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January 24, 2016

  1. CRCA / OSHA Alliance Background

    Date Signed: January 24, 2014

    Alliance Overview:

    The alliance was developed to provide Chicago Roofing Contractors Association (CRCA) members and others with information, guidance, and access to training resources that will help them protect the health and safety of workers, particularly by reducing and preventing exposure to safety and health hazards in roofing, and understand the rights of workers and the responsibilities of employers under the Occupational Safety and Health Act (OSHA Act).

    Evaluation Period: This report covers the time period of January 24, 2015 to January 24, 2016.

    Implementation Team Members:

    • Mark Duffy, CRCA Co-Chairman Health & Safety Committee
    • Shawn Sullivan, CRCA Co-Chairman Health & Safety Committee
    • Bill McHugh, CRCA Executive Director
    • Linda McHugh, CRCA Administrator
    • Larry Joswiak, OSHA Assistant Area Director, Chicago North Area Office
  2. Implementation Team Meetings

    Besides the alliance/safety committee meetings, additional meetings and planning for projects are conducted via email and conference call.

    2015: March 25, 2015, June 10, 2015, and October 14, 2015.

  3. Activities and Products


    Three alliance/ safety committee meetings were attended by OSHA personnel and CRCA committee members, covering a variety of topics including OSHA jobsite inspections, current local and national emphasis programs, OSHA campaigns and initiatives. Topics included falls hazards, ladder safety, residential fall protection, quarterly Region V fatality report statistics, proposed and newly implemented rule changes, updated hazard communication requirements and heat campaign.

    The process involves an implementation team made up of management representatives of each organization, who met to develop a plan of action, determined working procedures and identified the roles and responsibilities of the participants. The implementation team met at least three times per year plus at the CRCA Annual Trade Show to track and share information on activities and results in achieving the goals of the Alliance, including the planning and implementation of all events and activities such as project groups, the annual trade show seminar planning and other alliance meetings. Examples of the education and activities completed to fulfill the alliance's objectives for the report period:

    • Safety Stand Down: Held nationwide from May 4-15, 2015, over 450 workers from CRCA member firms participated in the Safety Stand Down at construction sites throughout the Chicagoland area. These workers joined other construction personnel in the U.S. by voluntarily ceasing work for 30-60 minutes to provide focused training on how falls from ladders, scaffolds and roofs can be prevented by planning ahead and using the right safety equipment. These CRCA member firms presented focused safety training via tool box talks to non-management personnel. The training material was reviewed to ensure accuracy and consistency at all sites.
    • CRCA Membership Meeting: On Sept. 15, 2015, the CRCA Safety Consultant presented to approximately 150 CRCA Members that met to learn about current OSHA initiatives and trends in citations to be used in creating more comprehensive jobsite and other safety training. Recently updated standards were also reviewed including: Incident Reporting and Recordkeeping, Hazard Communication/Labeling, Confined Space, Employee Training, Competent Person description and more. Particular attention was given to fall protection, with areas of emphasis such as warning line use, safety monitor use, guardrails, proper use of body harnesses, hatch access and more.
    • CRCA Trade Show Safety Seminar: On January 22, 2016, 315 field and management representatives of roofing contractors (both CRCA Members and Non Members) attended an annual safety seminar at Drury Lane Conference Center in Oakbrook Terrace. The theme of this year’s seminar was “Stand Down For Safety 2016”. The programming was structured to mirror a typical OSHA Safety Stand Down with the goal of increasing safety for all through education on fall protection. The CRCA safety consultant presented data of the types of safety inspection deficiencies seen in 2015, breaking down by various types such as fall protection, fire protection, access between elevations, electrical, material storage/handling and personal protective equipment. The most frequently seen type of deficiency, fall protection, was further broken down to highlight areas such as lack of safety monitors, warning lines, PFAS, guardrail use, improper use of body harnesses, etc. This was done to help attendees identify safety areas where further education and reinforcement is needed. The seminar also included OSHA personnel presenting statistics on the Region V fatalities, emphasizing that falls account for the greatest amount of fatalities. This led to information on OSHA’s fall prevention campaign of Plan, Provide and Train, with an emphasis of fall hazards and the training to prevent accidents. OSHA presented effective methods to safely address such hazards as hole protection, hoist areas, in steep slope installation and more. The final segment of the seminar included a live demonstration of effective harness use by a vendor. This educational session also provided opportunity for a question and answer session where safety concerns from employers and employees were addressed with OSHA and CRCA educators. OSHA provided safety handouts in Spanish as well. In addition to the widely attended seminar, safety vendors were also available for attendees to learn about equipment and tools needed to develop safe roofing and waterproofing practices.
    • The CRCA Today: A magazine publication, published three times a year, with a hard copy distribution to 10,000+ Illinois and surrounding states’ roofing and waterproofing contractors as well as associated firms, provided a venue for OSHA's initiatives and safety education outreach. Such topics included a recap of the January 2015 safety presentation and promotion of the 2015 OSHA Safety Stand Down. The Summer, 2015 issue included information on the OSHA Hazardous Material Labeling requirement changes that occurred on 6/1/15 as well as prevention of heat emergencies, ladder safety and reinforcement of hazard communication solutions. The Fall/Winter issue included information on the revised OSHA’s penalty structure, rooftop access policies and responsibilities, tips on safe snow removal as well as an article on harness safety. (While all safety articles are geared to roofing and waterproofing industry safety, both the 10,000 hard copy distribution as well as the 6,000+ electronic distribution includes general contractors, material suppliers, building officials and others involved in construction in the readership.)
  4. Results

    OSHA has established a relationship with the Chicago Roofing Contractors Association and maintained open communication with their members. The annual CRCA Trade Show safety seminar is well-received and provides an opportunity for question/answer session(s) with the stakeholders and open dialogue about current issues and trends affecting their industry. They also provide an avenue to highlight fatality/injury trends in the industry within Region V as well as inform employers and employees of current OSHA enforcement initiatives/regulations.

    The implementation team goal was to meet four times and the team met three times during the evaluation period.

    Non-management employee involvement did not take place in the planning and implementation phases of all events and activities for the evaluation period as agreed to in the signed Alliance Agreement between OSHA and the CRCA. Employee involvement had been discussed prior to the signing of the Alliance Agreement and during the evaluation period at many meetings. Suggestions were made on how to achieve employee involvement. However, no action was taken to institute employee involvement other than to have employees attend the trade show seminar, membership meeting and participating in the fall stand down. Under the OSHA Alliance Program Directive, CSP 04-01-002, Section VII, “Alliance Purposes and Requirements”, C. “Criteria for New and Renewed Alliances”, Item Number 3 requires, “Alliances with employers and employer groups (e.g. trade associations) must also include worker representatives. This is accomplished by: a union signatory, participation of a community based labor group or worker involvement in the Alliance Agreement’s development and implementation, including project workgroups.” Due to the lack of employee involvement according to these criteria renewal of this alliance is not recommended at this time.

Report Prepared by: Larry Joswiak and Linda McHugh

For more information, contact the Office of Outreach Services and Alliances at (202) 693-2340 or go to www.osha.gov.

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