| 1. Management
Leadership |
| Element |
Stage I |
Stage II |
Stage III |
| 1.1 Management Commitment |
| Vision and Policy Statements |
-Develop, issue, and communicate S&H Vision Statement
and S&H Policy Statement. |
-Communicate Vision and Policy Statements to all
company and subcontractor employees; incorporate into new employee/subcontractor orientation.
-Include the vision and policy in bid packages. |
-Take proactive steps to ensure company and
subcontractor employees understand the S&H Vision and Policy Statements.
-Ensure policies becomes an integral part of routine activities and decision making during all
phases of construction |
| Leadership |
-Establish a policy requiring company and
subcontractor, if applicable, executives, managers, and supervisors to participate and demonstrate
leadership in S&H activities |
-Continue participation by top executives and
managers.
-Require subcontractors to adopt and begin implementing leadership policies and increase frequency
of management participation in S&H activities. |
-Continue to ensure total involvement in S&H of all
company and subcontractor senior management, supervisors and lead persons. |
| Resources |
-Develop safety and health budget and commit and
ensure utilization of adequate resources.
-Establish and implement a policy that integrates S&H into the overall company management planning
and budgeting process. |
-Provide additional resources for S&H activities,
including access to certified S&H professionals, if necessary, and licensed health care
professionals, and improve integration of S&H into other planning activities. |
-Continue committing and ensuring the utilization of
adequate resources by company and subcontractors.
-Ensure integration of S&H in all company and subcontractor planning and budget processes in the
company. |
| Goals and Objectives |
-Set and communicate annual S&H goals and objectives
based on findings from baseline hazard and trend analyses, and S&H perception survey results. |
-Review progress towards achievement of S&H goals &
objectives; establish & communicate new goals, as appropriate.
-Require subcontractors to develop goals and objectives consistent with Challenge participation. |
-Company and subcontractors review, revise, and
communicate S&H goals and objectives
-Ensure S&H goals and objectives are routinely considered in company’s and subcontractor’s
activities and programs. |
| Communication |
-Establish clear lines of communication throughout
all aspects of company operations.
-Provide reasonable access to senior management on S&H issues. |
-Maintain clear lines of communication with company
and subcontractor employees re: S&H issues |
-Continue open dialogue between company and
subcontractor management staff and employees. |
| Roles, Responsibilities, Authorities, and
Accountability |
-Develop a S&H accountability plan for
managers/supervisors and non-supervisory employees. |
-Communicate and implement accountability plan.
-Assign additional responsibilities to non-supervisory employees as appropriate.
-Encourage subcontractors to adopt and begin implementing similar accountability plan or establish
equivalent process. |
-Fully implement accountability system for all
company and subcontractor workers, including incorporating S&H responsibilities into job
descriptions and performance plans.
-Begin measuring performance of S&H responsibilities in annual performance appraisal processes |
| Discipline |
-Establish a company disciplinary policy for all
employees re: compliance with S&H regulation, rules, procedures, etc. |
-Continue to implement disciplinary plan with an
implementation schedule for managers and employees.
-Require subcontractors, if applicable, to adopt company disciplinary policy or establish
equivalent policies. |
-Ensure discipline is equally enforced for company
and subcontractor employees. |
Annual Self-
Evaluation |
No action required. |
-Develop a written plan/procedure for conducting
annual self evaluations and other evaluations, including a requirement for narrative reports.
-Encourage subcontractors to adopt a similar policy or establish an equivalent process. |
-Company and subcontractors implement systems and
written procedures to annually evaluate the S&H management systems.
-Company and subcontractors complete at least one annual self-evaluation of the S&H management
system.
-Complete an evaluation prior to completion of construction. |
| 1.2 Employee Involvement |
| S&H Perception Survey |
Conduct S&H Perception Survey for employees and
subcontractor employees, if applicable. |
-Review and respond to survey findings and
conclusions. |
-Conduct follow-up S&H Perception Survey to identify
further needed improvements. |
| S&H Perception Survey Change Plan |
-Develop an action plan to address findings from the
S&H Perception Survey. |
-Implement steps defined in the company’s action plan
to improve S&H culture.
-Require subcontractors to develop action plan to address findings related to them. |
-Continue implementing action plan |
| Employee Notification |
-Notify all employees of their S&H rights under the
OSH Act and inform them of the company’s participation in Challenge program. Discuss the VPP
principles.
-Encourage the reporting of hazardous conditions |
-Notify new employees of their S&H rights, company
participation in Challenge, & VPP principles.
-Incorporate into new employee/subcontractor orientation.
-Require the reporting of hazards. |
-Inform all employees annually of worker rights and
include elements in company/project site orientation for new company and subcontractor employees.
-Reinforce as appropriate. |
| Employee Involvement |
-Develop a plan and implementation schedule for
involving employees in developing a company safety
and health program (e.g. S&H teams) and begin involving employees in S&H activities (e.g. safety
audits) |
-Increase participation on teams, and/or form
additional teams.
-Involve employees in S&H activities (e.g., accident/near-miss investigations).
-Require subcontractors to adopt and begin implementing company policy, participate in company
activities, or equivalent processes. |
-All teams are functioning and meaningfully
contributing to S&H.
-Ensure teams are routinely conducting audits, accident/incident investigations, self-
inspections, and job hazard analyses.
-Utilize team input to improve and continue the company’s hazard reporting system.
-Encourage more active and open subcontractor participation. |
| 1.3 Contract Worker Coverage |
| Equal S&H Protection |
-Develop and begin implementing a plan for how
subcontractors will provide their employees with equal S&H protection |
-Work with subcontractor to improve and continue
implementing subcontractor program. |
-Work with subcontractor to improve and continue
implementing subcontractor program |
| Adherence to Rules |
-Require subcontractors and their employees to comply
with OSHA and company S&H rules. Inform all subcontractor employees of this requirement before
work begins. |
-Develop a system to handle S&H violations of
subcontractor employees working on-site. |
-Improve and continue to enforce company policy for
S&H violations. |
| Subcontractor Hazard Correction |
-Establish a requirement that subcontractors promptly
correct hazards involving their work activities. |
-Formalize and begin implementing methods to
ensure that hazards are identified, corrected, &
tracked in subcontractors’ work areas including
assignment of responsibility. |
-Ensure subcontractors effectively implement systems
to identify and correct hazards in their work areas and include responsibility for hazard
correction in writing. |
Subcontractor
Selection |
-Require in bid documents to include subcontractor
injury and illness records for past three years (if available), and copies of their written S&H
program.
-Consider the above information in when selecting subcontractors for work. |
-Implement policy and process for addressing S&H
performance of potential bidders. |
-Continue to encourage and reinforce the importance
for subcontractors to develop and implement good effective S&H management systems. |
| Removal Policy |
No action required. |
-Establish and communicate a formal policy on
subcontractor S&H violations, including removal and possible financial penalties.
-Include policy in the company contract requirements. |
-Hold subcontractors responsible for correcting
hazards created by their work and ensure any penalty policies are understood by all subcontractors
and tier contractors described in their contracts. |
|
2. Worksite Analysis |
| Element |
Stage I |
Stage II |
Stage III |
| Baseline Safety and Health Hazard Analysis,
including Industrial Hygiene (IH) Surveys |
-Conduct a S&H baseline analysis including a review
of previous accidents, injuries, and illnesses; complaints; previous studies; etc. |
-Require subcontractors to perform baseline analysis
as necessary in accordance with OSHA and company requirements and share pertinent information with
the general contractor, or other subcontractors. |
-Repeat baseline surveys, if warranted, by
significant changes in tasks, equipment, or processes. |
| Hazard Analysis of Routine Jobs, Tasks, and
Processes |
-Review routine tasks to ensure compliance with
local, state, and Federal safety and health regulations
-Begin to formalize system to ensure employees are properly trained on routine jobs, tasks, and
processes |
-Conduct hazard analysis for work and recommend
controls for routine jobs, tasks, & processes that have potential to cause an injuries/illnesses
or significant incidents; are perceived as high-hazard; or are required by a regulation or
standard.
-Update the company hazard analysis, as appropriate.
-Require subcontractors to adopt and implement hazard analysis of routine work tasks. |
-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
-Ensure subcontractors continue implementing similar processes. |
| Hazard Analysis of Significant Changes |
-Establish and begin implementing systems for
identification and documentation of S&H hazards of significant changes, new processes, and changes
in design/engineering plans.
-Require subcontractors, if applicable, to adopt and begin implement similar systems. |
-Continue conducting hazard analysis for significant
changes (e.g., non-routine tasks or new processes, materials, equipment and facilities/project
site) and recommend controls prior to the activity or use per company requirements and OSHA
standards.
-Subcontractors implement a policy and begin identify and document hazards of significant changes. |
-Continue conducting and documenting hazard analysis
for significant changes (e.g., non-routine tasks or new processes, materials, equipment and
facilities/project sites) and recommend controls prior to the activity or use. |
| Pre-use Analysis |
-Establish and begin implementing a pre-use analysis
of new equipment, chemicals, facilities/project sites, or significantly different operations or
procedures and recommend controls prior to the activity or use.
-Require subcontractors to develop and implement similar systems. |
-Continue conducting pre-use analysis of new
equipment, chemicals, facilities/project sites, or significantly different operations or
procedures and recommend controls prior to the activity or use.
-Subcontractors begin performing pre-task analysis of work they are contracted to perform. |
-Continue pre-task hazard analysis of new equipment,
chemicals, facilities/project sites, or significantly different operations or procedures and
recommend controls prior to the activity or use. |
| Industrial Hygiene (IH) Program |
No action required. |
-Establish, document, & implement future sampling
schedule, strategy, and rationale, e.g., develop a formal written IH program.
-Follow-up on results of baseline IH study.
-Conduct more in-depth analysis if warranted to determine actual employee exposures.
-Require subcontractors to participate in the company IH program where necessary.
-Follow-up on results of subcontractor baseline IH study, if applicable, and conduct more in-depth
analysis, if warranted. |
-Continue implementing the written IH programs taking
proactive steps to improve control of health hazards to prevent occupational disease. |
Routine
Self-inspections |
-Establish a routine self-inspection program that
ensures S&H inspections are performed as often as necessary
-Train company employees in the recognition and avoidance of hazards in their work area |
-Develop a system for scheduling routine
self-inspections of the workplace; conduct inspections with S&H staff. The entire site must be
self-inspected as often as necessary, but never less than weekly.
-Require subcontractors to adopt similar policies. |
-Conduct routine self-inspections covering entire
worksite as often as necessary, but at least weekly.
-Ensure subcontractor processes implement similar self-inspection processes. |
| Hazard Reporting System for Employees |
-Use data collected from accident incident reports
and other sources to determine areas to concentrate on
-Obtain supervisor and employee input for suggested plan of action in developing a hazard
reporting system |
-Develop & begin implementing hazard-reporting system
for employees (maybe anonymous), requiring timely responses back to employees.
-Require subcontractors to participate in the company process or establish equivalent processes. |
-Continue implementing hazard reporting systems and
encouraging more active reporting by both company and subcontractor employees; ensure timely
investigations of the hazard reported, ensure regular feedback, using different media, to all
employees on status of hazards reported. |
| Investigation of Accidents and Near-Misses |
-Develop and implement requirements to report and
investigate incidents/accidents.
-Investigate accidents and prepare and maintain written reports of investigations.
-Involve employees in the investigations.
-Require subcontractors, if applicable, to adopt and begin implementing similar systems. |
-Company and subcontractors expand investigation
activities to include near misses and make findings available to employees. |
-Continue reporting and investigating
accidents/incidents and near-misses. |
| Trend Analysis |
-Conduct initial trend analysis of 3 previous years’
injury & illness rates 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.
-Require subcontractors to develop and implement similar systems. |
-Conducts trend analysis regularly (at least
annually) of company and subcontractor S&H information and use results in setting future goals to
address trends. |
|
3. Hazard Prevention & Control |
| Element |
Stage I |
Stage II |
Stage III |
| Certified Professional Resources |
-Ensure outside sources are available in needed to
conduct baseline hazard analysis. |
-Ensure adequate resources (e.g., access to certified
S&H professionals, licensed health care professionals)
-Subcontractors ensure adequate resources, as well |
-Continue to provide necessary resources (e.g.,
Certified Safety Professionals, Certified Industrial Hygienists). |
| Hazard Elimination & Control Methods |
-Establish systems to prioritize and implement
controls for identified hazards, through the baseline S&IH study, trend analysis of OSHA logs, and
accident investigations.
-Identify options and selection most appropriate option or combination for hazard elimination and
control
-Require subcontractors to adopt company hazard elimination and control system or implement
equivalent |
-Develop an action plan to prioritize and implement
controls for hazards identified through self-inspections, employee reports of hazards, and
near-Miss investigations.
-Selects most appropriate control methods.
-Implement hazard controls (or interim protection) for top priority hazards before moving onto
Stage III.
-Subcontractors implement equivalent systems for hazard elimination and control methods. |
-Complete long term abatement projects from Stage II.
-Continue to identify, prioritize, and implement control 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
identification and control. |
| Hazard Control Programs |
-Inventory existing hazard control programs required
by OSHA standards. Develop missing programs or modify if necessary.
-Develop appropriate company S&H rules, standards, manuals, etc.
-Require subcontractors, if applicable, to develop and implement similar effective programs. |
-Continue to implement hazard control programs
developed or modified in Stage I and train all workers on these programs.
-Subcontractors implement effective hazard control programs, standards, rules, etc. |
-Continue to maintain hazard control programs
required by OSHA standards, and other rules and regulations.
-Review hazard control programs annually and update them as new processes, jobs, and tasks are
begun. |
| Tracking of Hazard Correction |
-Develop and begin implementing a hazard tracking
system for hazards identified through the baseline hazard analysis, trend analysis of OSHA logs,
and accident investigations.
-Require subcontractors to adopt and implement company tracking system or establish equivalent. |
-Continue implementing and improving tracking system
-Subcontractors implement effective systems to track hazard identified in baseline hazard
analysis, trend analysis, and self-inspections. |
-Company and subcontractor tracking systems are fully
functioning and include hazards identified through all methods.
-Communicate with workers throughout the process on the status of hazards until they are abated. |
| Preventive Maintenance of Equipment |
-Conduct an inventory of equipment and machinery
requiring preventive maintenance (PM).
-Require subcontractors, if applicable, to develop a similar PM program. |
-Review equipment inventory. Establish and implement
a preventive maintenance schedule.
-Subcontractors implement preventive maintenance program to ensure the safe upkeep of equipment
operating the project site. |
-Continue to perform preventive maintenance as
scheduled.
-Schedule is routinely observed and preventive maintenance is regularly conducted.
-Subcontractors have preventive maintenance inventory and schedule and it is being conducted. |
| Occupational Health Care Program |
-Conduct thorough review of injury/illness records.
-Compare with insurance claims loss runs to ensure records are in order.
-Utilize licensed health care professionals if needed.
-Require subcontractors to provide access to health care services based on baseline S&H analysis,
including physician and emergency medical care. |
-Continue to provide access to licensed health care
providers, health services, physician care, and emergency medical care as needed. Arrange for
services based on the outcomes of the baseline S&H analysis.
-Subcontractors determine how licensed health care providers, health services, physician care, and
emergency medical care will be provided for their employees working on-site and communicate this
information to their employees. |
-Continue providing services listed in Stage I and
II.
-Consider seeking health care providers to visit the site/project, and assist in identifying
causes and symptoms of injury/illness.
-Care provided is within the scope of contracts, licensure, and standard operating procedures. |
| Emergency Preparedness and Response |
-Establish and communicate to company and
subcontractor employees written procedures for addressing responses responding to all types of
emergencies.
-Conduct at least one evacuation drill to assess effectiveness of how procedures.
-Make emergency services available on all shifts such as emergency transportation, EMT’s,
emergency clinics, or hospital emergency rooms.
-Ensure at least one employee trained in first aid & CPR for each shift.
-Require subcontractors to adopt the company emergency procedures or equivalent. |
-Continue communicating emergency procedures and
providing emergency medical services.
-Establish an Emergency Response Team including first aid and CPR trained employees and
subcontractors
-Conduct at least one drill with company and subcontractor employees and assess its effectiveness
and follow-up on recommendations to improve emergency evacuation drills. |
-Continue to improve written emergency procedures for
responding to emergencies on all shifts.
-Review results of previous drills and conduct an annual drill.
-Establish one operational emergency response team for each shift.
-Ensure full implementation of site’s emergency preparedness and response plan. |
|
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 principles, hazards in the workplace, PPE, emergency evacuation procedures, and
individual emergency responsibilities.
-Ensure training is recorded.
-Maintain a record of training conducted. |
-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
-Ensure subcontractors are fulfilling their obligations to train their employees to recognize
hazards in the workplace. |
-Continuously improve safety and health training to
workers. |
| 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 provide them with
knowledge & skills needed to perform their S&H responsibilities in (i.e., hazard recognition,
accident investigation and root cause analysis, hazard controls, OSHA standards, and VPP
requirements). |
-Expand specific training to all selected employees,
managers and supervisors, and designated S&H staff.
-Subcontractors provide specialized training to their employees on how to perform their assigned
and contracted work and control/eliminate its hazards. |
-Take proactive steps to provide specific training to
their employees and share the knowledge & skills and lessons learned. |
|
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