OSHA Strategic Partnership Program<< Back to Region VI



 
Department of Labor Louisiana Forestry Association Louisiana Logging Council

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.
  1. 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 logging industry.

  2. To share knowledge and information of the best industry practices to educate the members in the safest performance of the job tasks.

  3. To improve safety and health programs by involving employees in every aspect of the site inspection process.

  4. To promote a cooperative relationship between the undersigned parties and establish a mutual respect.
Agreed this day, May 17,2000



 
John J. Deifer
Area Director
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
Occupational Safety and Health Administration Region VI
Dallas, Texas

 
SUBJECT: OSHA Strategic Partnership
  1. 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.
     
  2. Scope: This instruction applies to logging operations in the State of Louisiana.
     
  3. Action: The Baton Rouge Area Office will carry out the project following the procedures described in this instruction.
     
  4. 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.

  5. 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 .
     
    1. 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.

    2. 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.

    3. 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.

    4. To provide maximum leveraging of inspection resources by promoting more active employer action and responsibility in safety and health management.

    5. To promote a cooperative relationship among the Louisiana Forestry Association, the Louisiana Logging Council, OSHA, and the Louisiana logging contractors.
       
  6. Partnership Proposal Requirements

    1. Overview
       
      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.

    2. 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.

    3. 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.

    4. 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.

    5. Employee Involvement
       
      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.

    6. OSHA Incentives
       
      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.

    7. Verification
       
      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.

    8. OSHA Inspections
       
      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.

    9. Program Evaluation
       
      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.