The U.S. Department Of Labor Allentown, Pa Area Office
The Lehigh Career & Technical Institute - Materials Handling/Logistics Technology Department
Warehousing, Storage, Distribution and Transportation Partnership member
PA/OSHA Consultation Program at Indiana University of Pennsylvania
- Identification of Partners:
- U.S. Department of Labor - Occupational Safety and Health Administration (OSHA) - Allentown Area Office;
- Lehigh Career & Technical Institute - Materials Handling/Logistics Technology Department;
- PA/OSHA Consultation Program at Indiana University of Pennsylvania;
- Warehouse, Storage, Distribution and Transportation partnership member and their employees - signatory members.
Background, Purpose and Scope:
In a cooperative effort to foster safe and healthful worksites and meet OSHA's strategic goal of improving the safety, health and well-being of the nation's workforce, the USDOL/OSHA Allentown Area Office, the PA/OSHA Consultation Program at Indiana University of Pennsylvania, the Lehigh Career & Technical Institute Materials Handling/Logistics Technology Department, and partnership member within the jurisdiction of the OSHA Allentown office (See Appendix A). These partnership member (hereafter referred to as "Partnership members"), which are warehousing, storage, distribution and transportation operations agree to establish a partnership program to reduce the number of injuries and illnesses resulting from events or exposures within the workplace, assure compliance with the most frequently cited OSHA standards for their industry, promote the integration of occupational safety and health training through vocational-technical school instruction, and encourage companies interested in pursuing participation in the Safety and Health Achievement Recognition Program (SHARP) of the PA/OSHA Consultation Program at IUP and/or OSHA's Voluntary Protection Program (VPP).
The primary purpose of the agreement is to prevent accidents, injuries, and fatalities resulting from work activities within the warehousing storage distribution and transportation industries. This partnership will (1) develop an initiative to improve safety and health performance by reducing the Total Case Incident Rate (TCIR) and Days Away Restricted and Transferred (DART) rate of partnership members over the life of the partnership, (2) identify within the participating members worksites if anything other than the focused hazards contributing to injuries and illnesses and if so, develop a strategy to control or eliminate those hazards, (3) aid in the development of a workplace Motor Vehicle safety program or facilitate in a mentoring process for those who have not yet developed such a program, and (4) promote encourage the PA/OSHA Consultation Program to assist Partnership members in workplace hazard recognition.
The focused hazards are defined as: contact with objects; overexertion and falls. These are further clarified as:
- contact with objects will include hazards associated with unsafe operation of powered industrial trucks;
- "overexertion" will include the hazards associated with ergonomic issues, including unsafe lifting activities;
- and falls can include same level falls and fall hazards to a lower level.
Over the last several years, there has been and continues to be a tremendous growth in the warehouse, storage, distribution and transportation industry, and as such this office began reviewing local and national data to identify what issues, if any, were occurring within this industry. In review of injury and illness data, the Bureau of Labor Statistics (BLS) has identified several "events" or "exposures" which were clearly at the forefront: industrial truck incidents, falls to lower levels and on the same level, overexertion involving ergonomic stressors and hazards primarily attributed to lifting, and finally transportation accidents.
This Partnership will be available to any employer in the Allentown OSHA Area Office jurisdiction which has a North American Industrial Classification System (NAICS) Code which falls within the major group of 423 - Merchant Wholesaler, 484 - Truck Transportation or 493 - Warehousing and Storage.
Note: Although OSHA's jurisdiction does not include over-the-road motor vehicle safety and does not currently have any standards to address motor vehicular safety/training, this partnership will attempt to address, to the extent feasible and applicable, this increasing hazard in an educational and outreach manner. Review of occupational injury and illness data has shown that within the trucking and warehousing industry, transportation accidents are the third leading cause of nonfatal occupational injuries involving days away from work1.
This Partnership is consistent with OSHA's long-range efforts to develop a business, labor, and government partnership approach to safety management. It will enable OSHA to leverage its resources more efficiently in promoting safety and health through a cooperative effort involving the partnership members and consultation services sharing their experiences and successes. This Partnership will have an increased impact on the partners by reaching a greater number of partnership member and employees and should achieve improved worker protection through a reduction of job related injuries and illnesses sooner than by traditional means. Additionally, this Partnership is aimed at developing or improving the partnership members safety and health management systems.
Goals and Measurements:
Reduce the number of injuries and illnesses resulting from the focused hazards within this industry group.
The number of injuries occurring in the focused hazards for each participant will be reviewed annually for to determine reduction from their baseline. Additionally, each participant's TCIR and DART rates will be analyzed for an overall reduction in injury and illness rates.
Upon entry into this partnership, and annually, thereafter, each partnership member will provide the number of OSHA recordable injuries and illnesses which involve "contacts with objects" (including hazards associated with unsafe operation of powered industrial trucks), "overexertion" (hazards associated with ergonomic issues, including unsafe lifting activities), and from "falls" (same level falls and fall hazards to a lower level). Data will be used to establish a baseline for each participant and to measure annual progress toward reaching the partnership's goals.
Develop a system for the early identification and correction of the focused hazards which have resulted in or had the potential for serious injuries, illnesses and fatalities within these industries.
This goal will be measured by the utilization of hazard identification checklists, the Warehouse Self-Inspection Safety Audit Forms (Appendix C)2, developed by the Warehouse Education Research Council (WERC), which specifically focuses on those hazards within this industry group. Summary data will be collected by the Allentown OSHA Area Office to be used as the basis for safety and health training for all of the participants and as part of the annual offsite review process.
Reduce the number of serious hazards within this industry group.
The partnership will measure the partnership members' abatement of hazards identified through self-administered hazard identification checklists, JSA's, SOP's, etc., as noted in item no. 2 and through tabulation of any OSHA inspection data, OSHA interventions, as well as any workplace recommendations that may be made during an OSHA inspection.
Provide safety and health training and technical assistance on existing and new OSHA regulations emphasis on accident root cause(s) of injury within the industry.
This goal will be measured by the number of presentations, speeches or training sessions provided to the partnering members. Information such as the topics, the number of attendees and the number of affected employees will also be gathered for tracking this goal.
Partnership member's Commitment/Role:
- Join partnership by signing Appendix A - Letter of Intent to Participate (Pledge) and provide to OSHA.
Develop, implement and communicate an effective comprehensive safety and health program specific to the warehouse, storage and distribution industry.
Partnership member agree to implement safety and health programs. Effective safety and health programs include the following elements:
- Management Leadership
- Employee Participation
- Identification of Hazards through Worksite Inspections
- Hazard Prevention and Control
- Employee and Supervisory Training
- Enforcement of the Safety Program
Note: An assessment of the safety and health program may be accomplished by utilization of such tools at the OSHA-33 (Safety and Health Program Assessment Worksheet - Appendix D), the OSHA Challenge Program Stages for General Industry (Appendix E), or an equivalent form reviewed by OSHA, such as the WERC Self-Inspection Safety Audit Checklist.
- Provide OSHA the TCIR and DART rates, as written into this agreement, needed to prepare the annual evaluation and complete the offsite verification required to measure the implementation and success of the partnership agreement. The Focus Injury and Training Data Collection Form (Appendix B) will be used to supply this calendar year information.
- Develop a system for the early identification and correction of the focused hazards (contacts with objects, overexertion, and falls) which have resulted in injuries and/or illnesses within their workplace.
- Monitor and manage the site's safety and health program to reduce the number of injuries, accidents and near misses resulting from the focused hazards.
- Assure that a company representative (hourly or management) is in attendance at each of the partnership's meetings and/or training sessions held every month.
- Unless obtained during an OSHA inspection, any site-specific information provided to OSHA by any of the partnership members of this Partnership shall be considered confidential, and protected from disclosure to outsiders, to the extent allowed by law, other than as necessary to accumulate industry-wide data, and shall not be relied on by OSHA to prove the existence of a citable violation of OSHA standards or the Section 5(a)(1) (General Duty Clause) of the OSH Act.
Annually, on or around the anniversary signing date of this partnership, new companies can be added as signatories to this agreement (completing Appendix A - Letter of Intent to Participate). Interested companies are encouraged to attend partnership meetings in the interim.
This partnership does not preclude employees and/or partnership member 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.
Lehigh Career & Technical Institute's Commitment/Role:
- LCTI will provide safety and health technical assistance in the area of forklift safety through instruction and, if requested, will continue to provide support in reviewing and updating OSHA's Powered Industrial Trucks (Forklifts) eTool.
- LCTI agrees to occasionally facilitate, broker and/or host technical safety and health meetings and training sessions at their site if space is available and there are no conflicts with school activities.
PA/OSHA Consultation Program Commitment/Role:
- The PA/OSHA Consultation Program will give partnership members a high priority for scheduling on-site consultation visits. They will also provide the employer with a report summarizing their findings and will assess the impact on workplace safety and health.
- The PA/OSHA Consultation Program will provide resources to assist in the training and education of partnership members and their employees as resources permit.
- Help identify (offsite), through the collection of OSHA 300 data, the primary causal factors in injuries and illnesses, in particular the top hazards within this industrial group and develop feasible and useful countermeasures for correcting those hazards. Individual partnership member are not required, by virtue of this Agreement, to adopt or implement such countermeasures.
- Provide information on training resources including attendance at available OSHA Training Institute courses, offered locally, and information on other available sources of training.
- Provide technical assistance such as but not limited to, interpretation or clarification as to the meaning and application of OSHA standards and policy. Also OSAH will provide training, under the terms of this agreement, to help participants understand, find and fix hazards at their worksites and improve their safety and health management systems.
- Assure OSHA's participation in the partnership's meetings and/or training sessions conducted every month, as resources allow.
- Designate an experienced safety and health specialist (CAS) to serve as a resource and liaison for partnership participants.
Annually, OSHA will conduct an offsite review of the written program elements of this agreement to ensure that participants are carrying out their commitments under the partnership. The review may include documents such as the most current annual report, OSHA Form 300 data or its equivalent, safety and health training programs (Focus Injury and Training Data Collection Form (Appendix B)), completed hazard identification checklists and abatement efforts.
Rights of the Parties and Employees:
All partners remain subject to normal OSHA inspection procedures. The provisions of this agreement identified herein shall not modify any legal or contractual rights and remedies. OSHA's Partnerships provide groups of partnership member, employees and employee representatives an opportunity to participate in an extended, voluntary, cooperative relationship with OSHA in order to encourage, assist, and recognize their efforts to eliminate serious hazards and achieve a high level of worker safety and health. Partnerships have proven to be valuable tools for both OSHA and its participants. By entering into a Partnership with a party, OSHA is not endorsing any of that party's products or services; nor does the Agency enter into a Partnership with the purpose of promoting a particular party's products or services.
Participation in this Partnership does not obligate an employer to implement any work practice, install or modify any equipment, or hire any individual as an employee or consultant. Actions taken by an employer with respect to its local workplace and operations, in furtherance of its participation in this Partnership, shall not necessarily be binding on or required by that employer at workplaces and/or operations maintained elsewhere by that employer.
In cooperation with its partners, OSHA will prepare the required annual evaluation of this partnership using Appendix G. The evaluation will review the implementation of the agreement, lessons learned, and changes that need to be made to meet the goals of the agreement.
This agreement will terminate three years from its signing date. Any signatory member may terminate their participation at any time upon written notification to OSHA. If OSHA chooses to withdraw its participation, the entire agreement is terminated. This agreement may be modified at any time with the concurrence of all of the signatories.
Paperwork Reduction Act Notice:
Paperwork Reduction Act Notice Form Approved OMB# 1218-0244 Expires 06-30-2009. Public reporting burden for the time needed to develop the Partnership requirements, craft agreement language, and conduct an internal review process is estimated to be an average of 11 burden hours per respondent.
Signature Page for Warehousing and Materials Logistics
Strategic Partnership Agreement
OSHA, LCTI and the PA/OSHA Consultation Program
All undersigned Parties mutually agree to the terms and conditions of this document and commencement of this Partnership Agreement.
- Jean G. Kulp
- Area Director
- USDOL/OSHA - Allentown Area Office
- Sam Gualardo
- PA/OSHA Consultation Program at I.U.P.
- Sandra J. Himes
- Executive Director
- Lehigh Career and Technical Institute
LETTER OF INTENT TO PARTICIPATE (PLEDGE)
WAREHOUSING AND MATERIALS LOGISTICS PARTNERSHIP
We have read the requirements to participate in the OSHA Warehousing and Materials Logistics and agree with all aspects of the program, including the submission of the required information.
Based upon the mutual interest to protect our employees we agree to the terms of the OSHA Warehousing and Materials Logistics Partnership Agreement
Focused Hazard and Training Data Collection Form
Please list the number of OSHA 300 recordable injuries and/or illnesses for Calendar Year 201____ in each category (if none - please indicate 0):
OSHA 300 Form Injury and Illness Information:
Total number of injury/illness cases which involve:
Safety/Health Training (classroom and/or computer based) Information for Calendar Year 201____:
Topics of Training (please provide examples of safety/health training topics):
Contact person reporting information:
Warehouse Self-Inspection Safety Audit Forms
Each employer has been provided with copies of the "Warehouse Self-Inspection Safety Audit Forms" originally appeared in Warehouse Safety Program Guidelines © 1990, by the Warehousing Education and Research Council (WERC). The forms have been reprinted by permission of WERC for use in the OSHA Warehousing Logistics and Material Handling Partnership.
OSHA's Safety and Health Achievement Recognition Program (SHARP), Pre-SHARP, and SHARP Demonstration
- Employer Eligibility. Partnership member who request a consultation visit may be considered for participation in Pre-SHARP. In order to begin this process, Consultation Projects must inform partnership member that they must:
- Request and receive a consultation visit that involves a full service safety and health hazard identification survey, including a comprehensive assessment of the worksite's safety and health management system.
- Have at least one year of operating history at the particular worksite for which the employer is seeking Pre-SHARP participation.
- Pre-SHARP Requirements. Consultation personnel shall inform partnership member that the following criteria must be met prior to and following the granting of Pre-SHARP status.
- Initial Requirements.
- Receive a full service, comprehensive consultation visit that involves a complete safety and health hazard identification survey, including a comprehensive assessment of the worksite's safety and health management system;
- Post the List of Hazards identified by the consultant(s);
- Provide information regarding all hazards identified by the consultant(s) to employees;
- Correct all hazards identified by the consultant(s);
- Submit hazard correction verification to the Consultation Project;
- Inform employees of hazard correction(s); and
- Provide evidence of having the foundation of a safety and health management system.
- Post Pre-SHARP Status Requirements.
- Implement the Action Plan developed with the consultant outlining the necessary achievements and time frames required for the employer to achieve SHARP status. The employer must provide timely progress reports to the Consultation Project Manager;
- Upon receipt of an approval letter from the Regional Administrator or CPM granting Pre-SHARP status, the employer must post the letter in a conspicuous area. At sites having recognized employee representative(s), the employer must notify the employee representative(s) of the employer's intention to participate in Pre-SHARP and involve the recognized employee representative in the process;
- Involve employees in the safety and health management system, including the implementation of the Action Plan;
- Agree to notify the Consultation Project Manager prior to making any changes in working conditions or work processes that might introduce new hazards into the workplace; and
- Agree to a full service, comprehensive consultation visit for safety and health at the end of the Pre-SHARP deferral period, which initiates the SHARP application process.
- Initial Requirements.
- Deferral Time Frame. The deferral time frame recommended by the Consultation Project Manager must not exceed a total of 18 months from the expiration of the latest hazard correction due date(s), including extensions.
- Consultation Project Responsibilities. The Consultation Project personnel must:
- Assure verification of hazard correction of all hazards and compliance with requirements to post the List of Hazards and other employee information;
- Assist the employer in the development of an Action Plan to be implemented by the employer. The Action Plan must outline a goal, recommended method of correction, and an expected completion date for the 50 basic attributes of the Form 33 that received a score of less than "two;"
- Determine if the employer is capable of meeting all SHARP requirements within the deletion period, including DART rate and TRC requirements;
- Provide a signed notice of intent to participate in Pre-SHARP, to be posted by the employer;
- Provide to the Regional Office a letter or e-mail certifying that the employer exhibits reasonable promise of achieving the agreed-upon milestones within the deferral period;
- Provide to the Regional Office a copy of the employer's Form 33 evaluation, including an Action Plan;
- Recommend a deferral period (not exceeding a total of 18 months, including extensions, from the end of the latest hazard correction due date) to the Regional Office; and
- Request that the Regional Office terminate the employer's Pre-SHARP status if the employer fails to maintain Pre-SHARP requirements, or fails to meet SHARP requirements within the established time frame.
- Regional Responsibilities. The Regional Administrator may grant a deferral from OSHA programmed inspections for the period recommended by the Consultation Project Manager and notify the appropriate Area Office of the deferral. Prior to granting a deferral, the Regional Administrator must concur that:
- The worksite has met or is likely to meet the applicable DART and TRC rate requirements;
- The employer has in place the foundation of a safety and health management system; and
- The Action Plan adequately outlines the goal, recommended method of correction, and an expected completion date for each attribute of the Form 33 that received a score of less than "two."
- OSHA Inspection(s) at Pre-SHARP Worksites. As noted above, partnership member that meet all the requirements for Pre-SHARP status may be granted a deferral from OSHA programmed inspections; however, the following types of incidents can trigger an OSHA enforcement inspection at Pre-SHARP sites:
- Imminent danger;
- Fatality/Catastrophe; or
- Formal complaints.
General Employer and Consultation Project Obligations
- Fatalities or Catastrophes at SHARP or Pre-SHARP sites. Consultants should advise partnership member that in the case of a fatality or catastrophe at a SHARP/Pre-SHARP site, the employer must notify the OSHA Area Office within eight (8) hours of the incident as required in 29 CFR 1904.39. Consultants must also inform partnership member that they must notify the CPM as soon as possible after notification of the incident. Until all citations have been issued, Consultation personnel are not permitted to discuss with the employer any issues related to the fatality or catastrophe or an OSHA enforcement inspection. After the enforcement investigation is concluded and/or all citations have been issued, the CPM must evaluate the SHARP/Pre-SHARP status of the worksite using the following criteria:
- If no citation is issued, an on-site visit must be conducted to ensure that all elements of the safety and health management system continue to be effective.
- If a serious or repeat citation is issued, a consultant must conduct an on-site visit to ensure that the alleged hazardous condition(s), which amounted to violation(s), have been corrected and that the safety and health management system is operating effectively.
- If the CPM believes that a serious or repeat citation is connected to a diminution in the effectiveness of the company's safety and health management system, the CPM will recommend the employer's withdrawal from SHARP/Pre-SHARP.
- If the CPM believes that there is no connection between the serious or repeat citation and the effectiveness of the employer's safety and health management system, the employer must be counseled on how to prevent a recurrence.
- If a willful citation is issued or there is evidence that the site's application or interim self-evaluation is inaccurate, the employer will be asked to withdraw from the program. If the employer does not withdraw voluntarily within 5 working days, participation must be terminated. The employer may re-apply to the program 12 months after withdrawal or termination.
- Changes that May Affect a SHARP or Pre-SHARP Employer's Eligibility.
- Relocation. Consultants must inform partnership member planning to relocate their facilities that they must notify the Consultation Project sixty (60) days in advance of the move. Consultants must also visit the new site within thirty (30) days after the new site becomes operational to ensure that an effective safety and health management system is in place and that the employer still meets all the requirements for exemption or deferral. If this is not the case, the CPM must ask the employer to withdraw from the SHARP or Pre-SHARP program.
- Change in Ownership and Organizational Changes. Whenever ownership or major organizational changes occur that may impact the effectiveness of the company's safety and health management system, the employer or employer representative must notify the consultation project. The CPM must then discuss the changes with the employer and schedule an on-site visit, if necessary.
- Failure to Maintain SHARP or Pre-SHARP Requirements. If an employer fails to maintain the participation criteria outlined in this Chapter, the CPM should give the employer the opportunity to voluntarily withdraw from the program.
- Voluntary Withdrawal from the Program. Any approved SHARP/Pre-SHARP participant may withdraw at any time. Withdrawal may occur as a result of plant closing, economic difficulty, change in management, or at the request of the employer or CPM. To withdraw, the employer must send a letter explaining the withdrawal and/or return the SHARP certificate to the CPM. The withdrawal is effective immediately upon receipt of the letter. The CPM will notify the Regional Office of the employer's withdrawal from SHARP/Pre-SHARP. Withdrawal from the Program will result in all program benefits including exemption or deferral status being withdrawn.
- Termination of Exemption or Deferral. If an employer fails to maintain the participation criteria outlined in this Chapter and refuses the opportunity to voluntarily withdraw from the program, the CPM must request that the Regional Administrator terminate the employer's participation in SHARP/Pre-SHARP. The employer and the Area Office must be notified in writing when SHARP/Pre-SHARP participation is terminated. The written notice to the employer must contain the reason(s) for the termination and outline the requirements for re-entry into the program.
Those partnership member who do not meet the SHARP requirements, but who exhibit a reasonable promise of achieving agreed-upon milestones and time frames for SHARP participation, may be granted Pre-SHARP status. Upon achieving Pre-SHARP status, partnership member may be granted a deferral from OSHA Programmed Inspections.
Challenge Stages at a Glance
|1. Management Leadership|
|Element||Stage I||Stage II||Stage III|
|1.1 Management Commitment|
|Mission and Policy Statements||Develop S&H Mission Statement, with input from employees, and a S&H Policy Statement.||Communicate statements; incorporate into new employee/contractor orientation.||Take proactive steps to ensure understanding by all employees and contract workers and that they become a routine part of regular communication.|
|Leadership by Example||Begins to participate in S&H activities and follow S&H rules.||Continue; increase frequency of manager participation in S&H activities.||Continue; ensure total involvement of all executives, managers, & supervisors|
|Resources||Commit initial resources to control identified hazards. Begin integrating S&H into other aspects of management planning.||Provide additional resources for S&H activities, including access to certified S&H and licensed health care professionals, and improve integration of S&H into other planning processes.||Continue committing and ensuring the utilization of adequate resources. Ensure integration of S&H into all planning processes in the site.|
|Goals and Objectives||Establish & communicate annual S&H goals & objectives based on findings from baseline hazard and trend analyses; and assessment of the site's safety and health practices.||Review the site's progress towards achievement of S&H goals & objectives; establish & communicate new goals, as appropriate.||Review, revise, and continue communicating S&H goals and objectives. Ensure S&H goals and objectives are routinely considered in site's activities and programs.|
|Responsibility, Authority, and Accountability||Develop a safety and health accountability plan for managers, supervisors, and non-supervisory employees.||Enforce accountability plan.||Fully implement accountability system for all workers, including incorporation of S&H responsibilities into job descriptions and performance plans. Assign additional responsibilities to non-supervisory employees as appropriate.|
|Communication||Establish clear lines of communication with employees & provide reasonable access to top management re: S&H issues.||Maintain clear lines of communication with employees re: S&H issues||Encourage open dialogue between management staff and employees.|
|Disciplinary Plan||No action required||Develop & begin implementing disciplinary plan for managers and employees.||Ensure discipline is equability enforced, ensure higher levels of compliance.|
|Annual Self-Evaluation||No action required||No action required||Develop system and written procedures to annually evaluate the total site's S&H management system. Complete at least one annual self-evaluation of the site's safety and health management system.|
|1.2 Employee Involvement|
|Employee S&H Perception Survey||Conduct baseline employee S&H practices perception survey.||No action required||Conduct follow-up employee S& H perception survey.|
|S&H Practices Change Plan||Develop an action plan to address findings from the baseline employee S&H practices perception survey.||Implement steps defined in the site's action plan to improve S&H culture.||Continue; ensure significant improvement in S&H culture|
|Employee Notification||Notify all employees of their S&H rights, the site's participation in Challenge, & VPP principles.||Notify new employees of their S&H rights, site participation in Challenge, & VPP principles. Incorporate into new employee/contractor orientation.||Continue for new employees. At least annually, re-enforce for all employees. Encourage freely reporting workplace hazards without reprisal.|
|Meaningful Employee Involvement||Establish a few key S&H teams; begin involving employees in S&H activities.||Increase participation on teams, and/or form additional teams. Involve employees in safety and health activities (e.g., accident/near-miss investigations).||All needed teams are functioning and meaningfully contributing to S&H. Ensure regular teams are routinely conducting audits, accident/incident investigations, self-inspections, and job hazard analyses. Improve and continue the site's hazard reporting system.|
|1.3 Contract Worker Coverage|
|Adherence to Rules||Require contractors and their employees to comply with OSHA and site S&H rules.||Improve and continue to enforce policy for S&H violations.||Improve and continue- enforce policy for safety and health violations.|
|Contractor Selection||No action required||Consider contractors' safety and health performance in the bidding process, including a review of injury/illness rates.||Fully establish and use selection criteria. Encourage contractors to develop their own S&H management systems & decrease high rates.|
|Contractor Hazards||Contractor ensures correction of any hazards in their work areas.||Develop & implement a formalized method including assignment of responsibility to identify, correct, & track hazards in contractors' work areas.||Include responsibility for hazard correction in writing, in the contracts.|
|Removal Policy||No action required||Develop & implement contractor policy for S&H violations, including removal and other penalties.||Penalty policy is understood by all contractors, described in their contracts, and adhered to.|
|2. Worksite Analysis|
|Element||Stage I||Stage II||Stage III|
|Baseline Safety and IH Hazard Analysis||Conduct the baseline analysis (may use outside sources), including a chemical inventory and evaluation of typical safety and health hazards.||No action required||Re-do baseline survey, if warranted by significant changes in tasks, equipment, or processes.|
|Hazard Analysis of Routine Jobs, Tasks, And Processes||No action required||Conduct hazard analysis and recommend controls for routine jobs, tasks, & processes that have had associated injuries/illnesses or significant incidents or near-misses; are perceived as high-hazard; or are required by a regulation or standard; observe guidelines.||Conduct hazard analysis and recommend controls for routine jobs, tasks, and processes that have written procedures, have been recommended for more in-depth analysis, or are determined by the Challenge participant to warrant hazard analysis|
|Hazard Analysis of Significant Changes||No action required||No action required||Conduct hazard analysis for significant changes (e.g., non-routine tasks or new processes, materials, equipment and facilities) and recommend controls prior to the activity or use.|
|Pre-use Analysis||No action required||No action required||Conduct pre-use hazard analysis of new equipment, chemicals, facilities, or significantly different operations or procedures. and recommend controls prior to the activity or use.|
|IH Program||No action required (See Baseline Hazard Analysis).||Follow up on results of baseline IH study. Conduct more in-depth analysis if warranted to determine actual employee exposures. Establish, document, & implement future sampling schedule, strategy, and rationale.||Continue to follow the written IH program; take proactive steps to improve control of health hazards to prevent occupational disease.|
|Routine Self-inspections||No action required||Develop a documented system for routinely scheduled self-inspections of the workplace; conduct inspections with S&H staff; covering entire worksite, at least semi-annually.||Continue to conduct routine self-inspections. Increase frequency to at least monthly, with the entire worksite covered at least quarterly.|
|Employee Hazard Reporting System||No action required||Develop & begin implementing hazard-reporting system for employees (maybe anonymous),||Encourage more active reporting; ensure regular feedback, using different media, to all employees on status of hazards reported.|
|Investigation of Accidents and Near-Misses||Develop and implement system to report and investigate accidents. Determine root causes and track correction to completion.||Expand system to include reporting and investigation of near misses. Continue investigating accidents, begin investigating near-misses, and making corrective actions.||Thoroughly report and investigate all accidents and near-misses.|
|Trend Analysis||Conduct trend analysis of injury & illness history (previous 3 years of OSHA 200/300 logs) and begin developing a plan for conducting analysis of other S&H-related information||Conduct trend analysis of other S&H information not yet studied; conduct one of injury & illness history if a year has gone by since initial analysis.||Trend analysis takes place regularly (at least annually) for all types of S&H information, and is utilized in setting future goals to address identified trends.|
|3. Hazard Prevention & Control|
|Element||Stage I||Stage II||Stage III|
|Certified Professional Resources||(see Management Commitment)||(see Management Commitment)||(see Management Commitment)|
|Hazard Elimination & Control Methods||Develop an action plan to prioritize and implement controls for hazards identified, through the baseline S&IH study, trend analysis of OSHA logs and accident investigations. Implement controls or (interim protection if long-term abatement) for top priority hazards before moving onto Stage II.||Complete long term abatement projects from Stage I. Develop an action plan to prioritize and implement controls for hazards identified through self-inspections, employee reports of hazards, and near miss investigations. Implement hazard controls (or interim protection) for top priority hazards before moving onto Stage III.||Complete long term abatement projects from Stage II. Continue to pro-actively identify, prioritize, and implement controls for hazards identified through all means (hazard analysis, trend analysis, accident and near miss investigation, self-inspections, employee reports of hazards, pre-use analysis, etc) so that there is a continuous loop of hazard id and control.|
|Hazard Control Programs||Inventory existing hazard control programs required by OSHA standards. Develop missing programs or modify existing programs.||Implement hazard control programs developed or modified in Stage I and train all workers on these programs.||Review hazard control programs annually and updated as new processes, jobs, and tasks are begun.|
|Documented System for Hazard Correction Tracking||Develop and begin implementing a hazard tracking system for hazards identified through the baseline hazard analysis, trend analysis of OSHA logs, and accident investigations.||Expand tracking system to include hazards identified through hazard analysis of routine jobs; self-inspections; employee reports of hazards; and near miss investigations.||Tracking system is fully functioning and includes hazards identified through all methods.|
|Preventive Maintenance||Conduct an inventory of equipment and machinery requiring preventive maintenance.||Review equipment inventory. Establish and implement preventive maintenance schedule.||Ensure schedule is routinely observed and preventive maintenance is regularly conducted.|
|Occupational Health Care Program||Conduct records review of previous three years OSHA 200/300 logs. Compare with insurance claims forms and ensure records are in order. Provide physician services for emergencies (see below).||Continue to provide access to licensed health care providers, health services, physician care, and emergency medical care. Arrange for services based on the outcomes of the baseline safety and health analysis.||Continue providing services listed in Stage I and II. In addition- Health Care providers visit the site, and assist in identifying causes and symptoms of injury/illness. Care provided in within the scope of licensure.|
|Emergency Preparedness and Response||Establish & communicate written procedures for responding to all types of emergencies; Make emergency services available on all shifts including: ambulances, EMT's, emergency clinics, or hospital emergency rooms. Provide at least one employee trained in first aid & CPR for each shift or an equally effective alternative. Conduct at least one evacuation drill & assess its effectiveness.||Continue providing emergency medical services. Establish an Emergency Response Team including first aid and CPR trained employees. Conduct at least one drill and assess it's effectiveness and follow-up on recommendations to improve emergency evacuation drills.||Continue providing emergency medical services. Establish a Haz. Mat. Team if necessary. Consult with local fire department to ensure adequate coverage for fire, explosion, or chemical release. Conduct evacuation drills at least annually and assess their effectiveness. Provide AED and training on its use for those on the Emergency Response Team.|
|4. Safety and Health Training|
|Element||Stage I||Stage II||Stage III|
|General guidelines||Observe OSHA guidelines in providing training for required programs.||Continue observing OSHA VPP guidelines in providing training.||Continue observing OSHA VPP guidelines in providing training.|
|Training for all workers||Provide training to all workers on their S&H rights, Challenge, VPP fundamental principles, hazards in the workplace, PPE, emergency evacuation procedures, and individual emergency responsibilities.||Continue providing training to all workers, including new workers, on their S&H rights, Challenge, VPP fundamental principles, hazards in the workplace, PPE, emergency evacuation procedures, and individual emergency responsibilities.||Take proactive steps to improve & continue providing training to all workers, including new workers, on their S&H rights, Challenge, VPP fundamental principles, hazards in the workplace, PPE, emergency evacuation procedures, and individual emergency responsibilities|
|Training for specific groups of workers||Provide specific training to managers and supervisors, to designated S&H staff and others with S&H responsibilities, and to contract workers to equip them with knowledge & skills needed to perform their S&H responsibilities in Stage I (i.e., hazard recognition, accident investigation and root cause analysis, hazard controls, OSHA standards, and VPP requirements).||Provide specific training to managers and supervisors, to designated S&H staff and others with S&H responsibilities, and to contract workers to equip them with knowledge & skills needed to perform their S&H responsibilities in Stage II.||Take proactive steps to provide specific training to all employees and contract workers to equip them with the knowledge & skills they need to perform their S&H responsibilities in Stage III.|
Safety and Health Program Assessment Worksheet | Blank Form 33
|Request Number||Visit Number||Visit Date|
|Legend: 0 = No; 1 = No, Needs major improvement; 2 = Yes, Needs minor improvement; 3 = Yes; NA = Not Applicable; NE = Not Evaluated; * = Stretch Items Attribute of Excellence|
|Synthesis Item Score|
|With the total knowledge you now have of this organization (whether or not such knowledge has been captured by attribute ratings), use your professional judgment to assign an overall score for the organization's safety and health system.|
|Hazard Anticipation and Detection|
|1. A comprehensive, baseline hazard survey has been conducted within the past five (5) years.|
|2. Effective safety and health self-inspections are performed regularly.|
|3. Effective surveillance of established hazard controls is conducted.|
|4. An effective hazard reporting system exists.No OSHA Challenge Administrators or current participants at this time.|
|5. Change analysis is performed whenever a change in facilities, equipment, materials, or processes occurs.No OSHA Challenge Administrators or current participants at this time.|
|6. Accidents are investigated for root causes.No OSHA Challenge Administrators or current participants at this time.|
|7. Material Safety Data Sheets are used to reveal potential hazards associated with chemical products in the workplace.No OSHA Challenge Administrators or current participants at this time.|
|8. Effective job hazard analysis is performed.No OSHA Challenge Administrators or current participants at this time.|
|9. Expert hazard analysis is performed.No OSHA Challenge Administrators or current participants at this time.|
|10. *Incidents are investigated for root causes.No OSHA Challenge Administrators or current participants at this time.|
|Hazard Prevention and Control|
|11. Feasible engineering controls are in place.No OSHA Challenge Administrators or current participants at this time.|
|12. Effective safety and health rules and work practices are in place.No OSHA Challenge Administrators or current participants at this time.|
|13. Applicable OSHA-mandated programs are effectively in place.No OSHA Challenge Administrators or current participants at this time.|
|14. Personal protective equipment is effectively used.No OSHA Challenge Administrators or current participants at this time.|
|15. Housekeeping is properly maintained.No OSHA Challenge Administrators or current participants at this time.|
|16. The organization is properly prepared for emergency situations.No OSHA Challenge Administrators or current participants at this time.|
|17. The organization has an effective plan for providing competent emergency medical care to employees and others present at the site.No OSHA Challenge Administrators or current participants at this time.|
|18. *Effective preventive maintenance is performed.No OSHA Challenge Administrators or current participants at this time.|
|19. An effective procedure for tracking hazard correction is in place.No OSHA Challenge Administrators or current participants at this time.|
|Planning and Evaluation|
|20. Workplace injury/illness data are effectively analyzed.No OSHA Challenge Administrators or current participants at this time.|
|21. Hazard incidence data are effectively analyzed.No OSHA Challenge Administrators or current participants at this time.|
|22. A safety and health goal and supporting objectives exist.No OSHA Challenge Administrators or current participants at this time.|
|23. An action plan designed to accomplish the organizations safety and health objectives is in place.No OSHA Challenge Administrators or current participants at this time.|
|24. A review of in-place OSHA-mandated programs is conducted at least annually.No OSHA Challenge Administrators or current participants at this time.|
|25. *A review of the overall safety and health management system is conducted at least annually.No OSHA Challenge Administrators or current participants at this time.|
|Administration and Supervision|
|26. Safety and health program tasks are each specifically assigned to a person or position for performance or coordination.No OSHA Challenge Administrators or current participants at this time.|
|27. Each assignment of safety and health responsibility is clearly communicated.No OSHA Challenge Administrators or current participants at this time.|
|28. *An accountability mechanism is included with each assignment of safety and health responsibility.No OSHA Challenge Administrators or current participants at this time.|
|29. Individuals with assigned safety and health responsibilities have the necessary knowledge, skills, and timely information to perform their duties.No OSHA Challenge Administrators or current participants at this time.|
|30. Individuals with assigned safety and health responsibilities have the authority to perform their duties.No OSHA Challenge Administrators or current participants at this time.|
|31. Individuals with assigned safety and health responsibilities have the resources to perform their duties.No OSHA Challenge Administrators or current participants at this time.|
|32. Organizational policies promote the performance of safety and health responsibilities.No OSHA Challenge Administrators or current participants at this time.|
|33. Organizational policies result in correction of non-performance of safety and health responsibilities.No OSHA Challenge Administrators or current participants at this time.|
|Safety and Health Training|
|34. Employees receive appropriate safety and health training.No OSHA Challenge Administrators or current participants at this time.|
|35. New employee orientation includes applicable safety and health information.No OSHA Challenge Administrators or current participants at this time.|
|36. Supervisors receive appropriate safety and health training.No OSHA Challenge Administrators or current participants at this time.|
|37. *Supervisors receive training that covers the supervisory aspects of their safety and health responsibilities.No OSHA Challenge Administrators or current participants at this time.|
|38. Safety and health training is provided to managers.No OSHA Challenge Administrators or current participants at this time.|
|39. *Relevant safety and health aspects are integrated into management training.No OSHA Challenge Administrators or current participants at this time.|
|40. Top management policy establishes clear priority for safety and health.No OSHA Challenge Administrators or current participants at this time.|
|41. Top management considers safety and health to be a line rather than a staff function.No OSHA Challenge Administrators or current participants at this time.|
|42. *Top management provides competent safety and health staff support to line managers and supervisors.No OSHA Challenge Administrators or current participants at this time.|
|43. Managers personally follow safety and health rules.No OSHA Challenge Administrators or current participants at this time.|
|44. Managers delegate the authority necessary for personnel to carry out their assigned safety and health responsibilities effectively.No OSHA Challenge Administrators or current participants at this time.|
|45. Managers allocate the resources needed to properly support the organizations safety and health system.No OSHA Challenge Administrators or current participants at this time.|
|46. Managers assure that appropriate safety and health training is provided.No OSHA Challenge Administrators or current participants at this time.|
|47. Managers support fair and effective policies that promote safety and health performance.No OSHA Challenge Administrators or current participants at this time.|
|48. Top management is involved in the planning and evaluation of safety and health performance.No OSHA Challenge Administrators or current participants at this time.|
|49. Top management values employee involvement and participation in safety and health issues.No OSHA Challenge Administrators or current participants at this time.|
|50. There is an effective process to involve employees in safety and health issues.No OSHA Challenge Administrators or current participants at this time.|
|51. Employees are involved in organizational decision making in regard to safety and health policy.No OSHA Challenge Administrators or current participants at this time.|
|52. Employees are involved in organizational decision making in regard to the allocation of safety and health resources.No OSHA Challenge Administrators or current participants at this time.|
|53. Employees are involved in organizational decision making in regard to safety and health training.No OSHA Challenge Administrators or current participants at this time.|
|54. Employees participate in hazard detection activities.No OSHA Challenge Administrators or current participants at this time.|
|55. Employees participate in hazard prevention and control activities.No OSHA Challenge Administrators or current participants at this time.|
|56. *Employees participate in the safety and health training of co-workers.|
|57. Employees participate in safety and health planning activities.|
|58. Employees participate in the evaluation of safety and health performance.|
OSHA Strategic Partnership Program | Annual Partnership Evaluation Report
|Purpose of Partnership|
|Goal of Partnership|
|Strategic Management Plan Target Areas (check one)|
|Construction||Amputations in Manufacturing|
|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 OSHA Contact Person|
|# Active Partnership member||# Active Employees|
|Industry Coverage (note range or specific SIC and NAICS for each partner)|
Section 2 | Activities Performed
|Note whether an activity was provided for by the OSP and whether it was performed|
|b. Consultation Visits|
|c. Safety and Health Management Systems Reviewed/Developed|
|d. Technical Assistance|
|e. VPP-Focused Activities|
|f. OSHA Enforcement Inspection|
|g. Offsite Verifications|
|h. Onsite Non-Enforcement Interactions|
|i. Participant Self-Inspections|
|j. Other Activities|
|2a. Training (if performed, provide the following totals)|
|Training session conducted by OSHA staff|
|Training session 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 provided for 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 provided for but not performed)|
|2c. Safety and Health Management Systems (if performed, provide the following total)|
|Systems implemented or improved using the 1989 Guidelines as a model|
|Comments/Explanations (briefly describe activities, or explain if activity provided for 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|
|2e. VPP-Focused Activities (if performed, provide the following total)|
|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 inspection 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 total)|
|Hazards and/or violations identified and corrected/abated|
|2j. Other Activities (briefly describe other activities performed)|
Section 3 | Illness and Injury Information
|Year||Hours||Total Cases||TCIR||# of Days Away from Work Restricted and Transferred Activity Cases||DART||Contact with Objects||Over-exertions||Falls|
|Baseline Avg (2008-2011)|
Section 4 | Partnership Plans, Benefits, and Recommendations
|Changes and Challenges (check all applicable)|
|OSHA Enforcement Inspection|
|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 partnership member|
|Improved relationship with employees or unions|
|Increased number of participants|
|Status Recommendations (check one)|
|Continue with the following provisions:|
|Terminate (provide explanation)|
1 BLS-Table R4. Number of nonfatal occupational injuries and illnesses involving days away from work by industry and selected events or exposures leading to injury or illness, 2010.
2 "Warehouse Self-Inspection Safety Audit" originally appeared in Warehouse Safety Program Guidelines © 1990, by the Warehousing Education and Research Council (WERC). Reprinted by permission of WERC for use in this OSHA Warehousing and Materials Logistics Partnership Agreement.