of the
organization and applies its commitment to safety and health protection with as much vigor as to
other organizational purposes. Management serves as a role model in safety and health matters for
employees to emulate. Management commitment requires a leadership role when it comes to such matters
as planning, written programs, authority and resources, line accountability and contract worker
coverage.
- Employee Involvement – provides the means through which workers develop and/or express their own
commitment to safety and health protection, for themselves and for their fellow worker. Employee
involvement must be meaningful and without the fear of reprisals. Examples of employee involvement
include, but are not limited to:
- Conducting site inspections, safety and health audits, job hazard analysis, and other types of
hazard identification.
- Developing and using a system of reporting hazards.
- Developing and revising the site’s safety and health rules and safe work practices.
- Participating on workplace teams charged with identifying root causes of accidents, incidents or breakdowns.
- Participating on safety and health committees.
- Participation in safety and health reviews.
- Worksite Analysis – Involves a variety of worksite examinations to identify not only existing
hazards but also conditions and operations in which changes might occur to create hazards. Worksite
analyses can include, but are not limited to the following: physical inspections of the workplace to
observe existing and potential hazards, conducting accident and near-miss investigations of the
workplace to determine existing and potential hazards, evaluating trends in injuries and illnesses,
and conducting medical symptom surveys of employees.
- Hazard Prevention and Control – Triggered by a determination that a hazard or potential hazard
exists, the hazards are eliminated, where feasible, by effective design of the job site or task.
Where it is not feasible to eliminate them, they are controlled to prevent unsafe and unhealthful
exposure to workers.
- Safety & Health Training – Providing all employees with hazard recognition skills, along with the
means and methods necessary to protect themselves from potential hazards.
- The effectiveness of the safety and health program will be confirmed through a site visit
evaluation, performed an independent third party occupational safety and health firm, and consisting
of the following elements:
- Comprehensive on-site safety and health inspection;
- Review of written safety and health program and site specific plan;
- Review of training record;
- Review of OSHA 300 logs.
Any deficiencies noted in the evaluation that constitutes an OSHA-defined serious hazard must be
corrected in 30 days and documented by the contractor.
- The contractors will have the following enhanced safety and health requirements as well as all
other provisions of this agreement:
- A permit requirement and prior approval from the employer’s “Competent Person” for confined space
work, hot work and excavation work.
- Although providing mandatory fall protection at the 6’ level is not required by the current OSHA
construction standards and is not mandated by OSHA as a requirement for participation in any OSHA
partnership agreement, the contractors on this partnership are committed to providing a greater
level of protection to the employees and will require protection at the 6’ level and above.
- Mandatory use of Ground Fault Circuit Interrupters (GFCIs).
- Loads shall not be lifted over the heads of employees.
- Employees exposed to vehicular traffic shall wear reflective material.
- Appropriate protection shall be provided for all trench and excavation work.
- All scaffolding will have guardrails and cross braces.
- All machines will have proper safety guard.
- Partners will make a commitment to see that all employees, where necessary, will wear a hardhat
and eye protection while accessing, egressing, and working on jobsites.
- Provide hand washing or lotion facilities, where feasible, within close proximity to the
restroom facilities. The restroom facilities will be clean, in good repair, appropriately supplied,
and have a workable inside lock.
- Contractors will have Competent Personnel on each project that are responsible for, possess the
authority to, and are capable of effectively implementing the overall project-specific safety and
health program as well as their employer’s safety and health program.
- Contractors will ensure that supervisors on the jobsite have completed the OSHA 30-hour or
equivalent during the first year. All employees on the jobsite will have completed the OSHA 10-hour
or equivalent during the first year.
In the first quarter each year, contractors will submit to the ABC their STEP Application as well as
the summary injury/illness data records which document their DART (Days Away, Restricted or job
Transfer) and TCIR (Total case incidence rate) for all work in the previous year.
VI. Benefits
Employers meeting all necessary criteria for participation in this partnership, and upon acceptance
into the ABC partnership program, will receive from OSHA the following incentives to participants:
- When calculating the initial penalty reduction, OSHA may provide an additional 10 percent
reduction for good faith beyond the reductions provided in the FIRM where the employer has taken
specific steps beyond those provided in the FIRM to implement the Act and achieve a higher level of
employee protection (see FIRM, Chapter IV.C.2.i5 (b)).
- OSHA will provide offsite preconstruction technical assistance, or on an as needed basis through
the life cycle of the worksite, for the participating contractors and their major subcontractors
where appropriate, to review safety and health issues specific to the selected worksite. Such issues
shall normally include but are not limited to protection from the four leading causes of fatalities
on construction sites including falls, electrocutions, struck by, and caught in or between.
VII. OSHA Verification and Monitoring
Participants randomly selected from the partnership member list will have the effectiveness of their
safety and health programs verified through an unannounced onsite inspection by OSHA. The number of
OSHA onsite monitoring inspections will be a minimum of 5 percent and a maximum of 10 percent of the
participants annually, at the Area Director’s discretion, providing there are at least 10 partners.
At a minimum, there will be one OSHA onsite monitoring inspection annually. In addition, any OSHA
inspections of a participant’s job site can serve as a monitoring inspection. During the opening
conference, the selected inspection sites will be evaluated for a focused or non-focused inspection.
It is anticipated that sites qualifying for participation in this program would qualify for a
focused inspection. Focused inspections recognize the efforts of responsible contractors and
therefore will limit "Focus" inspections on the leading hazards responsible for 90 percent of
accidents. These areas include falls, struck by, caught in and between, and electrical. Inspections
shall be conducted in accordance with all current guidelines and national and regional office
policy.
VIII. Management and Operation
This partnership shall be administered by the ABC. Each partner shall designate a representative to
sit on the OSHA/ABC Partnership Committee. This team shall be responsible for administration of the
partnership, application review, and approval, as well as resolution of any issues which may arise
with the partnership in effect. The Columbus OSHA area office shall serve as an advisor to the
OSHA/ABC Partnership Committee.
The ABC Safety Committee will hold quarterly conference calls/meetings to track, analyze and share
information on partnership actives and results. At least annually, the OSHA/ABC Partnership
Committee will meet to evaluate the effectiveness of the agreement. This meeting will include:
- Evaluating data and partnership impact;
- Identifying ABC members with outstanding safety and health excellence;
- Share information on best practices that improve safety and health performance.
The Occupational Safety and Health Administration agrees to:
- Work with ABC and its members to provide free safety and health information, training and training
materials;
- Provide training materials, through ABC, to help employers understand and comply with OSHA
regulations and to implement effective safety and health management systems;
- Ensure that Compliance Safety & Health Officers are knowledgeable of partnership requirements and
objectives, and encourage them to provide assistance as requested by the ABC and/or its members;
- Not issue citations for other than serious violations, provided the abatement of violations is
observed by the compliance officer;
- Track, analyze and share information on activities such as:
- Current relevant OSHA inspection findings.
- Relevant regulatory interpretations.
- Current industry statistics.
ABC agrees to:
- Host committee meetings, quarterly and annually.
- Administer the program by providing staff support and facility usage.
- Promote program through monthly newsletter and other ABC sanctioned activities.
- Act as first point of contact for prospective contractors.
- Recruit and retain program participants.
- Provide resources to support program participants and prospective participants.
IX. Employee and Employer Rights
This partnership does not preclude employees or employers from exercising any right provided under
the OSHA Act, nor does it abrogates any responsibility to comply with rules and regulations adopted
pursuant to the Act.
X. Terms of OSP
This agreement will expire March 2008, which is one year from the date of signing. Should either
party choose to withdraw prior to that date, 30 days written notice will be given, and either party
may also propose modification or amendment of the agreement.
Participation will be terminated if one or more of the following occurs:
- A site inspection reveals eligibility requirements are not being met;
- A participant has falsified information on the application or supporting records;
- The participant takes other actions that may be determined to be grounds for termination by the
Area Director.
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