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Gilbane Building Company-Northwest Mutual Tower and Commons



The Occupational Safety and Health Administration
for the
DuPont CH3 Project in Elk Grove Village, Illinois


    Holder Construction Group, LLC (Holder) and the Chicago North Area Office of the Occupational Safety and Health Administration (OSHA) recognize the importance of providing a safe and healthful work environment for employees engaged in the construction industry. This OSHA Strategic Partnership Agreement (OSP) at the DuPont CH3 Project in Elk Grove Village, Illinois, will facilitate the goals of OSHA to reduce occupational-related fatalities and serious injuries within the construction industry.

    Holder Construction Group, LLC, which was established in 1960 in Atlanta, Georgia, employs more than 1,000 workers in locations in Atlanta, Georgia; Phoenix, Arizona; Dallas, Texas; Charlotte, North Carolina; San Jose, California; and Washington, D.C. The $190 million DuPont CH3 project is located at 1400 Devon Ave, Elk Grove Village, Illinois. The project consists of construction of a 317,000 square foot Data Center. There will be approximately 30 subcontractors with 200-300 employees working at the site throughout the duration of the project. It is expected to take 12 months to complete. All contractors and their subcontractors that work on this project will be considered Partners. The activity level required to complete this project on schedule will call for complete compliance and cooperation efforts by all parties to ensure this project has a safe and healthy work environment at all times.

    The groups listed below have developed this OSHA Partnership Agreement jointly with a common objective to provide a safe and healthy environment for all at the DuPont CH3 project. It is the intent of this agreement to focus their combined expertise and knowledge to promote safety and encourage all workers on site to do their part in doing the same.

    • Holder Construction Group, LLC
    • U.S. Department of Labor/Occupation Safety and Health Administration – Chicago North Area Office
    • Illinois Onsite Safety and Health Consultation – Illinois Department of Labor
    • Plumbers Local Union 130
    • International Brotherhood of Electrical Workers, Local 134
    • The United Brotherhood of Carpenters & Joiners, Local 839
    • Laborers International Union of North America, Local 118
    • Pipefitters Local Union 597
    • International Association of Iron Workers, Local 1
    • International Union of Operating Engineers, Local 150
    • International Association of Sheet Metal Workers, Local 73


    The purpose of this Partnership is to provide a safe and healthful work environment for employees involved in the construction industry. Holder is committed on preventing serious accidents and fatalities during the construction of the DuPont CH3 Data Center through increased training, implementation of best work practices, enhanced safety and health programs, and compliance with applicable OSHA standards and regulations.


    The overall goal of the partnership is to create a working relationship that focuses on preventing work-related fatalities, eliminating serious workplace hazards, and establishing a foundation for the development of an effective safety and health program.

    Specific responsibilities for contractor compliance and involvement in the partnership for compliance, site audits, partnership improvements and evaluations of partnership modifications and achievements are delineated in Paragraph X of this document. Responsibilities are delineated for Holder Construction, OSHA, IL On-Site Safety and Health Consultation Program and Trade Unions.

    1) Maintain the project-wide injury and illness rate 25% below the 2015 BLS Total Recordable Case (TRC) rate and Days Away from Work, Job Transfer or Restriction (DART) rate for the industry. Establish proactive measures for the common hazards found at construction sites.
    1. Provide all necessary engineering controls, administrative controls and personal protective equipment.
    2. Provide a comprehensive Job Site Safety Orientation for all workers prior to allowing them to work on site
    Holder will collect and calculate the following injury and illness data on a monthly basis for comparison to the national average:
    - Total Case Incident Rate (TCIR)
    - Days Away / Restricted and Transfer Date (DART)
    Holder will compare the sites (TCIR) and (DART) with the 2015 BLS data published (TCIR) rate of 3.3 and a (DART) rate of 1.3 for (General Contractors) NAICS Code 2362.
    2) Promote cooperative relationship between labor and management and encourage employee participation to achieve a safe and healthful workplace.
    1. Conduct weekly toolbox safety meetings.
    2. Conduct training courses every month that will equate to the 10 and 30 hour classes at the end of the project. These classes are available to all employees working on site.
    3. Keep open door safety policy and encourage hazard reporting.
    4. Conduct hazard analysis during Pre-Task Safety Planning.
    5. Ensure worker participation in safety committee.
    1. Minutes of tool box meeting will be used to track and document attendance.
    2. Track number of workers who have completed required safety and health training.
    3. Track number of supervisors/managers who have completed required safety and health training and training hours.
    4. Track number of incoming safety issues, suggestion forms and complaints and their resolution.
    3) Identify and prevent the most common causes of workplace injuries and illnesses in the construction industry, included but not limited to: falls, electrical safety, struck-by, caught in/between, silica, carbon monoxide, heat stress, cranes and noise.
    1. Provide weekly toolbox safety meetings and conduct 10 and 30 hour OSHA training courses (Spanish & English).
    2. Implement a six feet fall protection rule.
    3. Require 100% hand protection.
    4. Conduct site audits and daily site walk through.
    5. Practice daily morning stretch and flex.
    1. Site safety personnel will conduct daily, weekly and monthly audits to ensure that the most common hazards are addressed.
    2. Track number of workplace inspections performed
    3. Track number of hazards and corrected/abated
    4. Track response time for correcting identified hazards
    5. OSHA log 300 will be used to track the number of work-related injuries and illnesses.
    4) One hundred percent (100%) of contractors and subcontractors to have site-specific comprehensive written safety and health programs.
    1. Written safety and Health programs will be required for all contractors, subcontractors and tier-subcontractors. Holder will review and maintain copies.
    1. Conduct worker opinion survey about the program effectiveness at the conclusion of the project
    2. Number of programs implemented or improved using the updated guidelines

    The Safety and Health Management System (SHMS) is a critical part of this OSHA Partnership Agreement in that it is an important aspect of collaboration between the project management team, supervisors, and the workers on site. This Safety and Health Management System reflect OSHA's updated safety and health program management guidelines. It will include but not be limited to the following core elements:

    Leadership / Management Roles

    Holder will implement a Safety and Health Management System patterned after OSHA Safety and Health Program Management Guidelines that will encourage partnering employers to commit a high level of worker involvement to assist in monitoring and identifying job site hazards on a continual basis to prevent accidents. The Safety and Health Management System will be implemented at the initiation of the partnership and continue to be implemented during the entire duration of the partnership.

    Worker Involvement

    The workers will be encouraged to report job site hazards and bring all potential hazards to the attention of Holder and/or supervisors if discovered for immediate response and correction. This will be encouraged in the following ways:

    • Holder will hold a Job Site Safety Orientation with each worker prior to work on site.
    • Holder will provide a system to allow workers to report potential job site hazards to Holder and/or supervisors upon discovery to stop work if necessary. Holder will require all workers to attend weekly tool box talks.
    • The Holder will participate in monthly safety audits and provide all subcontractors on site with a copy of the safety audit reports for use in discussion with workers during tool box talks.

    Worksite Analysis

    This project will focus on safety at all times and Holder will enforce job site safety compliance to OSHA standards including but not limited the following ways:

    • Holder will conduct daily site inspections and review all subcontractors, workers and site conditions for safe practices.
    • Holder will take immediate action to correct any unsafe conditions.
    • Holder will continually monitor all workers, visitors and others entering the work site to ensure safe conditions throughout the worksite.

    Hazard Prevention and Control

    Holder considers Hazard Prevention and Control a process requiring continual efforts of monitoring and identifying job site hazards and taking corrective actions to maintain a safe and healthy job site at all times.

    • Holder will ensure that hazard correction procedures are in place.
    • Holder will ensure that everyone knows how to use and maintain personal protective equipment.
    • Holder will make sure that everyone understands and follows safe work procedures.

    Safety and Health Training

    • Holder will ensure only properly authorized and instructed employees should be allowed to do any job.
    • Holder will ensure workers do not do a job that appears to be unsafe.
    • Holder will ensure that supervisors should be trained to recognize hazards and understand their responsibilities.


    • Holder will ensure workers and/or their representatives are involved with daily and monthly site inspections.
    • Holder will ensure workers and/or their representatives participate in monthly safety meetings as well as report any near miss or unsafe conditions.
    • Holder will provide support to all workers and/or their representatives by providing feedback on risks and assisting them in eliminating hazards.


    The program will be evaluated on an annual basis through the use of the Strategic Partnership Annual Evaluation Format measurement system, as specified in Appendix C of OSHA Directive CSP 03-02-003.

    It will be the responsibility of Holder to gather required data to evaluate and track the overall results and successes of the Partnership program. This data will be shared with OSHA and the Illinois Onsite Safety & Health Consultation Program.

    OSHA will conduct, write and submit the annual evaluation with input received from the partners.


    OSHA will conduct one unannounced enforcement verification inspection each year for the term of the project. These inspections will be conducted through normal enforcement inspection activity. Inspections conducted in response to complaints, Local Emphasis Programs, or referrals will qualify as the enforcement verification inspection if, in addition to addressing the complaint/referral item(s), the compliance officer completes the focused inspection protocol for the worksite. These inspections include the potential for issuing citations and assessing penalties for violations.

    Holder and its subcontractors will remain subject to OSHA inspections and investigations in accordance with agency procedures.


    The partnership may use any and all enforcement incentives allowed to any employer who receives an enforcement inspection. The incentives are detailed in the OSHA Field Operations Manual (FOM), OSHA Instruction CPL 02-00-160 (August 2, 2016). This partnership may not include any programmed inspection deferral or deletion provisions outside the scope of those provided to an employer through OSHA's current policy directives.

    OSHA will also offer the following incentives (as resources permit):

    1. Provide outreach, technical assistance and training to include:
      1. Being available for a variety of offsite activities such guidance in conducting audits and evaluations.
      2. Seminars, workshops and other speaking events.
      3. Informational materials such as safety and health brochures, pamphlets, and electronic tools.


    Holder in association with U.S. Department of Labor/Occupational Safety and Health Administration – Chicago North Area Office, Illinois Onsite Safety and Health Consultation – Illinois Department of Labor and all listed Unions will form a partnership committee to monitor the implementation of this Agreement. It will consist of a representative from each of the designated partners. Holder will serve as the chairperson and as OSHA's primary contact. The Committee will review contractor compliance and involvement in the partnership, analyze job site audits, make partnership improvements, and evaluate partnership modifications, achievements, and success.

    Holder Construction Group, LLC will:

    • Implement Holder Construction Group, LLC's comprehensive safety and health programs, which includes:
      1. Management commitment and employee involvement;
      2. Hazard analysis;
      3. Hazard control;
    • Mentor subcontractors who have not yet developed their own safety and health program and, if necessary, refer them to OSHA and/or On Site Consultation for assistance.
    • Enforce 100% fall protection for all fall hazards over six (6) feet.
    • Act as the Project Site Safety Leadership Team and will share the responsibility for overseeing site safety, to serve as a point of contact, and to oversee the partnership goals.
    • Conduct daily safety audits.
    • Ensure that all subcontractors participate in job-site safety meetings/toolbox talks on a weekly basis and shall document all attendance and topics.
    • Submit monthly accident reports to the partners, including first aid, injury, property damage, and near-miss reports.
    • Coordinate and conduct a comprehensive site audit on a monthly basis. OSP Partners and subcontractor representatives, with the exception of OSHA, will participate in the site safety audit. If non-compliant activity or hazards are discovered, immediate correction is required. Holder will document the corrective action taken, and share this information during the quarterly update meetings.
    • Allow OSHA access to the site during inspection activities (monitoring and un-programmed activities such as fatalities and employee complaints).
    • Audit the partnership and make recommendations for improvement.
    • Share and make available to all workers job-site inspections and near-misses incidents.
    • Require the use of appropriate personal protective equipment by all entering the work site. Appropriate personal protective equipment will include leather work shoes / boots (dress shoes, tennis shoes and any other types of shoes are not allowed on site), ANSI approved hardhats, eye protection and high-visibility reflective vests or clothing as a minimum, will be worn at all times on the worksite.

    OSHA will:

    • Participate in the monthly Committee meetings, but not participate in the monthly site audit inspection.
    • Designate a Chicago North Area Office contact to be used as a resource for technical issues, and will be available to assist with safety and health training/tool box meetings.
    • Review Holder Construction Group, LLC safety and health self-audits.

    On-Site Safety and Health Consultation Programs will:

    • Appoint a representative to the Committee.
    • Participate in (1) safety audit per month.
    • Attend a minimum of (1) monthly Committee meeting per quarter.
    • Provide/assist in training as resources permit.
    • Provide industrial hygiene and safety consultation services upon request.

    Trade Unions will:

    • Appoint a representative to the Committee.
    • Represent all Unions affiliated with the work trade scopes of this project.
    • Assist in trade jurisdiction and work requirements and can offer additional OSHA certified safety training to their respective Union members.
    • Assist in planning and implementation of all safety and health management systems.


    This partnership does not preclude workers and/or employers from exercising any right provided under the OSH Act (or, for federal workers, 29 CFR 1960), nor does it abrogate any responsibility to comply with rules and regulations adopted pursuant to the Act.

  11. OSP TERM

    This agreement will terminate on December 1, 2017, or at the completion of construction activities if that occurs sooner. If any signatory of this agreement wishes to terminate its participation prior to the established termination date, written notice of the intent to terminate must be provided to all other signatories.

    If OSHA chooses to terminate its participation in the partnership, the entire agreement is terminated.

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


    United States Department of Labor
    Occupational Safety & Health Administration

    Based upon a mutual interest to protect construction workers, the parties below agree to the above terms on the Holder Construction /OSHA Partnering Agreement for the DuPont CH3 project in Elk Grove Village, IL.

    Signed this 2nd day of May, 2017

    • Angie Loftus, Area Director
    • Chicago North Area Office

    • Ben Noven, Division Manager
    • Illinois Onsite Consultation Program

    • Jim Mansfield, Business Representative
    • Plumbers Local Union 130

    • Terry Thvedt, Business Representative
    • The United Brotherhood of
    • Carpenters & Joiners, Local 839

    • Michael May, Business Representative
    • International Association of Sheet
    • Metal Workers, Local 73

    • Tim Gallager, Business Representative
    • Pipefitters Local Union 597

    • Mike Drew, Business Representative
    • International Union of Operating Engineers, Local 150

    • Shawn Belin, Vice President
    • Holder Construction Group, LLC

    • Jorge E. Cisneros, Safety Director
    • Holder Construction Group, LLC

    • Casey Kelly, Superintendent
    • Holder Construction Group, LLC

    • Colt Moylan, Business Representative
    • International Brotherhood of Electrical Workers,
    • Local 134

    • Leo Esparza, President
    • Laborers International Union of North
    • America, Local 118

    • Kenneth Davis, Business Representative
    • International Association of Iron Workers, Local 1
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