OCCUPATIONAL SAFETY & HEALTH ADMINISTRATION
HARTFORD AREA OFFICE
STATE OF CONNECTICUT
DEPARTMENT OF LABOR
DIVISION OF OCCUPATIONAL SAFETY AND HEALTH
GILBANE BUILDING COMPANY
CONNECTICUT BUILDING TRADES
The partners to this agreement are
- U.S. Department of Labor, Occupational Safety and Health Administration, Hartford Area Office (Hartford Area Office);
- State of Connecticut, Department of Labor, Division of Occupational Safety and Health (Connecticut OSHA);
- Gilbane Building Company; and the
- Connecticut Building Trades.
PURPOSE AND SCOPE
Gilbane Building Company; the United States Department of Labor, Occupational Safety and Health Administration (OSHA), Hartford Area Office; and the State of Connecticut, Department of Labor, Division of Occupational Safety and Health, mutually recognize the importance of ensuring a safe and healthful work environment in the construction industry in the State of Connecticut. To advance this mutual goal, the Partnership between Gilbane Building Company, Hartford Area Office, Connecticut OSHA and the Connecticut Building Trades has been established to formalize a cooperative effort between these entities, committed to encouraging companies to improve their safety and health performance voluntarily, providing methods to assist them in their efforts and recognizing companies with exemplary safety and health programs.
This project is a complete interior and exterior renovation of the CT State Office Building located at 165 Capital Avenue, Hartford CT. The 350,000sq' building structure originally constructed in 1931 has 6 floors, a basement level and a sub-basement level. The two exterior central courtyards will be reconfigured allowing access and usage from the cafeteria level. The building's exterior will undergo full exterior restoration to the Limestone, Granite and Historic Metals. The windows will be replaced with new energy efficient steel windows keeping with the existing historic window appearance. The renovation of the interior structure will be brought to Class A office standards.
The original 600-car parking structure on the corner of Washington and Buckingham Street will be replaced by a new Pre-Cast 1,006-space parking structure with two elevators and a lower level for future retail space. The $205 million project will have over 200 tradesman onsite during peak construction activities between the State Office Building and the New Parking Garage. Project Substantial Completion is earmarked for November 25th 2019 with total Completion by January 23rd 2020.
GOALS/STRATEGIES & PERFORMANCE MEASURES
GOALS STRATEGIES MEASURES 1. Developing a contractor/government partnership that will encourage involvement of the general and sub- contractors in the improvement of safety and health performance.
- Gilbane Building Company will require all the subcontractors to develop and implement written safety and health programs.
- Gilbane Building Company will require all sub-contractors onsite to work toward implementing a "zero tolerance" safety practice in order to help achieve the desired reduction of worksite incidents.
- Gilbane Building Company will have a written site specific health and safety plan for work to be conducted onsite. To articulate the requirements of the health and safety plan and the role of the OSHA Partnership, a site specific orientation has been developed and implemented at the worksite where high hazard tasks are performed.
- Gilbane Building Company will compile a summary of the number of inspections made by Gilbane's Health and Safety Manager (or their designee) and any third party. The report will be broken down into the six major categories of construction-focused hazards (falls, electrical, struck by and crushed by hazards, noise and silica), and will show the number of items within the six (6) categories that were corrected.
- Gilbane Building Company will require all foremen along with subcontractors to conduct a daily job briefing and review with their crew prior to starting work.
- Gilbane Building Company will utilize Connecticut OSHA consultants to perform an initial hazard survey as well as conducting periodic safety and health surveys.
- Gilbane Building Company will utilize Connecticut OSHA consultants to perform training for Gilbane Building Company and subcontractors on topics as the project progresses.
- Gilbane Building Company will verify by reviewing the number of subcontractors that implemented written safety and health programs and recognize those with exemplary programs.
- Gilbane Building Company will conduct a periodic review of each subcontractor's injury/illness statistics for the Project.
- Gilbane Building Company will facilitate the site safety orientation led by Gilbane's onsite Health and Safety Manager and is given to all workers that arrive onsite (general contractor and subcontractor employees).
Gilbane Building Company will adjust the orientation to include specific information resulting in lessons learned in changing site conditions.
- The Gilbane Building Company Health and Safety Manager will periodically sit in on daily briefings and discuss with foremen pertinent and important safety and health talking points/topics and areas that may be improved on.
2. Identifying opportunities for enhancing safety and health practices related to the operation and maintenance of material handling equipment involved in the Project.
- Gilbane Building Company will facilitate ongoing training on the safe operations of material handling equipment to all employees involved in the operation.
- Gilbane Building Company will ensure toolbox discussions are held on a weekly basis. The discussion topic will change each week. During the discussion, site specific topics are mentioned on work either occurring currently or upcoming events the crews should be aware of.
- Gilbane Building Company will document the number of employees that have been trained and licensed on the material handling equipment.
- Gilbane Building Company will request from all workers their training documentation, qualifications, and/or certifications. The worker and his/her qualifications will be inserted into a tracking spreadsheet by trade and company.
3. Reduce workforce fatalities, serious injuries and illnesses and provide a safe work environment for employees at the Project.
- Gilbane Building Company will establish a system to collect and analyze injury and illness trends (including near-miss incidents) by all contractors performing work at the Project. This data will be used as a tool for continual safety and health program improvement.
- Gilbane Building Company safety representatives will track all man hours onsite for both Gilbane Building Company personnel and subcontractors to accurately maintain a current Total Case Incident Rate (TCIR) and Days Away Restricted Time (DART) rate.
- Gilbane Building Company will maintain the necessary OSHA 300 injury and illness data for the Project.
- Gilbane Building Company will maintain a monthly incident/accident tracking log.
- Gilbane Building Company after each significant incident, will schedule an incident review to get all members of the crew to discuss what occurred. The purpose of the meeting is to find out the contributing factors/root causes, and discuss what corrective actions need to be established.
- Gilbane Building Company will compare the Project to the U.S. Bureau of Labor Statistics (BLS) national trends and use these rates as a tool for continual health and safety program development.
4. Ensure, where feasible, all serious hazards are eliminated or controlled through controls, safe processes and/or procedures, and personal protective equipment (PPE).
- Gilbane Building Company will confirm health-related issues arising during the course of the construction work are adequately addressed by Gilbane Building Company and its subcontractors. All health-related issues will be discussed monthly during the Partnership meetings.
- Gilbane Building Company, with Connecticut OSHA, will provide hearing conservation, silica, and any other health related hazard training to all employees and its subcontractors.
- Gilbane Building Company, with Connecticut OSHA, will implement an effective industrial hygiene monitoring program to control hazards such as but not limited to silica, noise and other airborne contaminants which may be present during various parts of the Project. This will include personal monitoring, employee training, implementation of engineering controls where feasible, and the use of respiratory and dermal protection when necessary. Gilbane Building Company will provide training to all site contractors in the requirements of the new silica standard (29 CFR 1926.1153 including Table 1).
- Gilbane Building Company will track the number of employees trained on Fall Protection and the use of Fall Protection systems as they relate to the Project.
- Gilbane Building Company will track the number of tool box talks regarding conditions on the worksite for the duration of the Project will be tracked.
- Gilbane Building Company will ensure that all subcontractors conduct safety meetings to inform workers of all serious hazards and the controls, procedures, safe processes and/or PPE necessary to protect against them.
- Gilbane Building Company will ensure that all subcontractors are in compliance with all fall protection requirements when working on elevated work levels six (6') feet or more above lower level including training of all affected employees on the safe and correct use of fall protection systems.
The goals, strategies, and performance measures above will be implemented to meet the following objectives of this Partnership:
- Reducing the number of at-risk conditions and behaviors that have the potential to result in worker fatalities, injury and illness.
- Reducing the number of injuries affecting participant subcontractor employees, emphasizing those resulting from the six primary construction hazards, abating hazards (conditional and behavioral) identified from weekly safety and health inspections, and having no repeat occurrences of such issues upon re-inspection.
- Reducing the TCIR and DART rate to 20% below the current national average for North American Industry Classification System (NAICS) Code 236, Construction of Buildings, based upon the Bureau of Labor Statistics (BLS) data available for the most current year. The 2014 Bureau of Labor Statistics (BLS) TCIR and DART rates for NAICS Code 236 are 3.3 and 1.9, respectively.
The partners will prepare a joint annual evaluation of the Partnership. The evaluation will review the success of the Partnership, lessons learned, and changes that will be made to meet the goals of the Partnership. The annual performance evaluation report format from Appendix C of the OSHA Strategic Partnership Program for Worker Safety and Health (OSPP), Directive CSP 03-02-003, will be used. Performance measures listed in the goals and objectives section of this agreement will be collected and analyzed to determine the Partnership's progress toward meeting its goals.
The following are benefits for Gilbane Building Company and its subcontractors when and only when they are working at the Project:
- Outreach, information, training and technical assistance by Hartford Area Office and Connecticut OSHA.
- Special recognition, which may include but is not limited to, press releases issued by OSHA and recognition on OSHA's web page designating Gilbane Building Company as a participant in the OSHA Strategic Partnership Program.
In accordance with OSHA's Clarification of Verification Exemption Policy for OSHA Strategic Partnership Program Construction Participants dated June 1, 2006, Gilbane Building Company and all construction subcontractors will receive annual verification inspections. The onsite enforcement verification inspections are conducted to determine participants' compliance with terms of this agreement. The first inspection will be conducted no later than sixty (60) days after Partnership participants formally enter into this agreement. Citations and penalties may be issued, when appropriate, as a result of these inspections. During this period Gilbane Building Company shall develop and implement the safety and health management systems required under this agreement.
OSPP MANAGEMENT AND OPERATION
A Partnership Management Team (PMT) with members from Gilbane Building Company, Hartford Area Office, Connecticut OSHA and the Connecticut Building Trades will oversee and coordinate this Partnership. The team will determine Partnership procedures, which will include measures to be used and data to be collected, hold conference calls and meet monthly to evaluate the effectiveness of the Partnership. Gilbane Building Company and Hartford Area Office are responsible for collecting baseline and annual performance data upon which the OSPP will be measured. Gilbane Building Company aggregate injury and illness incidence rates (total case rates) and fatality rates will be compared with the most current BLS published data to determine whether goals have been met.
Gilbane Building Company will establish the following:
Project-Specific OSHA Safety and Health Program Management Guidelines – Gilbane Building Company shall develop a project-specific safety and health plan to be used as a benchmark for subcontractor programs to meet or exceed. This plan shall incorporate the following minimum elements:
Gilbane Building Company shall assign a qualified safety and health representative to administer its safety and health program. This person will have, at a minimum, completed the OSHA 30-Hour Construction Outreach course.
Weekly foremen's meetings – Gilbane Building Company with the Connecticut Building Trades shall hold a weekly meeting with all subcontractor foremen that shall include discussions of project safety and health issues and review job hazard analyses for upcoming activities. Additionally, representatives of all active subcontractors will meet to discuss participant performance and progress toward Partnership goals. The Hartford Area Office, Connecticut OSHA and the Connecticut Building Trade representatives are welcome to attend these meetings.
Hazard Identification and Assessment
Weekly worksite audits of areas where employees are working will be conducted.
Job Hazard Analysis Gilbane Building Company shall conduct a comprehensive assessment of project work and require its subcontractors to develop JHAs to eliminate or reduce hazards to which their employees are potentially exposed.
Hazard Prevention and Control
100% fall protection when fall exposure at 6 feet or greater.
Mandatory use of Ground Fault Circuit Interrupters (GFCI) throughout the Project.
All cranes, hoists, and personnel lifts (scissor/aerial) will be inspected prior to use.
All cranes will have a current annual inspection conducted by a third party acceptable to Gilbane Building Company.
Use of appropriate PPE, including the use of ANSI- approved safety glasses at all times.
Education and Training
Conduct site-specific safety and health training.
Recordkeeping – Gilbane Building Company shall maintain a project OSHA 300 Log (or equivalent), per the requirements of 29 CFR 1904.
Coordination and communication on Multiemployer Worksites/Subcontractors:
- Weekly Task-Specific Instructions – All subcontractors shall provide workers with instructions on the integration of safety and health requirements with current work tasks for the week. All subcontractors shall allow an OSHA representative to attend any of these meetings, when requested by OSHA.
- Weekly Safety and Health Inspections – All subcontractors shall conduct weekly inspections of their work areas to identify conditional and behavioral deficiencies, as defined by the Project safety and health plan and OSHA standards. Deficiencies will be documented, and corrected or reported to Gilbane Building Company for corrective action.
- Recordkeeping – All subcontractors shall report and record workplace injuries and illnesses as required by 29 CFR 1904 and shall report recordable incidents to Gilbane Building Company for recording on the Project OSHA 300 Log.
- Job Hazard Analysis – All subcontractors shall conduct a JHA for each high hazard task to be performed, and review the appropriate JHA with affected employees at regular intervals.
Hartford Area Office and Connecticut OSHA's Role:
- Provide initial and continued review and evaluation of Gilbane Building Company's compliance with the Partnership Agreement.
- Provide initial review of Gilbane Building Company's Project Safety and Health Plan.
- Make recommendations where deficiencies or opportunities for improvement exist.
- Provide feedback on incident trends and patterns as needed.
- Assist Gilbane Building Company with ensuring that effective training is available and delivered, as needed.
- Participate in training as resources permit.
- Periodically attend site safety and health meetings.
- Provide initial site surveys and perform environmental monitoring when appropriate.
- Provide clarification of OSHA standards for Gilbane Building Company and subcontractors.
- Provide input on compliance strategies.
Subcontractor Buildings Trades:
- Weekly Safety and Health Inspections – Representative of the trades on the worksite shall participate in weekly inspections of their work areas to identify conditional and behavioral deficiencies, as defined by the Project safety and health plan and OSHA standards. Deficiencies will be documented and corrected or reported to Gilbane Building Company for corrective action.
- Job Hazard Analysis – Representatives of the trades on the worksite shall participate in the development of JHAs for each high hazard task to be performed, and review the appropriate JHA with affected employees at regular intervals.
EMPLOYEE AND EMPLOYER RIGHTS AND RESPONSIBILITIES
This Partnership does not preclude employees and/or employers from exercising any right provided under the OSH Act (or, for federal employees, 29 CFR 1960), nor does it abrogate any responsibility to comply with the Act.
TERMS OF OSPP
This agreement will terminate at the conclusion of the work being performed at the Project. However, if the Gilbane Building Company, Hartford Area Office, Connecticut OSHA or Connecticut Building Trades wishes to withdraw their participation prior to the established expiration dates, the Partnership will be considered null and void upon receipt of a written notice of the intent to withdraw.
Signed this _____ day of _____, 2018
Kenneth Tucker, Director
State of Connecticut
Department of Labor
Division of Occupational Safety and Health
Dale Varney, Area Director
Hartford Area Office
U.S. Department of Labor/OSHA
Gilbane Building Company
Connecticut Building Trades
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