Strategic Partnership between
the U.S. Department of Labor Occupational Safety and Health Administration Madison Area Office,
the Wisconsin Onsite Consultation Program, Southern Wisconsin Building and Construction Trades Council, and AECOM for the Riverside Energy Center Project
in Northern Beloit, Wisconsin
IDENTIFICATION OF PARTNERS
AECOM, Wisconsin Onsite Consultation Program, Southern Wisconsin Building and Construction Trades Council and the Madison 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 Riverside Energy Center Project in Beloit, Wisconsin, will facilitate the goals of OSHA to reduce occupational-related fatalities and serious injuries and illnesses within the construction industry.
AECOM began construction of the Riverside Energy Center in September 2016 and plans to complete construction by October 2019. The $725 million power plant project is expected to generate approximately 1,000 construction jobs during the project, through completion. 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 healthful 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 employees at the power plant project worksite. It is the intent of this agreement to focus their combined expertise and knowledge to promote safety and health, and to encourage all workers on site to do their part in doing the same.
- U.S. Department of Labor/OSHA – Madison, Wisconsin Area Office
- Wisconsin Onsite Consultation Program
- Southern Wisconsin Building and Construction Trades Council
The purpose of this Partnership is to provide a safe and healthful work environment for workers involved in the construction industry. AECOM is committed to preventing serious incidents and fatalities during the construction of the Riverside Energy 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 working relationships that focus 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 Section X. of this document. Responsibilities are delineated for all partners: AECOM, Wisconsin Onsite Consultation Program, OSHA, all other contractors on site, and all trades. AECOM is engaged in power plant construction, NAICS = 237130. All data collect for the measures listed below will be shared with the Madison OSHA Area Office at the Partnership's regular meetings.
Maintain a project-wide injury and illness rate which is 50% below the 2016 BLS Total Recordable Case (TRC) rate and Days Away from Work, Restricted or Transfer (DART) rate for the industry Establish proactive measures for the common hazards found at construction sites.
Provide all necessary engineering controls, administrative controls and personal protective equipment.
Provide a comprehensive Job Site Safety Orientation for all workers prior to allowing them to work on site
Implement a job site wide hazard analysis to assure all anticipated hazards that can be engineered out are addressed, create administrative controls/procedures to cover those that cannot be engineered out and complete a personal protective equipment assessment.
AECOM will collect and calculate the following injury and illness data on a monthly basis for comparison to the national average:
- Total Recordable Case rate (TRC)
- Days Away/Restricted or Transfer rate (DART)
Promote a cooperative relationship between labor and management and encourage employee participation to achieve a safe and healthful workplace. Conduct weekly toolbox safety meetings.
Conduct monthly joint management/trade safety meetings.
Keep an open door safety policy and encourage hazard reporting.
Conduct hazard analysis during Pre-Task Safety Planning.
Ensure worker participation (all crafts represented) in the onsite safety and health committee.
Minutes of tool box and joint management/trade meetings will be used to track and document attendance.
Course rosters/sign-ins to be used to track the number of employees receiving training.
Hours spent conducting training employees and supervisors in all training activities will be collected.
Retain pre-task work sheets
Retain attendance rosters for safety committee meetings
Track incoming safety issues, suggestion forms and complaints and their resolution.
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, trenching/excavations, cranes, respirable crystalline silica, carbon monoxide, heat stress, and noise. Conduct weekly toolbox safety meetings.
Implement a six foot fall protection rule.
Conduct site audits and daily site walk through.
Encourage industrial hygiene surveys for inhalation hazards (e.g., silica) and noise.
Minutes of toolbox meeting will be used to track and document attendance
Site safety personnel will conduct daily, weekly and monthly audits to ensure that the most common hazards are addressed.
Review six foot fall protection requirements with all workers on site and document training on the site orientation forms
Monitor silica and noise exposure levels where appropriate
OSHA representatives will be present for quarterly site safety audits and to meet with the safety and health committee on site.
OSHA log 300 will be used to track the number of work-related injuries and illnesses.
Near miss tracking forms will be utilized to track near misses on the site.
Injuries, illnesses and near misses will be categorized based on type of hazard and trends will be analyzed in the annual review.
One hundred percent (100%) of contractors and subcontractors will be required to have site-specific comprehensive written safety and health programs. Written safety and health programs will be required for all contractors, subcontractors and tier-subcontractors. AECOM will require, review and maintain copies of all contractors', subcontractors', and tier-subcontractors' safety and health programs, and will ensure that 100% of contractors and subcontractors have effective SHMS. Develop and implement a program to support employees working to obtain the Safety Trained Supervisor (STS) certification through the Board of Certified Safety Professionals (BCSP). AECOM will provide study material and assistance to employees interested in taking the certification exam to earn the STS designation. AECOM will track the number of employees who take the exam for the STS designation and the number of employees who pass the exam and obtain their certification. Support OSHA's stand-down initiatives to further the industry's awareness of fall and trenching/excavations hazards in the workplace. AECOM and all on-site contractors will participate in OSHA's annual National stand- down to prevent falls and Trenching/Excavation hazards in construction event until the project is completed. AECOM and all on-site contractors will print and display OSHA's National safety stand-down information in locations where employees are working and inside their on-site trailers. AECOM, along with their contractors will use OSHA's "Join the National Safety Stand-Down" webpages to sign-up for the events, provide information about their stand down activity and complete the survey.
In addition, AECOM, along with their contractors will provide the Madison Area Office the number of employees that were participants, with the goal being 95% participation with all employees on site.
SAFETY AND HEALTH MANAGEMENT SYSTEMS
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. The SHMS will enhance the partnership through collaboration of all parties on site, and increased communication among parties, to impact worker safety and health. Examples of interactions between AECOM and subcontractors through their SHMS will be incorporated in the annual evaluation. This Safety and Health Management System will include but not be limited to the following core elements:
Management Leadership Roles
AECOM 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.
The workers will be encouraged to report job site hazards and bring all potential hazards to the attention of AECOM and/or supervisors if discovered for immediate response and correction. This will be encouraged in the following ways:
- AECOM will hold a Job Site Safety Orientation with each worker prior to work on site.
- AECOM will provide a system to allow workers to report potential job site hazards to AECOM, all other contractors, and/or supervisors upon discovery to stop work if necessary.
- AECOM and all other contractors will require all workers to attend weekly tool box talks.
- AECOM and all other contractors 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.
Hazard Identification and Assessment
This project will focus on safety at all times and AECOM will enforce job site safety compliance to OSHA standards including but not limited the following ways:
- AECOM will conduct daily site inspections and review all subcontractors, workers and site conditions for safe practices.
- AECOM and all other contractors involved will take immediate action to correct any unsafe conditions.
- AECOM will continually monitor all workers, visitors and others entering the work site to ensure safe conditions throughout the worksite.
Hazard Prevention and Control
AECOM 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.
- AECOM will ensure that hazard correction procedures are in place.
- AECOM and all other contractors involved will ensure that everyone knows how to use and maintain personal protective equipment.
- AECOM and all other contractors involved will make sure that everyone understands and follows safe work procedures.
Education and Training
- AECOM and all other contractors involved will ensure only properly authorized and instructed employees are permitted to do any job.
- AECOM and all other contractors involved will ensure workers do not do a job that appears to be unsafe.
- AECOM and all other contractors involved will ensure that supervisors are trained to recognize both health and safety hazards associated with their line of work, and understand their responsibilities.
Program Evaluation and Improvement
AECOM understands that once a safety and health program is established, it should be evaluated to verify that it is being implemented as intended. After that, employers should periodically, and at least annually, step back and assess what is working and what is not, and whether the program is on track to achieve its goals.
- Control measures are periodically evaluated for effectiveness.
- Processes are established to monitor program performance, verify program implementation, and identify program shortcomings and opportunities for improvement.
- Necessary actions are taken to improve the program and overall safety and health performance.
Communication and Coordination for Employers on Multi-employer Worksites
AECOM considers effective communication and coordination among contractors and their workers critical to a safe workplace.
- General contractors, contractors, and staffing agencies commit to providing the same level of safety and health protection to all employees.
- General contractors, contractors, subcontractors, and staffing agencies communicate the hazards present at the worksite and the hazards that contract workers may create on site.
- General contractors establish specifications and qualifications for contractors and staffing agencies.
- Prior to beginning work, general contractors, contractors, and staffing agencies coordinate on work planning and scheduling to identify and resolve any conflicts that could impact safety or health.
- AECOM and all other contractors involved will ensure workers and/or their representatives are involved with daily and monthly site inspections.
- AECOM and all other contractors involved will ensure workers and/or their representatives participate in monthly safety and health committee meetings, as well as report any near miss or unsafe conditions.
- AECOM and all other contractors involved will provide support to all workers and/or their representatives by providing feedback on risks and assisting them in eliminating hazards.
Performance measures as outlined in Section III will be used to assess the effectiveness of the Partnership. AECOM will collect and track data for the performance measures and share the information with OSHA and other partners. Specific measures will include: TCIR and DART rate evaluations; numbers of employees trained; numbers of safety suggestions, hazards corrected, and complaints resolved; number of weekly and monthly safety and health audits conducted; number of subcontractor SHMSs programs evaluated; number of employees taking the STS exam; number of employees passing the STS exam; and, the number of employees participating in the annual Stand Down events.
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 AECOM, in conjunction with other contractors on site, to collect required data to evaluate and track the overall results and successes of the Partnership program. This data will be shared with OSHA. The data may also be shared with other partners as necessary.
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/National 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. In the case that an enforcement activity is not generated during a calendar year, a verification inspection will be conducted to ensure that the partnership and SHMS are being effectively implemented.
All contractors on site will remain subject to OSHA inspections and investigations in accordance with agency procedures.
OSHA's Field Operations Manual details opportunities available during citation/case settlement for all employers who undergo onsite enforcement inspections. These opportunities are also available for partnering companies participating in OSHA's Strategic Partnership Program.
OSP MANAGEMENT AND OPERATION
AECOM in association with other contractors on site, the U.S. Department of Labor/Occupational Safety and Health Administration - Madison Area Office, the Wisconsin Onsite Consultation Program and all listed trades will form a partnership committee to monitor the implementation of this Agreement. It will consist of a representative from each of the designated partners. AECOM 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.
AECOM, in conjunction with all other contractors onsite, will:
- Implement their company's comprehensive safety and health management programs, which includes:
- Management leadership
- Employee involvement
- Hazard identification and assessment
- Hazard prevention and control
- Education and training
- Program evaluation and improvement
- Communication and coordination for Partnership Members, contractors and staffing agencies
- 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 to request assistance.
- Enforce 100% fall protection for all fall hazards over six (6) feet, including steel erection activities.
- 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 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. AECOM and all other contractors involved will document the corrective action taken, and share this information during the monthly update meetings. All of the information documented and collected during these monthly audits will be shared with the Madison OSHA Area Office.
- Allow OSHA access to the site during inspection activities (programmed and un-programmed activities such as fatalities, referrals, and employee complaints).
- Audit the partnership and make recommendations for improvement.
- Share and make available to all workers, job-site inspections and investigation of near-misses and incidents.
- Require the use of appropriate personal protective equipment by everyone 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.
- Participate in the Safety and Health Committee meetings and the monthly site audit inspections.
- Designate a Madison 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 AECOM safety and health self-audits.
Wisconsin Onsite Consultation will:
- Participate in the Safety and Health Committee meetings and the monthly site audits.
- Designate an On-Site Consultation staff member (or members) to serve as a resource for technical issues, and that will be available, upon request and with at least five business days of advance notice, to assist with safety and health training/tool box meetings.
- Provide on-site consultation services upon request to assist contractors with implementation of safety and health management systems.
- Provide on-site consultation services upon request to assist contractors with industrial hygiene surveys.
Southern Wisconsin Building and Construction Trades Council will:
- Appoint a representative to the Safety and Health Committee.
- Represent all trades affiliated with the work trade scopes of this project.
- Assist in trade jurisdiction and work requirements and offer additional OSHA certified safety training to their respective members.
- Assist in planning and implementation of all safety and health management systems.
- Implement their company's comprehensive safety and health management programs, which includes:
WORKER AND EMPLOYER RIGHTS
This partnership does not preclude workers and/or employers from exercising any rights 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.
This agreement will terminate on November 1, 2019, 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.
Based upon a mutual interest to protect construction workers, the parties below agree to the above terms on the Riverside Energy Center Partnering Agreement for the Power Plant Project in Beloit, Wisconsin.
Signed this ____th day of ___________, 2018
Chad Greenwood, Acting Area Director
OSHA - Madison Area Office
Steve Strebel, Director
Wisconsin Onsite Consultation Program
Rob Potter, Executive Director
Southern Wisconsin Building and Construction Trades Council