Article I. Background
In past years, the National Park Service (NPS) has experienced the highest employee injury and
illness rates of all Department of Interior (DOI) bureaus. Recognizing this problem, the NPS
approached the Occupational Safety and Health Administration (OSHA) asking for help in improving the
employee safety and health programs at establishments with high Lost Time Case Rates (LTCR).
As a result, Grand Teton National Park and OSHA enter into this Agreement pursuant to the authority
of the NPS Organic Act of 1916, 16 U.S.C. 1-4, Sections 19 and 24 of the Occupational Safety and
Health Act of 1970, and Executive Order 12196 that allows OSHA to provide assistance to specific
sites categorized as National Parks, National Recreation Areas, and National Seashores.
Article II. Objectives
- Develop and implement an effective comprehensive safety and health program in accordance with 29
CFR Part 1960 B Basic Program Elements for Federal Employee Occupational Safety and Health Programs.
- Reduce the total case rates (OSHA 200 Recordable Log) for Grand Teton National Park by 3% per year.
- Reduce the Lost Time Case Rate (LTCR) for the park by 10% per year.
- Reduce the OWCP claims at the rate specified in the GPRA goals.
- Identify and correct the primary causal factors in employee injuries and illnesses, in particular
those behind the three top causes of injuries and illnesses.
- Improve employee productivity and quality of life by providing safe and healthful occupational
environments.
Article III. Statement of Agreement
OSHA, Grand Teton National Park, and the Park’s union (the International Brotherhood of Electrical
Workers (IBEW) Local 322) agree to work in partnership to improve employee safety and health at
Grand Teton National Park. Accordingly, they make the following commitments:
The OSHA Billings Area Office Will:
- Help identify programmatic needs at the park site by reviewing the Safety and Health Program and
providing practical help in implementing the program;
- Help identify the primary causal factors in injuries and illnesses, in particular the three top
hazards at this site, and develop countermeasures for correcting those hazards;
- Provide access to training resources including:
- A safety management training session for division chiefs, first line supervisors and employees;
- Lockout/Tagout training;
- Confined Space Entry training;
- Construction Hazards training;
- Lead, Silica, and Asbestos training;
- Fall Protection training;
- Guidance to other available sources of training.
- Assist NPS safety and health professionals by offering the following technical assistance:
- Practical abatement assistance;
- Technical equipment loans (e.g, air monitoring meters);
- Air monitoring assistance;
- 1-800-488-7087 Telephonic Assistance.
Grand Teton National Park Will:
- Provide a written policy statement from the Superintendent as a part of the introduction to the
Safety and Health Program that identifies safety as the first priority for every job.
- Post copies of this signed agreement and the written safety policy at key locations.
- Have top management officials, including division heads and union leadership, attend a program
presented by OSHA on basic safety management.
- Commit to implementing the Safety and Health Program and achieving the objectives of this
agreement.
- Ensure that employees participate in developing and managing the safety and health program by
soliciting participation of workers and their representatives in hazard identification and abatement
and in employee training.
- Participate in implementing a comprehensive Safety and Health Program at the Park which includes:
- investigations of the root causes of all serious accidents and “near misses” and provides reports
of corrective action(s) taken, if any;
- Implementation of a decision-making protocol for determining when rescue operations will be
carried out;
- Continued implementation of the Park’s “chemical greening” program;
- Evaluating the need for long-term medical surveillance to be provided for employees exposed to
harmful agents such as asbestos, lead, and silica;
- Employee attendance at all related meetings;
- Employee access to all documents pertinent to the safety and health program and this agreement;
- Supporting the existing Safety, Health and Environmental Awareness committee; and
- Employee access to the OSHA 200 Log.
- Ensure that employees are not subject to restraint, interference, coercion, discrimination, or
reprisal for filing a report of an unsafe or unhealthful working condition, or other participation
in the Safety and Health Program or this agreement.
- Implement a system of accountability for safety that includes rewards, consequences, behavior
modification, and inclusion of safety in all performance standards.
- Annually commit a percentage of the park funding to address safety and health concerns and issues.
- Continue the system of internal safety and health self assessments including action items and
follow-up.
- Identify and correct safety and health hazards in all locations within the park.
- Ensure union participation in the Safety and Health Program.
- Provide safety oversight for contractors operating within the park.
Article IV. Verification Process
Both parties will evaluate the agreement on an annual basis to determine progress towards the stated
objectives. This evaluation will include an on-site evaluation, and will include elements such as:
- The safety and health program will be evaluated using OSHA’s “Form 33” or a substantially
equivalent evaluation tool to be determined by the parties. The results of these evaluations will be
compared to a baseline assessment which will be conducted in calendar year 2001;
- Progress towards the desired reductions in the lost time case rate and total case rate will be
evaluated by comparing rates derived from the OSHA 200 log. Data from calendar year 2001 will be
used as a baseline. The parties will also track anticipated reductions in the Park’s OWCP rate;
- GTNP will also track various activity measures such as the number of self-assessments conducted
within the park, the number of hazards identified and corrected, the number of employees who
received training on a safety and health related matter, and the number of employees removed from
risk.
Article V. Programmed Inspections
All formal complaints, serious accidents, and fatalities will be inspected by OSHA. Complaint
inspections will be limited in scope to the complaint items only, in accord with agency procedures.
Accident and fatality investigations will be conducted in accord with agency procedures.
Article VI. Terms of Agreement
This agreement will run from August 28, 2001, through December 31, 2004. The agreement will be
reviewed at the end of 2004 by both parties and may be renewed by simple letter of renewal signed by
both agency representatives; Superintendent of Grand Teton National Park and Area Director, OSHA,
Billings, Montana. The agreement may be updated through the time of renewal or, at any time prior to
renewal by mutual agreement of both agency representatives noted above.
Article VII. Key Officials
The key officials in this agreement include the Superintendent of Grand Teton National Park, and
Area Director of OSHA at Billings, Montana. Other key officials include the Assistant Superintendent
of Grand Teton National Park, the division chiefs of the park, and the Park Safety, Health and
Environmental Awareness Committee, and the Regional Administrator (Region VIII) and other designated
officials of OSHA.
Article VIII. Payment
The above technical and program development assistance, training, etc., from the OSHA Area Office at
Billings will be provided without requiring compensation from the NPS. Assistance from other OSHA
offices may require compensation from NPS, but will be determined on a case-by-case basis. Any such
compensation to OSHA’s other offices to accomplish the objectives of this agreement will be
transferred according to the policies of the agencies, and the respective departments of which these
agencies are a part.
Article IX. Termination
Either agency may cancel the agreement by notifying the other agency at least 60 days in advance.
Reason(s) for cancellation of the agreement will be stated in the notice of cancellation.
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Steven F. Iobst
Acting Superintendent, Grand Teton National Park |
Date |
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Adam M. Finkel, Sc.D., CIH
Regional Administrator (VIII) OSHA |
Date |
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David DiTommaso, Area Director
OSHA |
Date |
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