I. Identification of Partners
Holder Construction Company and the Denver Area Office of the Occupational Safety and Health
Administration (OSHA) mutually recognize the importance of providing a safe and healthful work
environment for employees engaged in the construction industry. This strategic partnership will
heighten the visibility of OSHA at the Hines 1515 Wynkoop Office Building in Denver, Colorado.
Holder Construction Company, which was established in 1960 in Atlanta, Georgia, employs more than
600 workers in locations in Atlanta, Georgia; Phoenix, Arizona; and Washington, D.C. The project is
located at 1515 Wynkoop St., Denver, Colorado. The project consists of constructing a $58 million,
390,000 square foot commercial office building. There will be approximately 12 subcontractors with
300-400 employees working at the site throughout the duration of the project. It is expected to take
24 months to complete. All contractors and their subcontractors that work on this project will be
considered Partners.
A Partnership Committee will be formed and it will be comprised of the Holder Construction Company’s
Corporate Safety Director, Superintendent, and Safety Coordinators, and the Compliance Assistance
Specialist from the Denver Area Office.
II. Purpose and Scope
This partnership represents a voluntary agreement which affords Holder Construction Company an
alternative to traditional OSHA enforcement. The purpose of this partnership is to foster open
communication among OSHA, Holder Construction Company, subcontractors and tier-subcontractors.
III. Goals, Strategies and Performance Measures
| |
GOALS |
STRATEGIES |
MEASURES |
| 1. |
a. Maintain the aggregate site DART rate for all
subcontractors at least 10% below the national average for SIC code 17xx (NAICS 238xxx) for the
duration of the project.
b. Maintain Holder’s site DART rate at least 20% below the national average for SIC code1542
(NAICS 236220) for the duration of the project. |
- Establish proactive measures for the common hazards found at construction sites.
- Use best methods practices.
- Provide all necessary engineering controls, administrative controls and personal protective
equipment.
|
Calculate aggregate DART rate for all site
contractors from OSHA 300 logs (maintained by Holder site safety representative) and compare to
the most recent BLS data |
| 2. |
a. Ensure that all project supervisors (Holder and
all subcontractors receive at least 10 hours of safety and health training.
b. Ensure that all site workers receive at least 2 hours of safety and health training on the four
major construction hazards, including, electrical, falls, struck-by (including work zone safety
issues) and caught in/between. |
- Conduct weekly toolbox safety meetings.
- Conduct 10 and 30 hour OSHA training courses.
- Keep open door safety policy.
- Conduct Pre-Task Safety Planning.
- Conduct site orientation training for subcontractors
|
- Minutes of tool box meeting will be used to track and document attendance.
- Course rosters to be used to track number receiving training.
|
| 3. |
a. Identify and prevent the most common causes of
workplace injuries and illnesses in the construction industry, included but not limited to: falls,
electrical safety, struck-by (including work zone safety issues), caught in/between, silica,
cranes and noise.
b. Identify work operations where employees may have exposure to hexavalent chromium, especially
welding operations on stainless steel (or other coated materials which may contain hexavalent
chromium) and application of coatings containing hexavalent chromium. |
- Provide weekly toolbox safety meetings and conduct 10 and 30 hour OSHA training courses.
- Use best methods to prevent injuries and illnesses of the most common hazards in the
construction industry.
- Conduct monthly comprehensive site audits and daily (and weekly) site walk through.
|
- Site safety personnel will conduct daily, weekly and monthly audits to ensure that the most
common hazards are addressed. The findings and recommendations of each inspection will be
reviewed at monthly safety and health meetings.
- OSHA log 300 will be used to track the number of work-related injuries and illnesses.
- Track incoming safety issues, suggestion forms and complaints to resolution and document
communication with employees.
- Investigate and document all significant incidents, near misses, saves, etc., detailing
corrective action taken if any.
|
| 4. |
One hundred percent (100%) of contractors and
subcontractors to have comprehensive written safety and health programs. |
Written safety and Health programs will be required
for all contractors, subcontractors and tier-subcontractors. |
Holder will require and maintain copies of all
contractors, subcontractors, and tier-subcontractors S&H programs. |
IV. Evaluation
A joint evaluation of the partnership will be prepared annually by the partners. The evaluation will
review the success of the partnership, lessons learned, and identify any modifications made to meet
the goals of this agreement. The annual evaluation will be in writing and in accordance with the
Appendix C of OSHA Directive CSP 03-02-002, OSHA Strategic Partnership Program for Worker Safety and
Health, effective date of February 10, 2005. The first annual evaluation will be due within 2 months
after the date of signing of the partnership agreement; subsequent evaluations are due annually
thereafter.
V. Verification
On-site Verification Enforcement Inspections
OSHA will conduct one unannounced verification inspection each calendar year during the duration of
the project to assess the implementation of the partnership agreement. These inspections will follow
Focused Inspection protocol and will be conducted in accordance with paragraph XIV B.4 of OSHA CSP
03-02-002: OSHA Strategic Partnership Program for Worker Safety and Health by a compliance officer
familiar with this agreement.
Violations of standards, regulations or the General Duty Clause found during verification
inspections may result in citations. Inspections conducted in response to complaints and referrals
may qualify as a verification inspection if, in addition to addressing the complaint or referral
items, the compliance officer completes the focused inspection protocol for the entire work site.
All employees’ rights under the OSH Act will be afforded.
If OSHA determines that any site subcontractor, under the control and direction of Holder
Construction Company, does not meet the requirements set forth in this partnership agreement, the
OSHA inspection of this subcontractor’s work will proceed in accordance with the traditional OSHA
protocol for comprehensive inspections.
VI. Benefits
OSHA will provide the following benefits to employers at the 1515 Wynkoop Office Building project:
- OSHA will provide outreach, technical assistance and training including:
- Visit the site to assess and review the implementation of the partnership and to provide
opportunities for the partners and others to discuss potential challenges and further improvements
to the partnership.
- Share information about the results of safety and health audits, including near miss and accident
investigation reports, attend post-audit meetings, and assist and advise the partners.
- Conduct specific training at the request of Holder Construction Company for site employees and
contractor management personnel (i.e.: review of new hexavalent chromium regulation, NFPA 70E
issues, open forum for Q&A with Compliance Assistance Specialist(s), facilitate vendor sponsored
training, etc.)
- Upon successful completion of an onsite verification inspection, the site will be deleted from
any programmed inspection list for up to one year from the date of the verification inspection.
- In the event that citations are issued during verification or other inspection activity, OSHA may
provide an additional 10 percent penalty reduction for good faith beyond the reductions provided for
in OSHA Instruction CPL 2.103 Field Inspection Reference Manual (FIRM). However, the additional
reduction will not apply to high gravity serious, willful, failure to abate, or repeat citations.
OSHA will not issue citations for other-than-serious violations provided the violations are abated
at the time of the inspection.
VII. Management and Operation
- Partnership Committee Roles and Responsibilities
A partnership committee will be formed to manage the operation of this partnership agreement. It
will consist of the Holder Safety Representatives and the OSHA Compliance Assistance Specialist. A
Holder Safety Representative will serve as the chairperson, the Site Safety Coordinator and as
OSHA’s primary contact. The Holder Safety Representative will review contractor compliance and
involvement in the partnership, analyzes job site audits, make partnership improvements, evaluate
partnership modifications, achievements and success. The partnership committee will convene on a
quarterly basis to review implementation of the partnership.
The Holder Construction Company agrees to exercise control over any recognized site safety or health
hazard identified during comprehensive self-inspections, and to eliminate the potential for injury
or illness in accordance with this partnership agreement. The on-site safety representative will
report any findings directly to the appropriate contractor/subcontractor.
- OSHA Enforcement for Unprogrammed Inspections
This partnership provides for immediate employer response to each allegation of a safety or health
hazard brought to its attention by any employee or employee representative. Upon a finding that an
allegation is valid, the employer shall promptly abate the hazard.
This partnership site will receive unprogrammed inspections only in response to a fatality,
catastrophe, serious injury, formal complaint, or either the referral of, or the visual observance
of, a high-gravity serious hazard on-site. Colorado OSHA will use telephone or fax to handle all
other complaints except those cases involving serious injuries. When an inspection of a non-formal
complaint is deemed necessary, a copy of the complaint will be provided to the participant’s Safety
Director or other designated representative at the time of inspection.
Employers engaged in this partnership recognize that OSHA fully investigates accidents involving
death or serious physical harm. If OSHA, during the course of the accident investigation, determines
that the incident resulted from violations of an OSHA standard, the employer will not be afforded
partnership incentives.
VIII. Employee and Employer Rights
This partnership does not preclude employees and/or employers from exercising any right provided
under the OSH Act, nor does it abrogates any responsibility to comply with rules and regulations
adopted pursuant to the Act.
Employees will be encouraged to participate in the implementation of the overall safety and health
program, and to participate in self-audits, self-inspections, job hazard analyses, and accident
investigations.
IX. Partnership Terms
This agreement will terminate upon completion of the project. If any signatory of this agreement
wishes to terminate their participation prior to the established termination date, written notice of
the intent to withdraw must be provided to all other signatories.
If OSHA chooses to withdraw its participation in the partnership, the entire agreement is
terminated. Any party may also propose modification(s) or amendment(s) to the agreement.
X. SIGNATURES
Herb Gibson
Area Director
Occupational Safety and Health Administration (OSHA) |
Date |
David M. O’Haren
Executive Vice President
Holder Construction Company |
Date |
Lance Wafler
Superintendent
Holder Construction Company |
Date |
Burton Farris
Safety Director
Holder Construction Company |
Date |
|
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