Question: What date should we use for the conclusion of an Alliance that has gone beyond its renewal due date?

Answer:

Please use the date that the conclusion letter was mailed to the Alliance participants. Do not use the renewal due date (or "expiration date") as the conclusion date unless the letter was mailed on that date.

Question: How long is a renewal period?

Answer:

Renewals can be for two to five years, based on the activity and impact of the Alliance. Alliances are evaluated annually to determine if they are meeting the goals in the agreement and work plan. Alliances that are not meeting these goals should be concluded early or put on a plan to improve performance. In addition, Alliances cannot be renewed automatically.

Initial Alliance signings are for two years.

Question: Our Alliance has gone past its renewal due date (or "expiration date") but it still active. Can we still renew it?

Answer:

Yes, If an active Alliance has gone beyond its renewal period, it can still be renewed. It is not necessary to conclude the Alliance and sign a new one. Please use the date the new agreement is signed as the renewal date. Do not use the previous Alliance renewal due date (or "expiration date"). For renewal agreements signed by mail, see Signing by Mail.

Question: We recently renewed an Alliance for two years and the new Directive allows for a five year renewal period. Can we extend the renewal period to five years without going through the renewal process again?

Answer:

No, When the Alliance comes up for renewal at the end of the two-year period, it may be renewed for up to five years.

Question: Can we add signatories to an Alliance agreement without signing a new agreement?

Answer:

Yes, in some cases you may be able to sign an addendum to add a new signatory. Please contact the Office of Outreach Services and Alliances at (202) 693-2340 for more information.

Question: Can OSHA sign an Alliance with another federal agency?

Answer:

Yes. However, there may be situations where a Memorandum of Agreement would be more appropriate than an Alliance. Check with your Solicitor’s Office for more guidance.

Question: How does the worker involvement requirement apply to Alliances with community or technical colleges?

Answer:

The target audience for these Alliances is the student/worker. To meet the worker involvement requirement in this context, Alliance participants can gather feedback on the courses from the students, or if applicable, have student representation at Alliance implementation meetings. The feedback can be collected immediately after the course and/or several months after course completion to determine whether students were able to apply what they learned during the course. This feedback may also be used to determine future Alliance activities.

Question: How should worker involvement be achieved for new and existing Alliances?

Answer:

Alliances are intended to provide a forum for employers and workers to work together to resolve workplace safety and health issues. To achieve this, Alliances with employers and employer groups (e.g., trade associations) must also include worker representatives to ensure that their activities sufficiently address the safety and health needs/issues faced by the target audience (in most cases, workers).

The directive states that worker involvement can be accomplished by:

• Having a union signatory whenever possible (e.g., from a union with a presence and/or experience in the industry); or
• Having worker involvement in the Alliance agreement's development and implementation, including project workgroups; or
• Having participation in the Alliance of community-based labor groups or similar organizations knowledgeable and involved in the issues addressed by the Alliance.

Other examples of worker involvement include:

• Inviting union representatives, or community- and faith-based labor groups, to implementation meetings.
• Requesting union, or community- and faith-based labor groups, review of products/topics in development.
• Surveying the target audience (e.g., students, workers, union representatives) to identify gaps in existing training or educational resources that could be addressed by the Alliance, and/or to ascertain the effectiveness of the Alliance’s products/activities (e.g., trainings, publications, outreach campaigns, etc.)
• Obtaining input and feedback from consulates (in cases where workers are predominantly from other countries).
• Including OSHA compliance assistance staff in implementation team meetings. This may include a representative from the OSHA National Office.

Question: Will there be an update on discussions from the July 17th stakeholder meeting in Washington, DC?

Answer:

Yes. There will be a review of the July 17, 2017 meeting along with comments and suggestions from the public on potential avenues for action.

Question: How do I submit my comments to the docket?

Answer:

A new docket, "VPP Sustainability" has been created for the stakeholder meetings. The Docket Identification Number is OSHA-2017-0009. To comment on OSHA's VPP programs, go to the VPP Sustainability Docket. Please submit comments prior to the close of business on September 15, 2017.