U.S. Department of Labor
Occupational Safety and Health Administration,
Norfolk Area Office (OSHA)
Virginia Ship Repair Association, Inc. (VSRA)
To facilitate OSHA's goal of reducing occupationally related fatalities by 3% each year, and reducing the total Rate of Days Away from Work by 4% each year, the Norfolk Area Office in Region III of the Occupational Safety and Health Administration (OSHA) and the Virginia Ship Repair Association, Inc. (VSRA) have agreed to joint implementation of the Shipyard Safety Training Partnership.
This agreement is consistent with OSHA's long range efforts to develop a business / labor / government partnership approach to safety and health management, allows for better use of OSHA resources, and encourages more participation in the safety process by VSRA members. Representatives of the shipyard activities most directly involved or affected by this partnership have been consulted and encouraged to provide continuous improvements and enhancements to this partnership agreement.
Expected outcomes of the program include developing and implementing model shipyard occupational safety and health and training programs for all participants.
The Virginia Ship Repair Association (VSRA) has over 170 member companies that work in or support the ship repair industry in Virginia and along the Mid-Atlantic coast of the United States. The association works closely with a variety of government agencies, federal and state, as well as other maritime organizations, to create a high standard of excellence in and for the ship repair industry. In this regard, VSRA has a long-standing commitment to promote safety and health awareness to its members, which includes a strong training commitment to educational courses and seminars.
Joint efforts by OSHA and VSRA, through this partnership agreement, will leverage each others' resources to target larger populations in the ship repair industry for safety and health focus and will promote a voluntary, cooperative effort between OSHA and the VSRA membership to reduce occupational accidents and save lives.
Identification of Partners and the Geographical Boundaries of the Partnership Agreement
U.S. Department of Labor, Occupational Safety and Health Administration, Norfolk Area Office (OSHA)
Virginia Ship Repair Association, Inc. (VSRA) 150 Boush Street, Suite 802 Norfolk, Virginia 23510
Geographical Boundary of the Partnership Agreement:
Available to VSRA participants in the State of Virginia
OSHA Primary Contact
Leo Edwards, Acting Area Director, U.S. Department of Labor, Occupational Safety and Health Administration, Norfolk Area Office
- Increase the number of ship repair employers who develop, implement, and maintain comprehensive safety and health programs in accordance with OSHA's 1989 Safety and Health Program Management Guidelines or the equivalent.
Achieve participant recordable illness and injury rates below the national average for the SIC 3731/SIC 3732 (NAICS 336611/NAICS 336612). A partnership goal is to keep the DART rate (cases with days away from work, job-transfer, or restriction) below the most recently published national average for the industry which was 6.0 for the year 2005. The partnership goal is to further reduce this level of injuries by at least 4% annually for the life of the agreement, and to facilitate OSHA's goal of reducing fatalities by 3% annually.
(Strategy) Participants' safety and health programs will be evaluated using Appendix A, the VSRA Safety & Health Self Assessment Checklists.
(Strategy) Develop and maintain systems for the early identification and correction of the hazards which have resulted in serious injuries in the ship repair industry. The primary causes of injuries and illnesses among participants will be determined by all parties (VSRA, OSHA, VSRA participants) through quarterly review of self-assessments, injury and illness records, and any other relevant accident reports. If necessary during the partnership, the focused hazards will be adjusted based on experience.
(Strategy) Develop and provide safety and health training, technical assistance, operating procedures, and abatement methods that accurately target and reduce the primary causes of injury and illness in the shipbuilding and ship repair industry as identified by the partners.
(Strategy) Share best practices in occupational safety and health for the ship repair industry.
(Measure) Injury and illness rates will be evaluated annually by review of OSHA 300 logs and any other relevant accident reports.
- OSHA Agrees To:
- Assist VSRA in the development of criteria to be used for safety and health training.
- Provide technical information and assistance to VSRA regarding the grant process in order to apply for funding for Safety and Health Training Programs.
- Participate in VSRA annual training seminars.
- Provide an OSHA representative to meet with VSRA members on a quarterly basis to review partnership issues, examine the injury and illness experience of participants, suggest corrective measures to eliminate hazards and share best practices.
- Share information on current violations and statistics, including relevant interpretations, proposed standards and similar information, which may be of interest to VSRA members.
- Assist participating members who have established and implemented a comprehensive safety and health program (such as referenced in Safety and Health Program Management Guidelines, FRN 54:3904-3916, January 26, 1989 and/or American National Standards Institute ("ANSI") A 10.38, "Basic Elements of an Employer Program to Provide a Safe and Healthful Work Environment").
- VSRA Agrees To:
Administer the partnership agreement, as outlined below, and serve as the principal safety and health resource in support of VSRA members. Additionally, VSRA will:
- Assist participating members in developing, implementing and maintaining comprehensive safety and health programs through the administration of VSRA's self- assessment program.
- Maintain participant signatory letters and certifications, Appendix B, and verify certifications with OSHA upon request.
- Review with OSHA and VSRA participants, on a quarterly basis, the primary causes of injuries and illnesses among the participants, suggest corrective measures to eliminate hazards and share best practices.
- Act as liaison for VSRA members with OSHA. Members will be able to contact VSRA or OSHA with questions.
- Offer quality training on topics of importance to participants and VSRA membership, especially the focused hazards determined by the partners.
- Through the Safety Committee provide safety and health meetings with members to assist with their training efforts. Members can use this information for site-specific and topical training. To further assist members, the Safety Committee and VSRA will undertake the development of a safety and health awareness program that includes lectures as well as a specific safety slogan that members may utilize.
- Obtain and provide to members, upon request, current informational materials, brochures, and publications from available resources.
- Organize and provide OSHA standards interpretations as well as local inspection perspectives to assist members in understanding and properly applying standards to their work sites.
- VSRA Participants Agree To:
- Sign a letter of agreement, Appendix B, with VSRA indicating their intent to participate in this partnership.
- Certify that their company has not been cited by the Norfolk Area Office within the past three (3) years for alleged violations classified as "repeated" and/or "willful."
- Ensure employee training in the program, including supervisory personnel, utilizing VSRA supported safety and health training programs or equivalent training.
- Provide written affirmation using Appendix B that a comprehensive written safety and health program is in place, which is at least equivalent to the criteria referenced in Section VI, Paragraph A.6 as the minimum established criteria for participation, including implementation of policies and procedures to ensure that safety rules and procedures are enforced at their work sites.
- Complete Safety & Health Self Assessment Checklists, Appendix A, upon entry into partnership with review and certification by President/CEO that deficiencies have been corrected.
- Provide written affirmation using Appendix B that their policy and procedures hold line supervisor and employee accountable for following established safety and health rules and OSHA regulations.
- Provide the level of training required by OSHA regulations to their employees either through VSRA, their own training personnel or other consultant/trainers.
- Provide annual safety related data or statistics to the VSRA office concerning man- hours worked, lost day work injuries, and accident records. This data will be used to determine primary causes of injury and illness among participants in order to develop training, sound operating procedures, and abatement methods. VSRA shall maintain this information's confidentiality as to company and shall release only compiled "group wide" data that does not reveal the statistics for any individual participating members.
- OSHA Agrees To:
Give priority service to VSRA participating members requiring OSHA technical assistance.
OSHA will not issue penalties for other-than-serious violations, provided that the abatement of violations is observed.
OSHA will recognize and consider VSRA safety and health training programs when inspecting work sites of partnering members (participating in this partnership with required safety and health program fully implemented), consider the extent of employee training and instruction and the VSRA member's safety and health program.
If cited by OSHA, participating contractors will be eligible for the maximum penalty reduction for good faith, currently outlined within OSHA Instruction CPL 2.103 (Field Inspection Reference Manual).
In order to assist in measuring the success of this partnership, the Norfolk Area Office will verify that all current participants have completed their self-assessments, Appendix A, and have corrected deficiencies where appropriate.
A joint evaluation of the partnership will be prepared annually by the Norfolk Area Office and VSRA using Appendix C. The evaluation will review the success of the partnership, lessons learned, and changes that will be made to meet the goals of the partnership.
Employee/Employer Rights and OSHA Investigations
Employee rights which are guaranteed under the OSH Act shall not be infringed upon as a result of this partnership. This partnership does not preclude employees and/or employers from exercising any right provided under the OSH Act, nor does it abrogate any responsibility to comply with rules and regulations adopted pursuant to the Act.
OSHA personnel will continue to investigate under local and national emphasis programs, workplace complaints, referrals, fatalities, catastrophes, other accidents or significant events, and contractors whose employees are exposed to or are creating plain view hazards at partnering worksites. These investigations will be conducted outside of this partnership agreement in accordance with established OSHA enforcement policy. Violations documented during such investigations may result in the issuance of citations and penalties.
Indemnification and Hold Harmless
OSHA, VSRA, and all Participating VSRA Members hereby agree that their sole remedy for any alleged defaults under this Agreement or under the Program set forth therein shall be the Termination of the Agreement as set forth above. Each party hereto and each Participating VSRA Member expressly agrees to hold the other parties harmless and to indemnify them for any claim brought by themselves or any employees, agents, or invitees of such entity as a result of any alleged violation of this Agreement; provided, however, that nothing in this release language shall in any way limit any Participating Member's liability for violation of any Federal or State safety laws or regulations.
This agreement will terminate on December 19, 2009 which is three years from the date of the signing. If any signatory of this agreement wishes to terminate its 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 signatory may also propose modification or amendment of the agreement.
For non-signatory participants of the strategic partnership, OSHA may terminate the participant's involvement at any time with written notice. Additionally, the participant may withdraw its participation from the strategic partnership at any time with a written notice of the intent to withdraw to OSHA.
Acting Area Director
Norfolk Area Office
Malcolm P. Branch
Virginia Ship Repair Association, Inc.
APPENDIX A - SAFETY & HEALTH SELF ASSESSMENT CHECKLISTS
VIRGINIA SHIP REPAIR ASSOCIATION, INC.
150 Boush Street, Suite 802 Norfolk, VA 23510 ~ 757-233-7034 ~Virginia Ship Repair Association
These Safety and Health Self Assessment Checklists were developed by the Virginia Ship Repair Association, Inc. (VSRA) and are offered to VSRA member companies as a guide only. They are not intended to supplant any applicable government regulations or specific guidelines for individual member companies. VSRA members are encouraged to use the checklists to foster safer work practices. VSRA cannot and does not accept any responsibility for the use or non-use of these safety checklists.
VSRA gratefully acknowledges the assistance of the members of the VSRA Safety Committee who helped publish the Safety and Health Self Assessment Checklists.
TABLE OF CONTENTS
- Asbestos Awareness
- Confined Space Program
- Diving Operations
- Fire Prevention and Hot Work
- Hazard Communication
- Hearing Conservation
- Lead and Heavy Metals
- Rigging and Materials Handling
- Lockout and / or Tagout
- Medical Services
- Portable Tools
- Powered Industrial Trucks; Aerial Lifts
- Personal Protective Equipment
- Respiratory Protection
- Safety Management
- Fall Protection
- A 1. Does the company train employees about general asbestos awareness? (Training includes health effects, labeling at barriers, materials, etc.) __________
- A 2. Are employees able to recognize the types of materials that may contain asbestos? Can employees recognize PACM (Presumed Asbestos Containing Materials)? __________
- A 3. Are they trained to not disturb suspect materials until their content is accurately determined? __________
- A 4. Do you have a resource that is certified to remove asbestos containing materials such as gaskets, insulation, lagging, wallboard, and flooring? __________
- A 5. If your employees conduct bulk sampling, have they received training as an accredited building inspector for asbestos containing materials according to EPA rules? __________
- A 6. Is the content of suspect materials determined by employees of the prime contractor prior to the start of your work? __________
- A 7. Do you look to the prime contractor to remove suspect materials prior to your work? __________
Reference CFR 29 1915.7-16, NFPA 306
- B 1. Does your company have a confined space program? __________
- B 2. Does your company train all employees who have to enter a confined space to recognize the characteristics of a confined space? __________
- B 3. Does your company train all employees on the hazards associated with confined spaces? __________
- B 4. Does your company train all production employees about the health effects of the hazards (oxygen deficiency, explosive atmospheres, and toxic atmospheres) that exist in confined spaces? __________
- B 5. Does your company train all employees on the atmospheric monitoring and logging requirements of a confined space program? __________
- B 5.5 Are records of completed tests and inspections kept on file for a period of at least three months from the completion date of the specific job from which they were generated? __________
- B 6. Does your company train employees to anticipate and be aware of the hazards faced during entry? __________
- B 7. Does your company train employees to recognize the adverse health effects that may be caused by the exposure to the hazard? __________
- B 8. Does your company train employees to know what personal protective equipment is needed for safe entry into and exit from the space? __________
- B 9. Are all confined spaces initially inspected by a SCP or certified safe for entry / safe for hot work by a certified marine chemist? __________
- B10. Are all confined spaces checked by a shipyard competent person as often as specified on the marine chemist certificate prior to entry? __________
- B11. Are employees required to inspect the work area after entry for spills, leaks, and combustible materials prior to the start of hot work? __________
- B12. Are all gas hoses and gas leads removed from the confined space and enclosed spaces at breaks and at the end of the shift? __________
- B13. Are supervisors required to make frequent checks of personnel working in confined spaces? __________
- B14. Has the company designated one or more competent persons or does a Marine Chemist perform tests or inspections which require a competent person? __________
- B15. Do the competent persons meet the criteria set forth in 1915.7 (c)? __________
- B16. Is a list maintained that includes the name of each competent person and the date of last training? __________
- C 1. Does your company perform diving operations or contract companies to perform diving operations? __________
- C 2. Does the dive team consist of a minimum of three personnel? Is one of the dive team personnel designated in writing as the Designated Person in Charge? __________
- C 3. Do all dive team personnel have the training and / or experience necessary to complete their assigned duties as a dive team member? __________
- C 4. Do all dive team personnel have a current and valid First Aid and CPR certification from a nationally recognized organization? __________
- C 5. Is the diving equipment in use appropriate for the task? __________
- C 6. Have all breathing gas supply hoses, compressors, air receivers, and depth gauges been tested in accordance with the standard, and the results recorded in a maintenance log? __________
- C 7. Are two-way voice communications provided for all surface-supplied diving operations? __________
- C 8. Has the Designated Person in Charge completed an evaluation for the presence of hazardous energy to include differential pressure? Have procedures been completed by the Designated Person in Charge to control any hazardous energy which may effect the safety of the diver? __________
- C 9. Has the Designated Person in Charge notified all nearby vessels and facilities of the impending dive operation so that their activities will not affect the safety of the diver? __________
- C10. Has the dive flag "Code Alpha" been hoisted to signal vessels in the vicinity of the diving operation? __________
- C11. Are the following maintained at the dive location?
- Safe Practices Manual containing dive procedures, checklists, and emergency procedures __________
- Emergency Phone Numbers __________
- First Aid Supplies & Bag-Type Manual Resuscitator __________
- First Aid Handbook or equivalent __________
- Record of Dive __________
- D 1.Does your company have procedures in place addressing fire prevention and hot work? __________
- D 2. Do company procedures mandate an inspection of hot work sites to verify the removal or protection of combustibles? __________
- D 3. Are positive measures taken during all hot work to confine all sparks, slag and heat? __________
- D 4. Are all cutting torch gas leads shut off at some point outside of a confined/enclosed space when a torch will be left unattended? __________
- D 5. Are gas hoses removed from confined spaces and enclosed spaces overnight, at shift changes and anytime the torch is removed from the hoses? __________
- D 6. Are fire watches trained and assigned to both (all) sides of a bulkhead or deck being welded and required to remain on station for 30 minutes afterwards to ensure no possibility of fire exists? __________
- D 7. Are fire watches required to have a properly sealed fire extinguisher ready for instant use? __________
- D 8. Are fuel gas and oxygen manifolds maintained either on the pier or on the weather decks of ships being worked? __________
- D 9. Are flammable/combustible preservative coatings removed in the way of welding or hot work? __________
- D10. Are flammable liquids required to be kept in closed containers when not actually in use? __________
- D11. Is mechanical ventilation mandated for all hot work conducted within a ship? __________
- D12. Are a 'Safe for Workers, Safe for Hot Work' inspections and/or certification required prior to all hot work in confined spaces? __________
- E 1. Does the company have a written Hazard Communication (HAZCOM) Program? __________
- E 2. Who is designated as responsible for the program or its included elements? __________
- E 3. Do you have a complete list of hazardous chemicals to which an employee might be exposed? __________
- E 4. Is this list kept by the work area or in a centralized form at some location? __________
- E 5. How do you provide for remote site locations? __________
- E 6. Where are Material Safety Data Sheets (MSDS) maintained? __________
- E 7. Have your employees been trained in this program? __________
- E 8. How often is refresher training provided? __________
- E 9. Are there provisions in your training for?
- Non-routine tasks? __________
- Other contractor or subcontractor notification at multi-employer sites? __________
- E10. Are all containers properly labeled? __________
- E11. Do labels contain the following information?
- Identification of contents? __________
- Hazard Warnings? __________
- F 1. Does the company have a Hearing Conservation Program for employees who are or may be exposed to an 8-hour time-weighted average (TWA) that equals or exceeds 85 decibels? __________
- F 2. Who is designated as responsible for the program? __________
- F 3. Is workplace noise monitoring conducted to determine who needs to be in the program? __________
- F 4. For those in the program are baseline and annual audiograms conducted? __________
- F 5. Is hearing protection required and provided where noise exposure equals or exceeds 85 db? __________
- F 6. Is a training program in place which covers, on at least an annual basis, the effects of noise and the use of protectors? __________
- F 7. Are noise exposure records maintained for two years? __________
- F 8. Are audiometric test records maintained for the duration of employment? __________
- G 1. If your work involves the removal/disturbance of surface coatings, does your company have a written Lead Program that meets the requirements of 1910.1025? __________
- G 2. Is your written program readily available? __________
- G 3. Is grit material analyzed as to content prior to use? __________
G 4. Does the company provide employees training in general lead awareness? __________
Does training include health hazards, postings of barriers and materials? __________
- G 5. Are your employees trained in the recognition of potential lead containing materials/coatings? __________
- G 6. Are suspect materials analyzed prior to the start of work activities that could create harmful lead levels? If your employees are sampling suspect materials, are they properly trained? __________
- G 7. Are employees trained to not disturb suspect material until they have been analyzed for lead content? __________
- G 8. Does the company have programs in place that address exposure to other heavy metals, such as cadmium (1915.1027), arsenic (1915.1018) and hexavalent chromium? __________
- G 9. Does the company's policy on hotwork on preservative coatings comply with the requirements listed in 1915.53? __________
- H 1. Does your company perform rigging and/or materials handling operations? If yes, are your employees trained in safe lifting procedures? __________
- H 2. Is all gear and equipment used for material handling physically inspected at the beginning of each shift? __________
- H 3. Are chain slings being used? If so, do they bear an indication of the month in which it was last thoroughly inspected? __________
- H 4. Is there a certification record being maintained and kept readily available for testing of hooks where manufacturers weight recommendations are not available? Does it include the date of weight test, the signature of the person who performed the test, and an identifier for the hook tested? __________
- H 5. Are chain falls and pull-lifts clearly marked to show the capacity? __________
- H 6. Are chain fall hooks moused with a safety latch? __________
- I 1. Does the company utilize equipment/procedures requiring a lockout / tagout program? __________
- I 2. Does the company maintain a Written Lockout/Tagout program consisting of energy control procedures, employee training, and periodic inspections? __________
- I 3. Are locks provided to authorized persons and required to be used for no other use than Lockout? __________
- I 4. Are all personnel trained to understand and respect the Danger tags associated with Lockout/Tagout? __________
- I 5. Are periodic inspections of the Energy Control Program conducted on at least and annual basis? __________
- I 6. Are lockout devices other than locks provided to employees to lockout specific devices, such as; group lockout devices, valve devices or circuit breaker devices? __________
- I 7. Do you work aboard Navy ships? If yes, are employees trained in the requirements of the Navy's Tagout system? __________
- J 1. Is your company required to comply with the Drug Free Workplace Act as a result of receiving $25,000 or more from federal contracting? __________
- J 2. Do you require pre-employment drug screening? __________
- J 3. If your firm currently performs drug screening, what drugs of abuse do you test for? __________
- J 4. Does the company perform random drug screening on "safety sensitive" or high-risk job classifications? __________
- J 5. For the hypothetical situation where a company employee is suspected of using or possessing illegal drugs on the work site (for example a drug dog alert or uncharacteristic behavior), describe your company's response. __________
- J 6. Do you have people trained in first aid and CPR? __________
- J 7. Is a first aid kit available and maintained at each work site? __________
- J 8. Do your employees know what to do in the event of a work-related injury? __________
- J 9. Do you maintain an OSHA 300 log? __________
- K 1. Does the company use portable tools? __________
- K 2. Does the company have a training program that includes the safe use of portable tools? __________
- K 3. Are portable tools inspected or safety checked prior to issue? __________
K 4. Are portable grinders with abrasive wheels greater than 2" issued with wheel guards and manufacturer-provided handles in place? __________
Are employees required to keep guards in place during use? __________
- K 5. Is use of compressed air for cleaning or blow-down limited to situations where it can be and is regulated to less than 30 psi? __________
- K 6. Are all portable electric tools which require grounding provided with a continuous ground? __________
- K 7. Are portable tool cords and electrical extension cords inspected for cuts in the insulation or loose connections prior to use in any shift? __________
- K 8. Are pneumatic air hoses inspected prior to use and checked for leaks, while in use? __________
- K 9. Are Chicago type couplings wired together? __________
- K10. Is the PPE appropriate for use with specific tools required to be used and is it provided (e.g. gloves with sharp edges or face protection with grinders)? __________
- L 1. Does the company use powered industrial trucks and aerial lifts? __________
- L 2. Has the employer implemented a training program? (1910.178(l)(2)) __________
- L 3. Does the employer have a training program for operating? (1910.178(l)(3)) __________
- L 4. Has the employer certified that each operator has been trained and evaluated? Certification shall include name of operator, date of training, date of evaluation and identity of person(s) performing training or evaluation? (1919.178(l)(6)) __________
- L 5. Does the employer have a refresher training and evaluation program? (1910.178(l)(4)) __________
- L 6. Are operators reevaluated at least every three years? (1910.178(l)(4)iii) __________
- L 7. Are operators required to use seat beats where provided? __________
- L 8. Are vehicles inspected daily before use? (1910.178(q)(7)) __________
- L 9. Are all aerial lift operators trained in safe operating procedures? (1910.67) __________
- L10. Are employees required to wear safety harnesses and lanyards while operating a boom type aerial lift? (1910.67) __________
- L11. Have employees been instructed in proper attachment point of a lanyard? __________
- L12. Have employees been instructed to wear life vests when working in aerial lift basket over water? __________
- M 1. Has the employer completed the required workplace hazard assessment to determine if hazards are present or are likely to be present? (1915.152) __________
- M 2. Are eye or face protection devices provided and worn where there is a danger of flying particles or corrosive materials? (1915.153) __________
- M 3. Are approved safety glasses required to be worn at all times in areas where there is risk of eye injuries such as punctures, abrasions, contusions or burns? (1915.153) __________
- M 4. Are employees who need corrective lenses (glasses, contact lenses) in working environments with harmful exposures, required to wear only approved safety glasses, protective goggles, or to use other medically approved precautionary procedures? (1915.153) __________
- M 5. Are protective gloves, aprons, shields, or other means provided against cuts, corrosive liquids and chemicals? (1915.157) __________
- M 6. Are hard hats provided and worn where danger of falling objects exists? (1915.155) __________
- M 7. Is appropriate foot protection required where there is risk of foot injuries from falling or rolling objects, or objects piercing the sole? (1915.156) __________
- M 8. Are all reissued protective equipment maintained in a sanitary condition and ready for use? (1915.152) __________
- M 9. Do you have eye wash facilities and a quick drench shower within a work area where employees are exposed to injurious corrosive materials? (1910.151) __________
- M10. Where special equipment is needed for electrical workers, is it available? (1910.335) __________
- M11. Are adequate work procedures, protective clothing and equipment provided and used when cleaning up spilled toxic or otherwise hazardous materials or liquids? (1910.120 (g)) __________
- N 1. Does the company use respiratory protection? __________
- N 2. Does the company have a written Respiratory Protection Program? __________
- N 3. Who is designated as the Program Administrator or Manager? __________
- N 4. Have fit test personnel been themselves trained in proper fit procedures? __________
- N 5. Are different types and sizes of respirators available in order to establish a comfortable and effective fit? __________
- N 6. Is the Medical Evaluation Questionnaire of 29 CFR 1910.134 Appendix C used prior to respirator fit testing? __________
- N 7. Do you have a Physician or other Licensed Health Care Professional (PLHCP) who evaluates personnel prior to fit testing? __________
- N 8. What are your requirements relative to facial hair and respirator use? __________
- N 9. Is training and fit testing provided prior to use and at least annually thereafter? Does training include proper use, wear, care, storage, cleaning, and limitations? __________
- N10. What is your change-out procedure for filters and cartridges? __________
- N11. Upon what do you base change-out guidance for cartridges which do not have an end of service life indicator? __________
- N12. What type of fit test do you conduct? Quantitative or Qualitative? __________
- N13. What is your policy with respect to personally owned respirator use on the job? __________
- N14. What cleaning procedures, if any, are in effect for reissued respirators? __________
- N15. Are any respirators maintained for emergency use and how often are they inspected? __________
- N16. Does your company use any supplied air respirators? __________
- N17. Is grade D breathing air supplied? __________
- N18. Is fit testing protocol performed using 1910.134 or manufacturer's instructions? __________
- O 1. Does the company have a written safety policy? __________
- O 2. Is a safety manager or designated technician employed? __________
- O 3. Are periodic safety meetings, gangbox or tailgate sessions held with employees? __________
- O 4. Is first line supervision responsible for the safety of employees assigned to them? __________
- O 5. What is the company's procedure for dealing with a report of a safety violation at another contractor's site? __________
- O 6. Do you require that your subcontractors comply with the same safety rules to which you are held? __________
- O 7. Do you have a program for New Employee Orientation that includes all job related safety concerns? __________
- O 8. Are accidents and incidents investigated promptly with reports forwarded to your management and to the prime contractor for whom you are working? How long after the accident should one expect to receive such a report? __________
- O 9. Are lessons learned from accidents / incidents communicated to other supervisors and workers within your organization? __________
- O10. Do you require a subcontractor supervisor investigation form to be submitted in the event of an accident / incident at your site? __________
- P 1. Is scaffolding erected & dismantled under the supervision of a competent person? (1915.71(b)(7)) __________
- P 2. Are the scaffolds maintained in a safe secure condition? (1915.71(b)(5)) __________
- P 3. Is scaffolding constructed in accordance with recognized principles of design and accepted standards? (1915.71(b)(1)) __________
- P 4. Are toe boards installed where needed to prevent tools and materials from falling on persons below? (1915.71(j)(5)) __________
- P 5. Where required, are toprails and midrails utilized? (1915.71(j)(1)) __________
- P 6. Are scaffolds and their support capable of supporting the load with a safety factor of not less than 4? (1915.71(b)(1)) __________
- P 7. Does access to scaffolds consists of well secured stairways, cleated ramps, fixed or portable ladders? (1915.71(k)(1)) __________
- P 8. For marine hanging staging, contact VSRA for assistance. __________
- Q 1. At what height above the deck below are personnel required to wear Personal Fall Arrest Systems (safety harnesses with lanyards)? (1915.159) __________
- Q 2. Does the company provide safety harnesses and lanyards for unguarded work situations? (1915.152) __________
- Q 3. Are personnel trained in the use of safety harnesses and lanyards before use? (1915.159) __________
- Q 4. Are personnel working near unguarded edges over water provided with and required to properly wear personal flotation devices? (1915.73 & 1915.158) __________
- Q 5. If ship lifeline removal is required in the course of work, what fall protection is required? (1915.71(j)) __________
- Q 6. Where deck plates or false decks are removed, what minimum planking is required? (1915.73) __________
- Q 7. Are employees visually restricted by blasting hoods, welding helmets, and burning goggles required to work from scaffolds and not from ladders? (1915.74) __________
- Q 8. Are all hoses, lines and leads elevated, tied up, or covered with planks where they might cause a trip hazard? (1915.91) __________
- Q 9. Are work areas kept clean of debris such as welding rod tips, bolts, nuts, flashlight batteries and the like? (1915.91) __________
- Q10. Is ladder safety covered in employee training or orientation? (1915.72) __________
- Q11. For hopper platform fall protection, contact VSRA for assistance. __________
- Has not been cited by the Norfolk Area Office within the past three (3) years for alleged violations classified as "repeated" and/or "willful."
- Will ensure employee training in the program (including supervisor personnel) utilizing VSRA supported safety and health training programs or equivalent training.
- Has a comprehensive written safety and health program in place, which is at least equivalent to the criteria referenced in Section VI, Paragraph A.6 as the minimum established criteria for participation, including implementation of policies and procedures to ensure that safety rules and procedures are enforced at their work sites.
- Will complete Safety & Health Assessment (Appendix A) upon entry into partnership with review and certification by President/CEO that deficiencies have been corrected.
- Has policy and procedures that hold line supervisors and employees accountable for following established safety and health rules and OSHA regulations.
- Provides the level of training required by OSHA regulations to its employees either through VSRA, its own training personnel or other consultant/trainers.
- Will provide annual safety related data or statistics to the VSRA office by the 1st of March for the previous year concerning man-hours worked, lost day work injuries, accident records and training hours for employees. This data will be used to determine primary causes of injury and illness among participants in order to develop training, sound operating procedures, and abatement methods.
- Consultation Visits
- Safety and Health Management Systems Reviewed/Developed
- Technical Assistance
- VPP-Focused Activities
- OSHA Enforcement Inspections
- Offsite Verifications
- Onsite Non-Enforcement Interactions
- Participant Self-Inspections
- Other Activities
Confined Space Entry
The following components of a confined space program pertain to those employees that enter confined spaces and are in addition to the general training elements listed above.
The following questions pertain to Shipyard competent persons.
Reference: 29 CFR 1910.400-440
Reference: 29 CFR 1915.7 - 57
Reference: 29 CFR 1910.1200.
Reference: 29 CFR 1910.95
Reference: Lead (1910/1915.53, 1018, 1025, and 1027)
Heavy metals (various)
Reference: 29 CFR PART 1915 Subpart G
Chains and chain slings 1915.112
Shackles and hooks 1915.113 (b) (1)
Chain falls and pull-lifts 1915.114
Reference: 29 CFR 1910.147
Reference: 29 CFR 1910.147
29 CFR 1915.98 First Aid
46 CFR Part 40 Department of Transportation Drug & Alcohol
46 CFR Part 16 U.S. Coast Guard Drug & Alcohol Testing
41 USC §701 Drug Free Workplace Act of 1988
29 CFR 1904 Recording and Reporting of Occupational Injuries & Illnesses
Reference: 29 CFR 1910.241 - 244, 334
Reference: 29 CFR 1910.178
8 CCR § 3668
29 CFR 1910.67
Reference: 29CFR Parts 1910 & 1915 as indicated
Reference: 29 CFR 1910.134
Reference: 29 CFR 1910.241 - 244, 334
Reference: 29 CFR 1915 & 1926
Reference: 29 CFR 1915 § 71-74, 91, 152, 158-159
Appendix B - VSRA Member Participation in the VSRA and OSHA Partnering Program
to Protect Shipyard Workers in Safety and Health Matters
This company, ______________________, hereby voluntarily agrees to participate in the Virginia Ship Repair Association and Occupational Safety Health Administration Partnering Agreement dated December 19, 2006.
By signature below we indicate our intent to participate in this partnership and that said company:
(Print - Name of Authorizing Official)
(Print - Name of Authorizing Official)
(Print - Name of Authorizing Official)
(Print - Name of Authorizing Official)
Appendix C - Annual Partnership Evaluation Report
Purpose of Partnership
Goals of Partnership
Strategic Management Plan Target Areas (check one)
Strategic Management Plan Areas of Emphasis (check all applicable)
|Amputations in Construction||Oil and Gas Field Services|
|Blast Furnaces and Basic Steel Products||Preserve Fruits and Vegetables|
|Blood Lead Levels||Public Warehousing and Storage|
|Concrete, Gypsum and Plaster Products||Ship/Boat Building and Repair|
Section 1 General Partnership Information
|Date of Evaluation Report|
|Start Date||End Date|
|Evaluation Contact Person|
|# Active Employers||# Active Employees|
|Industry Coverage (note range or specific SIC and NAICS for each partner)|
Section 2 Activities Performed
Note whether an activity was required by the OSP and whether it was performed
2a. Training (if performed, provide the following totals)
|Training sessions conducted by OSHA staff|
|Training sessions conducted by non-OSHA staff|
|Training hours provided to employees|
|Training hours provided to supervisors/managers|
Comments/Explanations (briefly describe activities, or explain if activity required but not performed)
2b. Consultation Visits (if performed, provide the following total)
|Consultation visits to partner sites|
Comments/Explanations (briefly describe activities, or explain if activity required but not performed)
2c. Safety and Health Management Systems (if performed, provide the following total)
|Number of systems implemented or improved using the 1989 Guidelines as a model|
Comments/Explanations (briefly describe activities, or explain if activity required but not performed)
2d. Technical Assistance (if performed, note type and by whom)
Provided by OSHA Staff
Provided by Partners
Provided by Other Party
|Interpretation/Explanation of Standards or OSHA Policy|
|Other (please specify)|
2e. VPP-Focused Activities (if performed, provide the following totals)
|Partners/participants actively seeking VPP participation|
2f. OSHA Enforcement Activity (if performed, provide the following totals for any programmed, unprogrammed, and verification-related inspections)
|OSHA enforcement inspections conducted|
|OSHA enforcement inspections in compliance|
|OSHA enforcement inspections with violations cited|
|Average number of citations classified as Serious, Repeat, and Willful|
2g. Offsite Verification (if performed provide the following total)
|Offsite verifications performed|
2h. Onsite Non-Enforcement Verification (if performed provide the following total)
|Onsite non-enforcement verifications performed|
2i. Participant Self-Inspections (if performed provide the following totals)
Hazards and/or violations identified and corrected/abated
2j. Other Activities (briefly describe other activities performed)
Section 3 Illness and Injury Information*
# of Days Away from Work Restricted and Transferred Activity Cases
|Three-Year Rate (2006-2008)|
|BLS National Average for 2005||
*Sample Chart - not required format
Section 4 Partnership Plans, Benefits, and Recommendations
Changes and Challenges (check all applicable)
|OSHA Enforcement Inspections|
Plans to Improve (check all applicable)
|Meet more often|
|Improve data collection|
|Conduct more training|
Partnership Benefits (check all applicable)
|Increased safety and health awareness|
|Improved relationship with OSHA|
|Improved relationship with employers|
|Improved relationship with employees or unions|
|Increased number of participants|
|Continue with the following provisions:|
|Terminate (provide explanation)|