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The United States Department of Labor Occupational Safety and Health
Administration, The Louisiana Forestry Association, and The Louisiana Logging
Council have recognized the importance of providing a safe and healthy workplace
for the Louisiana employees engaged in logging activities. Always seeking
innovative ways to achieve this goal these three organizations have mutually
agreed to enter into a partnership agreement that sets forth specific protocols
that they feel will have a direct and positive impact on the Louisiana worker.
Agreed this day, May 17,2000
- To collect and analyze injury data to determine the problem areas at the
logging worksite in order to reduce fatalities, injuries and illnesses in the
- To share knowledge and information of the best industry practices to educate
the members in the safest performance of the job tasks.
- To improve safety and health programs by involving employees in every aspect
of the site inspection process.
- To promote a cooperative relationship between the undersigned parties and
establish a mutual respect.
John J. Deifer
Baton Rouge Area Office
U.S. Department of Labor OSHA
Charles A. Vandsteen Executive Director
Louisiana Forestry Association
De s R. Aucoin President
Louisiana Logging Council
U.S. DEPARTMENT OF LABOR
SUBJECT: OSHA Strategic Partnership
Occupational Safety and Health Administration Region VI
- Purpose: This instruction provides the background and procedures to establish
a limited strategic partnership between OSHA and the Louisiana Forestry
Association/Louisiana Logging Council. The intention of this partnership is to
improve worker safety and health in the logging industry.
Scope: This instruction applies to logging operations in the State of
Action: The Baton Rouge Area Office will carry out the project following the
procedures described in this instruction.
Background: The logging industry has long been known as one of the most
dangerous occupations in America. In the last decade, some improvement in
logging safety has been realized. Logging employers that practice safety and
health . management experience notable improvements in safety performance. Much
of the improvement is credited to the progressive actions of organizations such
the Louisiana Forestry Association and the Louisiana Logging Council that have
created policies and processes to improve logging safety among their members.
Even with these efforts the state of Louisiana has experience<;l6 fatalities in
the logging industry within the last 12 months.
It has been difficult and time consuming to target and find logging contractors
for compliance inspection activities. The geographic range of work site
locations covers practically the entire state and the logging employees are
located at a specific work site for a relatively short duration. OSHA proposes
that a partnership that encourages training and education coupled with self
inspection will reduce the most common hazards associated with the logging site
while leveraging OSHA resources and as a result will produce a safer workplace.
Goals and Objectives
The partnership goal is to enhance the safety and health of the 1500 covered
employees involved. This supports OSHA's Strategic Plan as SIC 2411 is one of
the targeted industries and all indicators point to high injury rates and
fatalities in this Louisiana industry .
- To identify possible trends in accident data obtained from partnership
members and to ultimately reduce injuries and illnesses in the Louisiana logging
industry through effective partnership commitments.
To assist employers to improve their safety and health programs by conducting
. training programs, by providing current accident data and corrective measures
to the Louisiana Logging Council, and by supporting logging safety programs
currently in place by the logging industry.
To better utilize BRAO resources by using a partnership tool to reduce the
need for on-site visits by compliance officers while achieving a higher level of
worker safety and health.
To provide maximum leveraging of inspection resources by promoting more
active employer action and responsibility in safety and health management.
To promote a cooperative relationship among the Louisiana Forestry
Association, the Louisiana Logging Council, OSHA, and the Louisiana logging
Partnership Proposal Requirements
An interesting analysis of the nature and trend of logging injuries in the state of
Louisiana was conducted in 1997 by Cornelis F. de Hoop, professor, at
Louisiana State University Agricultural Center in Baton Rouge, Louisiana. This
study compiled from worker comp data identified high incident rates that ranged
from 19.98 in 1987 to 13.71 in 1990. The approach that this partnership will
utilize appears to be consistent with the conclusions drawn by Mr. de Hoop.
Using the more recent accident data that this partnership supplies the analysis
will be compared to Mr. de Hoop's 1997 study to ascertain if the same injury problem exists. Once
specific problems are identified, pro active measures to mitigate these problem
areas will be developed.
Identification of Partners
As of this writing 150 individual logging contractors have agreed through the
Louisiana Logging Council/La forestry Association to participate in this
strategic partnership. The average workforce of each contractor is 10 employees,
resulting in coverage for approximately 1500 Louisiana workers. These
contractors are members of the Louisiana Logging Council and have submitted
their request to be partnership participants to Mr. Clyde Todd) program
coordinator, of the Louisiana Forestry Association, which represents the
Council's interest in the state of Louisiana.
Data Collection and Analysis
The 150 individual contractors have agreed to submit accident and illness data
for the years 1999 and 1998 to Mr. Todd who will sanitize the information and
forward the data to the BRAO. This information will be analyzed by the BRAO
Strategic Team and a representative from the 7 (c) (1) Louisiana OSHA
Consultation Program. Professor de Hoop has volunteered to assist in comparing
this recent data to his own facts and lending his resources in establishing
trends. After a careful and thorough evaluation. possible solutions to the
discovered problems will be devised and disseminated to the partnership
contractors through the Louisiana Forestry Association's information system.
This infonnation will be the basis for the implementation of the contractor self
audit program. In addition to the regular inspection of the job site by the
competent person, the contractor will be asked to focus on the areas that have
created the most injuries and implement the solutions and/or pro-active measures
recommended by the data collection and analysis team. The measurement system
will be a two pronged approach. The verification inspection which focus on these
hazards should result in no serious violations of OSHA regulations and accident
data collected for the year 2000 and analyzed in year 2001 should reflect lower
incidents in these specific areas.
Safety and Health programs
A commitment has been made by all signatory logging contractors to establish a
written safety and health program. A manual of logging safety has been prepared
through a combine4 effort of Louisiana Forest Products Laboratory, Louisiana
Logging Council, Louisiana State University Agricultural Center, and the
Louisiana Forestry Association. Each contractor has been provided a complete
manual and in addition is required to complete at least 6 hours of continuing
education each year. The training is conducted in a formal setting utilizing
safety and health professionals from around the United States. This partnership
intends to strengthen and enhance this worksite safety and health program by
utilizing OSHA'S 1989 Safety and Health Program Management Guidelines.
OSHA has long recognized that successful safety and health programs encourage
strong employee participation and involvement. This OSHA Strategic Partnership
recommends that the employees are invited to engage in activities such as, but
not limited to, delivering training to current or newly hired employees,
developing and using a system for reporting hazards, conducting site inspections
for recognition of hazards, and making presentations at safety meetings. Safety
programs that are employee driven will ultimately result in a safer workplace.
As the partnership members have made a strong commitment to attempt to improve
their worksite safety, OSHA now offers incentives for this commitment. The BRAO
will provide the Council information on the most frequently cited standards
during recent logging inspections conducted in Louisiana. The BRAO will provide
upon request training and education at neutral sites and assist in providing
continuing education for the members. The BRAO will provide detailed information
subject to FOIA regulations to the Council concerning the 6 fatalities that
occurred recently in Louisiana. This information will be in the form of OSHA's
Fatal Facts reports so that the council can share the details of these accident
investigations with the members. The Louisiana 7(c)(l) Consultation Project
Manager has agreed to assign priority consideration to request from partnership
members for on site consultative visits. OSHA agrees to reach a consensus with
respect to the methods used to provide positive publicity about the OSHA
Strategic Partnership and the pa~nering establislunents. And finally OSHA agrees
to provide technical assistance not only from the BRAD but also from the
National and Regional offices.
To ensure that the partnership procedures are being effectively transferred to
the work site, verification inspections will be conducted. It has been decided
that 10% of the partnership members will receive verification audits. The scope
of the inspections will focus on the• hazards identified in the data collection
and analysis process. These areas have not been detennined at this time but
should be similar to the requirements contained in the existing regulations at
29 CFR 1910.266. Although the scope of the inspection will be focused, all
current OSHA policies will apply including the issuance of citations and
penalties for violations of the standards, regulations, or the general duty
clause. The results (sanitized to protect identity of the employer) of the
audits will be shared with the partnership members.
OSHA compliance inspections will be conducted in the state of Louisiana during
FY 2000. These inspections will be conducted under the authority of OSHA
Instruction CPL 2.102, instruction for Local Emphasis Programs. A list of
logging contractors will be obtained and a specified number will be selected for
comprehensive inspections using a random selection process. It is possible that
a partnership member will be selected using this random selection method. In
this event the compliance officer should be informed at the opening conference
that the employer is a member of this OSHA Strategic Limited Partnership. At
this time the compliance officer should initiate an inspection focusing on the
hazards identified by the data collection and analysis team. It is anticipated
that in most instances, the hazards that are the target of the Local Emphasis
program will parallel or closely relate to the hazards identified as most
serious by the partnership. All current agency policies will be applicable to
these inspections including citations and proposed civil penalties for serious
violations of the standards, regulations, or the general duty clause.
This Strategic Partnership will be evaluated and an evaluation report prepared
by March 1, 200 1. The member contractors will submit their accident and injury
data for calendar year 2000 to the Louisiana Forestry Association during the
month of January 2001. This data will be analyzed to hopefully show a reduction
in the types of injuries sustained during the previous data collection period.
The verification audits of member contractors will be compared to the inspections of non-member
contractors under the Local Emphasis Program. Comments will be solicited from
the individual partnering members, the Louisiana Forestry Association, and the
Louisiana Logging Council board of directors. These indicators will be used to
decide if the partnership will be terminated or be continued for a period of
time to be detennined by the Partnership members.