OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
UNITED STATES POSTAL SERVICE
UNITED STATES POSTAL SERVICE UNIONS
- GOALS AND OBJECTIVES
- Improve the safety and health environment so that OSHA, USPS, NPMHU, and APWU can work together to reduce MSDs.
- Identify tasks and conditions where MSD incidents occur and develop and implement ergonomic control processes to reduce or eliminate MSD incidents.
- Train USPS local managers, supervisors, NPMHU and APWU representatives, and the local Joint Labor-Management Safety and Health Committees to ensure comprehension of ergonomic risks and control processes.
- Reduce the number of MSD related incidents thereby reducing the number of days away from work for both lost workday and restricted duty cases associated with MSD incidents.
- Develop and evaluate best proven practices to be implemented in other postal facilities with similar ergonomic issues. Share best proven practices with applicable USPS operations with similar ergonomic issues.
- Train local employees as appropriate to participate in the ergonomic risk reduction process.
- STRATEGIES FOR ATTAINING GOALS
- Establish a national Ergonomic Work Group (EWG) consisting of USPS, Joint USPS/NPMHU Labor-Management Safety Committee, USPS/APWU Joint Labor-Management Ergonomic committee, and OSHA representatives to ensure the consistent implementation and evaluation of the ESP process.
- To the extent possible, identify one or more sites in each of OSHA's 10 regions covering USPS's 9 areas to participate in the ESP process. The goal in calendar year 2006 is to start an ergonomics process in 30 sites.
- As resources allow, OSHA will assist in the implementation of the ESP process through a variety of means including:
- Technical ergonomic assistance
- On-site support to ensure continued success of ESP process efforts
- Participation in joint safety and health committee meetings
- Participation in training
- Identification of mentoring resources
- Participation on the Ergonomic Work Group
- Participating sites through their respective local Joint Labor-Management Safety and Health Committees will identify and prioritize work activities for the development and implementation of ergonomic control processes to include:
- Management Leadership
- NPMHU and APWU Representative/Employee Participation
- Job Hazard Analysis
- Hazard Prevention and Control
- Program Evaluation
- USPS, NPMHU (National USPS/NPMHU Joint Labor-Management Safety Committee), and APWU (National USPS/APWU Joint Labor-Management Ergonomic Committee) will identify and make available best proven practices to be shared with other Postal Service facilities with similar risk in a timely manner.
- USPS, APWU, and NPMHU will provide OSHA with best practices that have universal application. OSHA may share such information with like industries.
- As resources allow, provide priority on-site ergonomic technical assistance to assist and advise on specific issues.
- Maximum allowable penalty reductions for ergonomic and other violations abated in a timely manner, as allowed by OSHA's Field Inspection Reference Manual (FIRM).
- Six month deferral in programmed inspections at partnering sites from the date of the partnership, as provided by OSHA's Site Specific Targeting (SST) or other targeting programs.
- Opportunities to identify mentors from VPP sites that have effective ergonomic programs.
- OSHA recognition for partnership activities and successes.
- ESP PROCESS OVERSIGHT
- A national Ergonomic Work Group (EWG) will be formed to facilitate the implementation and management of the ESP process.
- The EWG will, at a minimum, include up to the number of representatives from each of the following organizations/offices as identified below:
It is the responsibility of management to provide safe working conditions in all present and future installations and to develop a safe working force, and for the Unions to cooperate with and assist management to live up to this responsibility. The United States Postal Service (USPS), National Postal Mail Handlers Union (NPMHU), and American Postal Workers Union, AFL-CIO (APWU) recognize the importance of reducing musculoskeletal disorders (MSDs). It is agreed that entering into an Ergonomic Strategic Partnership (ESP) process with the Occupational Safety and Health Administration (OSHA), the United States Postal Service, National Postal Mail Handlers Union, and the American Postal Workers Union, AFL-CIO will enhance ergonomic controls at USPS facilities.
The USPS, NPMHU, APWU, and OSHA will work cooperatively to implement an ongoing process to identify MSDs early, and control the risk factors that can cause injuries and illnesses to postal employees. To accomplish this will require management, unions, and OSHA to have meaningful involvement and participation in the process. Under the direction of the national USPS/NPMHU Joint Labor-Management Safety Committee and the USPS/APWU Joint Labor-Management Ergonomic Committee, the Unions at the national level will evaluate and make recommendations on all aspects of the ESP process to include program adequacy, field implementation, training and unsafe conditions.
Specifically, the ESP process is designed to accomplish the following goals at participating USPS worksites:
USPS, NPMHU, APWU and OSHA will work in concert employing the following strategies to achieve the aforementioned goals:
The process will be tested in 10 sites to start. Expansion to additional sites will be discussed and recommendations made by the USPS/APWU Joint Labor-Management Ergonomic Committee and the national Joint USPS/NPMHU Labor-Management Safety Committee. OSHA representative(s) may attend this meeting.
OSHA will offer the following benefits for USPS worksites participating in the ESP process:
- USPS National Office - six
- NPMHU National Office - three
- APWU National Office - three
- OSHA - three
- Monitoring the ESP process and resolving issues
- Determining the appropriate ESP process measurements
- Receiving and evaluating ESP process data from participating sites.
- Preparing a written annual evaluation of the ESP process
The teams will consist of the following:
- OSHA regional or area office staff representative(s)
- A national representative from each Union
- USPS national representative
The EWG will develop and implement appropriate procedures to measure the progress of the ESP process in terms of meeting its goals. At a minimum, baseline data will be developed and the following will be evaluated:
- Measures of MSD injury/illness cases at participating sites
- Extent of local joint safety and health committee participation in the ESP process
- To the extent possible, employees' perceptions of the ESP process' impact on worker safety and health
- Measures of incidence and severity criteria (in comparison with the baseline numbers)
- Number of managers and employees trained
- Number of best practices shared
- Number of tasks reviewed and correction(s) implemented
These factors and other appropriate information will be provided by the USPS and presented at the semi-annual EWG meetings for review and comment. In addition, the EWG will prepare annual ESP process evaluations. The annual evaluations will be subject to review and discussion by EWG representatives prior to their publication.
Verification of good faith by the participants will be effected through both off-site and on-site methods.
- Data compiled and reviewed semi-annually by the EWG will be the basis for off-site verification.
- On-site verification will involve on-site evaluations performed by the EWG or their representatives. At least two onsite evaluations will be conducted jointly each year. OSHA will conduct at least two independent on-site ESP process evaluations.
On-site verification visits will be conducted in accordance with OSHA's Training and Education Directive (TED) 8.01, OSHA Strategic Partnership Program.
Nothing in this partnership shall be construed to preclude bargaining unit employees from exercising any right provided under the OSH Act, nor does it eliminate their responsibility to comply with any provision of the Act, or any standard or regulation promulgated pursuant to the Act.
This ESP agreement does not supersede or modify the current National Agreements and supplements thereto between the U.S. Postal Service and the Unions.
Participating USPS sites will remain subject to OSHA enforcement inspections and sanctions except as specified under Section IV (Incentives) of this agreement. OSHA will give appropriate consideration to any USPS sites that have implemented effective ergonomic processes or that are making good faith efforts to reduce ergonomic hazards.
This agreement will be in effect for a period of two (2) years from the date of signing. The agreement may be renewed by mutual agreement of all parties.
Any party to this agreement may, with 30 day written notice to the other parties withdraw from the partnership.
- John E. Potter
- Postmaster General, CEO
- United States Postal Service
- Edwin G. Foulke
- Assistant Secretary
- Occupational Safety and Health Administration
- William Burrus
- American Postal Workers Union, AFL-CIO
- John F. Hegarty
- National President
- National Postal Mail Handlers Union, A Division of Laborers' International Union of North America, AFL-CIO