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Gay Construction Co.
Emory Healthcare

Emory University Hospital - Southeast Corner Addition and Pedestrian Walkway
Strategic Partnership
Occupational Safety and Health Administration
Atlanta-East Area Office
The Georgia Institute of Technology - Occupational Safety and Health
Programs Office
Gay Construction Company


    This partnership was developed jointly by Occupational Safety and Health Administration (OSHA), the Georgia Institute of Technology Onsite Safety and Health Consultation Program (Georgia Tech) and Gay Construction Company. This Partnership will cover the construction of the new Emory University Hospital – Southeast Corner Addition and Pedestrian Walkway Project. The common objective and goals of the Partnership are reducing injuries and illnesses, increasing safety and health training, sharing of best work practices and increasing the number employers with safety and health management systems. This Partnership is consistent with OSHA's long-range efforts to develop a contractor/ government partnership approach to safety management. It allows for better use of OSHA resources and innovation in safety management and encourages more participation in the safety process from the construction community.

    To facilitate the goal of reducing occupational related fatalities and serious injuries within the construction industry OSHA, Georgia Tech and Gay Construction Company will implement this agreement under the OSHA Strategic Partnership Program (OSPP). By combining its efforts, skills, knowledge and resources, OSHA, Gay Construction Company and Georgia Tech expect to reduce exposure to hazards and thereby decrease the possibility of serious injuries and fatalities at the Emory University Hospital - Southeast Corner Addition and Pedestrian Walkway Project.


    The Partnership will include the following Partners:

    • Occupational Safety and Health Administration
    • Gay Construction Company
    • Georgia Institute of Technology Onsite Safety and Health Consultation Program

    The primary objective of this partnership is to create a working relationship that focuses on preventing work-related serious injuries and fatalities, controlling or eliminating serious workplace hazards, and establishing a foundation for the development of an effective safety and health program. The goals employed to achieve these results will include the following:

    These tables are best viewed on tablets, notebooks, or desktop computer screens.

    Reduce the total number of injuries and illnesses cases by 10 percent, thereby providing a safe and healthful work environment for employees at the Project.
    1. Reviewing the OSHA 300 log data of the Partnership participants. Reviewing injury and illness trends and implementing effective corrective action(s).
    2. Calculating the employer's Total Case Incident Rate (TCIR) and Days away from work, restricted, or job transferred (DART)1 rates.
    3. Comparing this data with the baseline rates for the Partnership.
    1. This goal will be measured by the number of companies participating in the Partnership, which reduce their TCIR and DART rates below the baseline for the Partnership.
    2. Baseline will be based on the 2013 BLS Rates for Non-Residential Construction NAICS 2362, which is 2.7 and 1.5.
    Effectively control workplace hazards by increasing the number of construction companies with safety and health management systems.
    1. Reviewing the number of employers that receive comprehensive consultation visits.
    2. Reviewing the number of employers that work with the Partner to develop and implement comprehensive safety and health management systems.
    Measure the number of participants that develop and implement effective safety and health management systems, as a result of participating in the Partnership, compared to the (baseline) initial year of the Partnership.
    Increase the number of employees who are provided effective safety and health training, such as the OSHA 10-hour course.
    1. Evaluation of the employers that establish effective safety and health training programs.
    2. Evaluation of the employers that provide employees with OSHA 10-hour/OSHA 30-hour training.
    1. Measure the number of employers with effective safety and health training programs.
    2. Measure the number of managers, supervisors and employees provided with OSHA 10-hour/OSHA 30-hour training compared to the (baseline) initial year of the Partnership.
    Conduct effective self-inspections, sampling, monitoring, training and consultative activities in areas where employees might be exposed to health hazards such as the following: hazardous noise levels; lead; silica; asbestos; ergonomic stressors; and other health-related hazards. The overall outcome of this goal should be the reduced overexposure of workers to health hazards, as well as a reduced injury and illness rate.
    1. Track health hazard related program improvements, as well as training focused on the prevention of health hazards.
    2. Gay Construction Company will track the number of self-inspections and site audits, as well as the number of health hazards identified during these activities.
    A comparison will be made between the number of health hazards identified during self-inspections and audits conducted during the (baseline) initial year of the Partnership.

    1 Days Away from work, Restricted, or job Transferred (DART) rate: This includes cases involving days away from work, restricted work activity, and transfers to another job. It is calculated based on (N / EH) x (200,000) where N is the number of cases involving days away, and/or restricted work activity, and/or job transfer; EH is the total number of hours worked by all employees during the calendar year; and 200,000 is the base number of hours worked for 100 full-time equivalent employees. For example: Employees of an establishment including management, temporary, and leased workers worked 645,089 hours at this worksite. There were 22 injury and illness cases involving days away and/or restricted work activity and/or job transfer from the OSHA 300 Log (total of column H plus column I). The DART rate would be (22 / 645,089) x (200,000) = 6.8


    1. Gay Construction Company will:
      1. Establish a jobsite safety walk team, consisting of a representative of all primary subcontractors on site, implements the Safety Committee's Safety Works Philosophy, in that all accidents are preventable and unnecessary, and implement a comprehensive safety and health management system, which includes:
        1. Management commitment and employee involvement;
        2. Hazard analysis;
        3. Hazard control:
        4. Arrangement of training assistance for other stakeholders on site.
      2. Mentor subcontractors in safety and health management systems. Subcontractors shall include all multi-tiered subcontractors that arrive for work on the site.
      3. Treat all temporary workers, subcontractors included, like any other worker; making certain each worker has the training and personal protective equipment (PPE) necessary to complete their assigned tasks in a safe and productive manner.
      4. Where the potential for airborne silica exposure exists, require the use of wet cutting, soft cutting techniques and/or dust collection system, and when needed, the mandatory use of approved respiratory protection. To the extent feasible, personal air monitoring will be conducted to assess employee exposure levels. Where the potential for other health issues exist (i.e., carbon monoxide, lead, or large-scale use of chemicals in the building interior during floor finishing), Gay Construction Company will coordinate with the subcontractor responsible for creating the potential hazard and ensure that air monitoring is accomplished to assess employee exposure levels. Sampling results will be compiled and tracked by Gay Construction Company.
      5. Have the authority to enforce safety rules and regulations. This authority will include provisions to hold contractors and employees accountable and, if necessary, remove contractor employees and/or their supervision from the job site.
      6. Ensure that a risk assessment is performed by a competent person on all fall hazards. The probability and severity of occurrence for each identified hazard will be evaluated to eliminate or reduce the risk to as low a level as reasonably feasible through engineering or administrative controls.
        1. Critical risk will not be tolerated. No work will be performed until action is taken to reduce the level of risk to as low as reasonably feasible.
        2. Bricklayers performing overhand bricklaying and related work above lower levels must be adequately protected. No monitor system will be allowed.
        3. Workers on the face of formwork or reinforcing steel must be protected from falling by personal fall arrest systems, with the use of a positioning device and/or lanyards.
      7. Serious ergonomic hazards will be identified and corrected.
      8. Ensure that ground fault circuit interrupters (GFCI) are used to protect all electrical circuits that are installed for work. All contractors will ensure that employees are protected by the use of a GFCI at all times.
      9. The Superintendent and On-site Safety Manager for Gay Construction Company will serve as a point of contact, monitor safety and health at the site and its progress toward achievement of the Partnership goals.
      10. Gay Construction Company's Superintendent and On-site Safety Manager will ensure that daily Safety Audits are conducted (since this is a multi-employer worksite and all workers are to work together on safety issues). Gay Construction Company, upon request, will review subcontractor's daily log books, note any hazards found, and then review them with all Safety Committee members at the weekly Coordination/Subcontractor meeting.
      11. Conduct and document job site safety meetings/toolbox talks on a weekly basis.
      12. Submit monthly accident reports to the Partners, including first aid, injury, property damage and near miss reports.
      13. Coordinate and conduct a comprehensive site audit twice each month led by Gay Construction Company's On-site Safety Manager and Superintendent. Safety Committee and Subcontractor Members will participate in the site safety audit. If non-compliant activity or hazards are discovered, immediate correction is required. Gay Construction Company will document the corrective action taken and share this information with OSHA and the Georgia Tech during the quarterly update meetings.
      14. Continually audit the partnership's effectiveness and make recommendations for improvement when necessary.
      15. Establish an Employee Safety committee, consisting of, at a minimum, the foreman or company representative for each subcontractor and the On-site Safety Manager and Superintendent for Gay Construction Company, which will meet on a monthly basis to share the results of jobsite inspections, information concerning accidents and near misses, suggestions for improvement and recommendations for training for the general workforce. Near misses and daily safety audits will be continued to be discussed during Tool Box Talks.
      16. Ensure that no employees are allowed to work directly below a suspended load except for: employees engaged in the initial connection of steel; employees necessary for hooking or unhooking the load. The following criteria must be met when employees are allowed to work under the load: materials being hoisted shall be rigged to prevent unintentional displacement; hooks with self-closing safety latches or their equivalent shall be used to prevent components from slipping out of the hook; all loads shall be rigged by a qualified rigger. Appropriate use of tag lines will be utilized to prevent work below suspended loads.
      17. Require the use of appropriate personal protective equipment (PPE). Hardhats are mandatory. Employees exposed to or working with heavy equipment and all flagmen on site shall wear high-visibility reflective clothing. A 100 percent eye protection program will be implemented and enforced.
      18. Ensure that all signs and warnings will be posted in English and Spanish, as well as any other appropriate languages.
      19. Implement a 100 percent Fall Protection Plan for all work performed 6 feet or more above lower surfaces.
      20. Implement an effective Heat Illness Prevention Program to educate workers about the hazards of working outdoors in the heat and steps needed to prevent heat-related illnesses. This should utilize tools such as OSHA's Heat Safety Tool Smartphone App and the Employer Guide to Using the Heat Index.
    2. Subcontractors will:
      1. Appoint a representative to the site Safety Committee responsible for resolving job safety matters and serving as a liaison to Gay Construction Company's On-site Safety Manager and Superintendent. Every prime subcontractor will have a person available to participate in the Safety Committee. Participation in the Safety Committee will consist of, but will not be limited to, participation in the Project Team Safety Walkthroughs and monthly safety meetings.
      2. Conduct jobsite safety inspections for those employees under their control. This will be in addition to the general inspections that are to occur daily. If non-compliant activity or hazards are discovered, immediate correction is required. Documentation of abatement methods and verification must be submitted to Gay Construction Company's On-site Safety Manager and/or Superintendent.
      3. Participate in the weekly Safety Committee/Subcontractor meetings and safety audits. If non-compliance activity or hazards are discovered, immediate correction is required. Abatement methods and verification must be submitted to Gay Construction Company's On-site Safety Manager and/or Superintendent who will document the correction taken and share this information during the monthly update meetings.
      4. Share the results of jobsite inspections with all workers by posting them in the Project office.
    3. OSHA will:
      1. Participate, to the extent resources permit, in the quarterly Partnership Committee/Subcontractor meetings, but will not participate in the walk around inspections, except that verification visits may be scheduled as part of the weekly walk around inspection.
      2. Serve as a resource and liaison for Partnership participants and also assist with safety and health training, as resources permit.
      3. Give priority to the construction project when technical assistance is needed.
      4. Audit the monthly reports/documents and make recommendations for improvements in meeting Partnership goals.
      5. Conduct inspections in accordance with section IX of this Partnership.
      6. Conduct the annual Partnership Evaluation Report in accordance with section VI of this Partnership and effectively track the accomplishment of the established goals, as well as the site's objectives.
    4. Georgia Tech's On-site Consultation Program will:
      1. Perform quarterly jobsite inspection.
      2. Give priority consideration to requests for services to small contractors who are engaged in work at the Project.

    Gay Construction Company will use their system to collect and analyze injury and illness trends (including near-miss incidents) regarding all contractors performing work at the site. This data will be used as a tool to ensure continual safety and health improvement at the site. The management of this agreement will be accomplished by Gay Construction Company implementing a comprehensive jobsite safety and health management system which includes:

    1. Completing a risk assessment prior to exposing employee to potential safety and health hazards. This will be accomplished by the use of the Gay Construction Company Job Hazard Analysis (JHA) form.
    2. Working with OSHA, Georgia Tech and Safety Committee members to provide the resources to conduct initial monitoring for ALL toxins, carcinogens, or hazardous substances currently emphasized by OSHA and which present inhalation hazards, such as silica, lead, and cadmium. Employee exposures will be assumed and respiratory protection worn until the results of the initial monitoring studies are received and demonstrate no exposure problems or prior surveys show no hazard exists. Gay Construction Company will endeavor to ensure that no work with these materials will occur, thus preventing any exposure. Gay Construction Company will request periodic evaluation visits by its insurance company's Industrial Hygienist and Georgia Tech when appropriate.
    3. Daily audits will be performed by all contractors on site. In addition, a comprehensive audit of the jobsite will be performed twice each month. A representative of the subcontractors will be a safety audit participant in the jobsite areas where the subcontractor's employees may be exposed to hazards. Any hazards found during the audits will be corrected promptly. Items noted on the audit will be annotated on a daily log. When hazards cannot be corrected immediately, they will be tracked until abatement is completed. Employees exposed to hazardous conditions noted during daily safety audits will be informed of the hazard and effective interim control measures will be implemented. A record will be kept of all hazards found during the comprehensive audits and the number of hazards corrected as a result
    4. Implementing an aggressive Fall Protection Plan to include fall protection in all cases where work is being performed 6 feet or more above lower surfaces.
    5. Ensuring employees receive training as follows:
      1. Supervisory personnel will possess an OSHA 10-hour card or its equivalent. Gay Construction Company will work with all subcontractors to provide their supervisory personnel with an OSHA 10-hour card or its equivalent.
      2. All employees will receive a site-specific construction safety orientation covering jobsite safety and health issues, procedures relative to the work being performed, as well as the requirements outlined in the Partnership Agreement. In addition, employees shall receive training on the content of the Risk Assessment for operations they will encounter. This may require periodic retraining of employees on the content of the Risk Assessment as they become relevant due to entering new phases of construction. This material will be provided by Gay Construction Company to the Subcontractor's designated safety representative for completion.
      3. Safety and health training will be provided to all workers in a language they understand. Bi-lingual instructors will be contracted to perform this training. A list of instructors will be provided by Gay Construction Company to all subcontractors to ensure that all workers are effectively trained.
      4. Other hazard-specific training will be conducted on an as-needed basis.
      5. Subcontractors can utilize other instructors as long as they can show a valid certification card showing completion of the course. Gay Construction Company Contractors have primary responsibility for coordinating this training; however, as resources allow Georgia Tech will also provide assistance. Gay Construction Company plans to hold 10-hour Safety Training sessions periodically as needed to help train all personnel, as its schedule allows.
    6. Subcontractors with written safety and health management systems must submit them to Gay Construction Company for evaluation. Companies without safety and health management systems may adopt Gay Construction Company's safety and health management system, or develop an adequate safety and health management system with the assistance of Georgia Tech.
    7. Ensure health-related issues which occur during the course of the Project are adequately addressed by Gay Construction Company and/or the affected subcontractors, with the assistance of OSHA as its resources permit and Georgia Tech. All health-related issues will be discussed monthly during the Partnership meetings.
      1. An effective hearing conservation program, including noise monitoring and engineering controls, where possible, will be implemented by Gay Construction Company's Safety Department.
      2. An effective environmental monitoring program will be implemented to control airborne hazards, such as silica, and will include personal monitoring, employee training, implementation of engineering controls where possible, and the use of respiratory protection when necessary. Previous site-based data will be considered acceptable.
    8. Ensure compliance with the NFPA 70E when working on live electrical equipment, including training and the availability and use of personal protective equipment. A permit system will be implemented whenever work around live electrical systems will be done to ensure the implementation of appropriate protective measures prior to exposure. The permit form includes requirements for pre-task review and lock out/tag out procedures to be followed.
    9. Ensure all equipment capable of amputations is adequately guarded.
    10. Gay Construction Company will explore the possibilities of extending training opportunities to clinic personnel and area contractors based on relevance of the topics and availability of space.

    The program will be evaluated on an annual basis through the use of the Strategic Partnership Annual Evaluation Format as specified in Appendix C of OSHA Instruction CSP 03-02-003, OSHA Strategic Partnership Program for Worker Safety and Health.

    It will be the responsibility of Gay Construction Company's Contractors to gather required participant data to evaluate and track the overall results and success of the Partnership Program. This data will be shared with OSHA. It will be the responsibility of OSHA to write and submit the annual evaluation.


    Participant benefits from OSHA may include:

    1. Maximum penalty reductions allowed in the OSHA Field Operations Manual (FOM) for good faith and history.
    2. In the event that a citation with penalties is issued, the Area Director has the authority to negotiate the amount of an additional penalty reduction as part of the informal conference settlement agreement.
    3. Priority Consultation service and assistance from the Consultation Program for small employers working on the construction site.

    Establish an Employee Safety Committee that will meet on a monthly basis to share the results of jobsite inspections, information concerning accidents and near-misses, suggestions for improvement and recommendations for training for the general workforce. Near-misses and daily safety audits will be continued to be discussed during Tool Box Talks.


    1. Verification Inspections: OSHA will conduct the initial Verification Inspection no sooner than three months, but within four months after Partnership participants formally enter into this agreement. During this period, participants should develop and implement the safety and health management systems required under this Partnership. After this period, OSHA will conduct the initial Verification Inspection and annually thereafter. The Verification Inspection will be conducted as a focused inspection, per the appropriate OSHA guidelines. Compliance officers that are familiar with the Emory University Hospital – Southeast Corner Addition and Pedestrian Walkway Partnership will do Verification Inspections. Employee rights under the OSH Act will be afforded. During the Verification Inspections, if OSHA personnel identify serious hazards that site management refuses to correct, the scope of the inspection may be expanded.
    2. Complaint/Referral Investigations: This Partnership provides for the immediate response to each allegation of a safety or health hazard brought to its attention by any person. Upon a finding that an allegation is valid, the employer shall promptly abate the hazard.
    3. OSHA agrees that a copy of each non-formal complaint/referral related to the work site and filed with OSHA will be forwarded by fax, or personally delivered by a CSHO, to the Emory University Hospital - Southeast Corner Addition and Pedestrian Walkway Management office onsite. In accordance with applicable law, the name of the complainant requesting confidentiality will not be revealed. Gay Construction Company agrees to investigate these complaints, regardless of the employer involved, and provide OSHA with a written response within 5 working days.
    4. Accident Investigations: Employers engaged in this Partnership recognize that OSHA fully investigates accidents involving a fatality or serious physical harm. If during the course of the investigation OSHA determines that the incident resulted from violations of the OSHA standards, the employer will not be afforded Partnership benefits.

    This Partnership does not preclude employees and/or employers from exercising any right provided under the OSH Act, nor abrogates any responsibility to comply with rules and regulations adopted pursuant to the OSH Act.


    It is understood that this Partnership shall be in effect until completion of construction activities at the Emory University Hospital - Southeast Corner Addition and Pedestrian Walkway Construction Site, but in no case longer than three-years. Should any "signatory" stakeholder choose to withdraw prior to project completion, a written notice shall be given stating the reason(s) and providing 30 days' notice to the other party(s).

    If OSHA chooses to withdraw its participation in the Partnership, the entire Partnership is terminated. Any party may also propose modification or amendment of the agreement.

    Changes to the Partnership may be implemented if all parties are in agreement that it is in the best interest of all members involved.



    Partnership Signing Date:______________________



    • William C. Fulcher/li>
    • Area Director
    • Occupational Safety & Health Administration (OSHA)


    • David E. Carl
    • Gay Construction Company
    • Vice President/Project Executive


    • Daniel J. Ortiz
    • Program Manager
    • Georgia Tech Research Institute's, Safety, Health & Environmental Technology Division


    • Phillip L. Rutledge
    • Gay Construction Company
    • Senior Project Manager


    • Luke E. Spooner
    • Project Manager
    • Gay Construction Company


    • Michael H. Sewell, CSP, CHST
    • Safety Director
    • Gay Construction Company


    • Brian T. Baker
    • General Superintendent
    • Gay Construction Company


    • Zachary C. Pelfrey
    • On-site Safety Manager
    • Gay Construction Company
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