OSHA and INVISTA S.à r.l. (INVISTA) signed an OSHA Strategic Partnership (OSP) on June 19, 2008 to improve and enhance safety and health management systems at its participating facilities in Regions III, IV, and VI. Due to severe weather conditions and damages to INVISTA facilities following Hurricane Ike in September 2008, OSHA and INVISTA agreed to postpone the initial start date of the OSP until normal INVISTA operations resumed. Accordingly, an addendum with an effective date of January 18, 2009 was signed by all of the original INVISTA signatories and the former Acting Assistant Secretary of Labor, Thomas M. Stohler. This Executive Summary and the attached Annual OSP Evaluation Report (Report) reflect OSP information collected between January 18, 2009 and December 31, 2009.
The OSHA and INVISTA OSP has special emphases on the management of INVISTA’s contractor safety, ergonomics, and process safety management (PSM) programs.The OSP also builds on the relationship developed through the OSHA and Koch Industries (the parent company of INVISTA) OSP, which was signed in 2003 and concluded in 2009.
Seven INVISTA facilities were selected to participate in the OSP to achieve the following goals: 1.) Prevent and reduce employee injuries and illnesses with a focus on PSM at applicable facilities; 2.) Prevent and reduce employee ergonomic injuries and illnesses at applicable facilities; 3.) Improve communication and knowledge sharing between OSHA and INVISTA; and 4.) Increase INVISTA’s participation in the OSHA Voluntary Protection Programs (VPP).
INVISTA is working with OSHA to accomplish the agreement’s goals through its implementation of the principles of the 1989 OSHA Voluntary Safety and Health Program Management Guidelines with special focus on enhancing the company’s: 1.) Contractor safety and prequalification processes; 2.) PSM programs at covered facilities; and 3.) Ergonomic program management with systems that identify, evaluate, and control ergonomic risk factors. As the participating facilities work on improving their Safety and Health Management Systems (SHMS), INVISTA also intends to expand its participation in VPP and the Special Government Employees (SGE) program and hopes to submit several applications before the conclusion of the OSP in January 2012.
2009 OSP Highlights and Results
During the evaluation period some progress was made by the OSP in the development of SHMS for the participating facilities. However, INVISTA’s available resources for this effort were limited due to a number of factors including two of the OSP participating facilities were not active for part of the year due to downturn in economy; many resources being diverted to support Hurricane Ike recovery efforts, and changes in key staff positions at the company. As of December 31, 2009, OSP participating facilities achieved an overall average TCIR and DART 40% and 80% below their industry averages respectively as determined by the 2009 Bureau of Labor Statistics (BLS) injury and illness rates.
Cultural Survey and SHMS Self-Assessments
To prepare the groundwork for developing effective SHMS at its participating facilities, INVISTA in 2007 conducted a workplace culture survey with 100 questions developed by Texas A&M University. Over fifty percent (50%) of INVISTA employees responded to the survey. The results assisted in identifying gaps with the company’s SHMS. The identified gaps included the need to improve communications between the facilities’ leadership and workers and the need to improve perceptions in the area of safety values and training. INVISTA plans to conduct a follow up survey in either 2011 or 2012, prior to the conclusion of the OSP.
During this evaluation period, INVISTA continued to work on its own internal self-assessment and monitoring system called Compliance Assurance Management System (CAMS). This system contains 7 major elements, 1.) Leadership and Management Commitment; 2.) Employee Ownership; 3.) Compliance and Risk Assessment; 4.) Hazard and Operability Study; 5.) Training and Education; 6.) Change Management; and 7.) Continuous Improvement. Using CAMS, the OSP participating INVISTA facilities conducted annual self-assessments and the results from these reviews serve as the baseline data for this OSP.
In 2009, INVISTA continued to build on its facilities’ contractor safety programs. In addition to using a criteria to review contractor qualifications prior to their work onsite, INVISTA requires all contractor workers go through an 8-hour training program and to receive facility specific training via an internal program, the Safe Work Permit program, which is administered by the Site Supervisor. Additionally, these workers undergo training on an annual basis while they are at the facility. Among other topics, this training includes reviews of the information presented on Material Safety Data Sheets provided for chemicals the contractors have brought on site.. Lastly, contractors are required to conduct a job hazard analysis before each job starts with weekly audits and issuance of applicable safe work permits for every job.
During the evaluation period, INVISTA placed a special emphasis on the assessment and control of ergonomic risk factors at INVISTA’s downstream facilities including OSP participating facilities in Athens, GA and Seaford, DE. These facilities manufacture spinning fibers and filaments which requires repetitive work at these facilities. INVISTA implemented an ergonomics program at these facilities in which ergonomic safety is incorporated into the facility’s overall SHMS. To track ergonomic risks and their abatement, INVISTA uses a Discomfort Complaint Evaluation Protocol which is administered once a complaint is received. A hazard evaluation is then performed where ergonomic risk factors and relevant medical information are recorded along with trends and improvements. Also, a Physical Ability Test is administered during the new hire process to assist in proper job placement. Finally, an annual self assessment incorporating ergonomic surveys is performed. For facilities with minimal ergonomic risk factors, such as upstream facilities, workers are provided with awareness training about ergonomic safety programs during annual safety meetings and the facilities distribute monthly reminders with information on ergonomics.
VPP and SGE Program Participation
At the end of the evaluation period, the following OSP participating facilities have achieved various stages of VPP activities:
In late 2009, the Partnership Management Team (PMT) noted that there were no standard procedures in place to perform offsite and onsite non-enforcement verifications. As a result, the PMT worked on developing a verification template during the latter part of 2009. Designed to be used for both types of verifications allowed under the OSP (offsite document review and onsite non-enforcement visits), the template consists of a goal, strategies, and measures matrix of the OSP agreement and the each OSP participating facility’s progress is documented next to each goal. The template received final approval in early 2010. As a result, no onsite non-enforcement verification visits were conducted and no offsite verifications were performed for any of the non-VPP facilities during the evaluation period.
The OSP produced some positive results in 2009. The participating facilities outperformed their industry counterparts with TCIR and DART rates averaging 40% and 80% below their BLS industry averages, respectively. In addition to enhancing its ergonomic, PSM, and contractor safety programs, the facilities also worked on their annual self-assessments. During the evaluation period, no offsite verification procedures were conducted since the verification template was not finalized until early 2010. During 2010, the PMT should place particular focus on the scheduling and completion of the required verifications. In addition, the PMT should work to ensure that the information received from INVISTA for future evaluations addresses all data points as listed in the performance measures section of the OSP Agreement.