1) Background:
In a cooperative effort to foster safe and healthful worksites and meet OSHA’s strategic goal of
improving the safety, health and well-being of the nation’s workforce, the USDOL/OSHA Allentown Area
Office, the PA/OSHA Consultation Program at Indiana University of Pennsylvania, the Lehigh Career &
Technical Institute, and Warehouse, Storage, Distribution and Transportation Industries and their
employees (See Appendix A), located primarily within the Lehigh and Northampton counties of the OSHA
Allentown office’s jurisdiction, agree to establish a partnership program to reduce the number of
injuries and illnesses resulting from events or exposures within the workplace, assure compliance
with the most frequently cited OSHA standards for their industry, and promote the integration of
business with vocational-technical schools.
The primary goal of the partnership is to prevent accidents, injuries, and fatalities resulting from
work activities within the warehousing storage distribution and transportation industry employers
that reside primarily in Lehigh and Northampton counties. In an effort to achieve this goal, this
program is to (1) develop an initiative to improve safety and health performance by reducing the
Total Rate of Days Away from Work or DART rate of participating employers by 4% per year over the
life of the partnership, (2) identify within the participating members worksites, if anything other
than the primary causal factors, contact with objects, over exertions and falls, are contributing to
injuries and illnesses, and if so, develop a strategy to control or eliminate those hazards, (3)
reduce employers’ worker compensation costs (4) aid in the development of a workplace Motor Vehicle
safety program or facilitate in a mentoring process for those who have not yet developed such a
program, (5) promote and encourage employer usage of the PA/OSHA Consultation Program to assist in
workplace hazard recognition, and finally (6) recognize those members with exemplary safety and
health programs.
Over the last several years, the Lehigh Valley has seen tremendous growth in the warehouse, storage,
distribution and transportation industry, and as such this office began reviewing local and national
data to identify what issues, if any, were occurring within this industry. In review of injury and
illness data, the Bureau of Labor Statistics (BLS) has identified several “events” or “exposures”
which were clearly at the forefront: industrial truck incidents, falls to lower levels and on the
same level, overexertion involving ergonomic stressors and hazards primarily attributed to lifting,
and finally transportation accidents.
The goal of this program is to develop an employer/academia/government partnership that will
encourage all members to improve their safety and health performance, assist them in doing that,
strive for the elimination of serious accidents within the industry, and to recognize those
employers with exemplary safety and health programs.
The Partnership will be available, beyond those lead organizations listed above, to any employer
primarily within the OSHA Allentown jurisdiction of Lehigh and Northampton counties (although
interested companies located outside of these counties and who wish to participate are not to be
excluded) and whose SIC Code fall within the major groups of 4200 – Motor Freight, Transportation &
Warehousing, 5000 – Wholesale Trade (Durable Goods), and 5100 – Wholesale (Non-Durable Goods).
(NOTE: Although OSHA does not maintain jurisdiction on over-the-road motor vehicle safety and does
not currently have any standards to address motor vehicular safety/training, this partnership will
attempt to address, to the extent feasible and applicable, this increasing hazard in an educational
and outreach manner. (In review of occupational injury and illness data, research has shown that
within the trucking and warehousing industry, transportation accidents are the second leading cause
of nonfatal occupational injuries involving days away from work))
This Partnership is consistent with OSHA’s long-range efforts to develop a business, labor, and
government partnership approach to safety management. It will enable OSHA to leverage its resources
more efficiently in promoting safety and health through a cooperative effort involving the
participating employers and consultation services, by sharing their experiences and successes.
Additionally, this Partnership will have an increased impact on the partners by reaching a greater
number of employers and employees and should achieve improved worker protection through a reduction
of job related injuries and illnesses sooner than by traditional means.
2) Identification of Partners:
- The U.S. Dept. of Labor - Occupational Safety and Health Administration - Allentown Area Office;
- Lehigh Career & Technical Institute – Materials Logistics Department;
- Warehouse, Storage Distribution and Transportation employers and their employees (see Appendix A
for members);
- PA/OSHA Consultation Program at Indiana University of Pennsylvania.
3) Goals and Measurements:
- Reduce the number of injuries, accidents and near misses resulting from “contacts with objects”
(hazards associated with unsafe operation of powered industrial trucks), from “overexertion”
(hazards associated with ergonomic issues, including unsafe lifting activities), and from “falls”
(same level falls and fall hazards to a lower level) by 4% a year, within this industry group.
This goal will be measured by the collection and annual analysis of OSHA injury & illness records
(OSHA 300 logs) and total hours worked, so that the DART rate of participating members can be
calculated.
- Reduce participating Partnership members Workers Compensation costs.
This goal will be measured by the review of employer’s worker compensation data.
- Develop a system for the early identification and correction of the focused hazards, which have
resulted in serious injuries and fatalities within these industries.
This goal will be measured by the development and implementation of a hazard identification
checklist, Job Safety Analysis (JSA’s), Standard Operating Procedures (SOP’s), etc., specifically
focused on those hazards within this industry group.
- Reduce the number of serious hazards within this industry group.
This goal will be measured by the employers abatement of hazards identified through
self-administered hazard identification checklists, JSA’s, SOP’s, etc., as noted in item no. 3 and
through tabulation of OSHA inspection data, OSHA interventions, as well as any workplace
recommendations that are made during OSHA inspections within this industry group.
- Develop and implement an effective comprehensive safety and health program specific to the
warehouse, storage and distribution industry and in accordance with the Safety
and Health Program Management Guidelines, issued on January 26, 1989.
This goal will be measured by the number of new or modified safety and health programs that are
developed, which incorporate the key elements as listed in Section 4.a.1.of this agreement.
- Provide safety and health training and technical assistance on existing and new OSHA regulations,
focusing on the primary cause(s) of injuries within the industry.
This goal will be measured by the number of presentations, speeches or training sessions provided to
the partnering members. Information such as the topics, the number of attendees and the number of
affected employees will also be gathered for tracking this goal.
- Improve the site’s safety and health program to become qualified and eligible to participate in
the Safety and Health Achievement Recognition Program (SHARP) of the PA/OSHA Consultation Program at
IUP and/or OSHA’s Voluntary Protection Program (VPP). For companies not yet eligible for either of
these programs a “Jump Start Mentoring Program” may be established, by facilitating the assignment
of mentors or through additional outreach and communications with OSHA and/or PA/OSHA Consultation.
The elements of such a “Program” would be defined and agreed upon by OSHA, PA/OSHA Consultation and
any interested members of this partnership.
This goal will be measured by the implementation or enhancement of programs, as identified by the
PA/OSHA Consultation Program (NOTE: Due to the confidentiality of the PA/OSHA Consultative service
this information will be provided by IUP as blanket statements that conditions (if any) have been
noted, and they’ve been adequately abated by the employer in accordance with specified time frames),
and the number of companies requesting an on-site consultation visit, number of companies receiving
a full service visit, and the number of companies applying for participation in the Deferral Program
or Safety and Health Achievement Recognition Program (SHARP) of the PA/OSHA Consultation Program at
IUP and/or this goal will be measured by the number of application requests received by OSHA for
participation in OSHA’s Voluntary Protection Program (VPP).
- To provide assistance and promote resources that will address the needs of non-English speaking
and other hard-to-reach employees, where appropriate.
This goal will be measured by the number of requests for non-English speaking resources. Resources
may include the videos, pamphlets, and technical assistance.
4) Employer’s Commitment/Role:
- Develop, implement and communicate an effective comprehensive safety and health program specific
to the warehouse, storage and distribution industry and in accordance with the Safety
and Health Program Management Guidelines, issued on January 26, 1989s.
- Employers agree to adopt and implement an effective overall safety and health program, which
shall include the following elements:
- Management Leadership
- Employee Participation
- Identification of Hazards through Worksite Inspections
- Hazard Prevention and Control
- Employee and Supervisory Training
- Enforcement of the Safety Program
An assessment of the safety and health program will be conducted, and this may be accomplished by
utilization of such tools as the Occupational Safety and Health Program Assessment Profile (Appendix
B) or the Safety and Health Program Assessment Worksheet (Appendix C) or any equivalent form. These
forms may be used in lieu of, not in addition to, the Safety and Health Program Management
Guidelines, issued on January 26, 1989. See Appendices B&C, respectively, for the forms.
- Provide annual updates of injury and illness information to OSHA for use in the evaluation of the
effectiveness of the partnership. Each individual employer may choose to substitute the OSHA 300
form for other forms of information, which conveys the same information.
- Reduce the number of injuries, accidents and near misses resulting from “contacts with objects”
(hazards associated with unsafe operation of powered industrial trucks), from “overexertion”
(hazards associated with ergonomic issues, including unsafe lifting activities), and from “falls”
(same level falls and fall hazards to a lower level.
- Develop a system for the early identification and correction of the focused hazards (contacts
with objects, overexertion, and falls) which has resulted in serious injuries and fatalities within
their workplace.
- Unless obtained during an OSHA inspection, any site-specific information provided to OSHA, by any
of the participating employers of this Partnership shall be considered privileged, confidential, and
protected from disclosure to outsiders, to the extent allowed by law, other than as necessary to
accumulate industry-wide data, and shall not be relied on by OSHA to prove the existence of a
citable violation of OSHA standards or the Section 5(a)(1) (General Duty Clause) of the OSH Act.
5) Employee Rights: This partnership does not preclude employees and/or
employers from exercising any right provided under the OSH Act, nor does it abrogate any responsibility
to comply with rules and regulations adopted pursuant to the Act.
6) Lehigh Career & Technical Institute’s Commitment/Role:
- LCTI will provide safety and health technical assistance in the area of forklift safety, through
instruction and assistance in the development of electronic training tools.
- LCTI agrees to occasionally facilitate, broker and/or host technical safety and health meetings
and training sessions at their site, if space is available and there are no conflicts with school
activities.
7) PA/OSHA Consultation Program Commitment/Role:
- The PA/OSHA Consultation Program will give participating employers a high priority for scheduling
on-site consultation visits. They will also provide the employer with a report summarizing their
findings and will assess the impact on workplace safety and health.
- The PA/OSHA Consultation Program will provide resources to assist in the training and education
of participating employers and their employees.
8) OSHA’s Commitment/Role:
- Establish a mentoring program for those sites interested in participating in the OSHA/ PA/OSHA
Consultation Program Deferral Program, Safety and Health Achievement Recognition Program (SHARP) of
the PA/OSHA Consultation Program at IUP and/or OSHA’s Voluntary Protection Program (VPP), which
along with other incentives provides exemptions from routine program-planned OSHA inspections.
- Help identify (offsite), through the collection of OSHA300 data or site accident reports, the
primary causal factors in injuries and illnesses, in particular the top hazards within this
industrial group and develop feasible and useful countermeasures for correcting those hazards.
Individual employers are not required, by virtue of this Agreement, to adopt or implement such
countermeasures.
- Provide information on training resources including attendance at available OSHA Training
Institute courses, offered locally, and information on other available sources of training.
- Provide interpretation or clarification as to the meaning and application of OSHA standards and
policy, as they apply to utilities and their contractors.
- As resources permit, participate in training sessions and meetings at the request of the
employer.
- Designate in the Area Office an experienced safety and health specialist to serve as a resource
and liaison for partnership participants.
9) Evaluation/Verification: An evaluation of the partnership will be prepared annually by OSHA using
the format in Appendix D. The evaluation will review the success of the partnership, lessons
learned, and changes that will be made to meet the goals of the partnership.
10) Rights of the Parties and Employees: All partners remain subject to normal OSHA inspection
procedures. The provisions of this agreement identified herein, shall not modify any legal or
contractual rights and remedies. OSHA’s Partnerships provide groups of employers, employees and
employee representatives, an opportunity to participate into an extended, voluntary, cooperative
relationship with OSHA in order to encourage, assist, and recognize their efforts to eliminate
serious hazards and achieve a high level of worker safety and health. Partnerships have proved to be
valuable tools for both OSHA and its participants. By entering into a Partnership with a party, OSHA
is not endorsing any of that party’s products or services; nor does the Agency enter into a
Partnership with the purpose of promoting a particular party’s products or services.
Participation in this Partnership does not obligate an employer to implement any work practice,
install or modify any equipment, or hire any individual as an employee or consultant. Actions taken
by an employer in respect to its local workplace and operations, in furtherance of its participation
in this Partnership, shall not necessarily be binding on or required by that employer in respect to
workplaces and/or operations maintained elsewhere by that employer.
11) Termination: This agreement will terminate on May 25, 2008 which is three (3) years from the
date of signing. If any signatory of this agreement wishes to terminate their participation prior to
the established termination date, written notice of the intent to withdraw must be provided to all
other signatories.
If OSHA chooses to withdraw its participation in the partnership, the entire agreement is
terminated. Any signatory may also propose modification or amendment of the agreement.
Jean G. Kulp
Area Director
USDOL/OSHA - Allentown |
Date |
Dr. Clyde Hornberger
Executive Director
Lehigh Career & Technical Institute |
Date |
John M. Engler, Project Mgr
PA/OSHA Consultation Program
Indiana University of Pennsylvania |
Date |
David Rubright
Adult Education Instructor
Lehigh Career & Technical Institute |
Date |
David Cardell
Material Handling Logistics Instructor
Lehigh Career and Technical Institute |
Date |
Don Boyajian
Walgreen Company
125 N. Commerce Way, Bethlehem, PA |
Date |
Bill Guffy
Americold Logistics
651 Mill Road, Fogelsville, PA |
Date |
Mark Reardon
Bridgestone/Firestone Company
8001 Industrial Blvd. Allentown, PA |
Date |
John Zagiel
Overnite Transportation
342 Stokes Park Rd., Bethlehem, PA |
Date |
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Employer |
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Employer |
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Appendix A – Participating Members |
- USDOL/OSHA – Allentown Area Office
- Lehigh Career & Technical Institute, Schnecksville, PA 18078
- PA/OSHA Consultation Program at Indiana University of Pennsylvania
- Walgreens Co. – 125 N. Commerce Way, Bethlehem, PA 18017
- Americold Logistics – 651 Mill Road, Fogelsville, PA 18051
- Bridgestone Firestone Northeast Dist. Ctr. – 8001 Industrial Blvd. Allentown, PA 18106
- Overnite Transportation – 342 Stokes Park Road, Bethlehem, PA 18017
Appendix B
Occupational Safety and Health Program
Assessment Profile |
Each of the elements and factors of the Profile may be scored from 1 to 5, indicating the level of
the safety and health program, as follows:
Overall Score |
Level of Safety and Health Program |
5 |
Outstanding program |
4 |
Superior program |
3 |
Basic program |
2 |
Developmental program |
1 |
No program or ineffective program |
Scoring. Score the establishment on each of the factors and elements after obtaining the necessary
information to do so. These shall be given a score of 1, 2, 3, 4, or 5.
- Refer to the Tables, below, as appropriate, to ensure that the score given to a factor corresponds
to the descriptor that best fits the worksite. Determine scores for each of the six elements as
follows:
- The score for the Management Leadership and Employee Participation
element shall be whichever is the lowest of the following:
- The score for the "Management Leadership" factor, or
- The score for the "Employee Participation" factor, or
- The average score for all four factors.
- For the sixth element, Training, just determine the level 1-5 that best fits the worksite and note
it in the appropriate box.
- For each of the other four elements, average the scores for the factors.
- If the element or factor does not apply to the worksite being inspected, a notation of "Not
Applicable" shall be made in the space provided. This shall be represented by "N/A".
This shall not affect the score.
Overall Score. An "Overall Score" for the worksite will be the
average of the six individual scores for elements, rounded to the nearest
whole number (1, 2, 3, 4, or 5). Round up from one-half (.5) or greater; round down from less than
one-half (.5).
EXAMPLE:
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2.5 + 2.7 + 2.3 + 3.0 + 2.3 + 2.0 = |
14.8/6 |
= |
2.467 |
= |
2
Profile Score |
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Tables |
- The text in each block provides a description of the program element or factor that corresponds to
the level of program that the employer has implemented in the workplace.
- To avoid duplicative language, each level should be understood as containing all positive factors
included in the level below it. Similarly, each element score should be understood as containing all
positive factors of the element scores below it. That is, a 3 is at least as good as a 2; a 4 is at
least as good as a 3, and so on.
- The descriptors are intended as brief illustrations of a workplace at a particular level. In
exercising their professional judgment, compliance officers should proceed with the understanding
that the descriptor that "best fits" will not necessarily match the workplace exactly or in literal
detail.
MANAGEMENT LEADERSHIP and EMPLOYEE
PARTICIPATION |
Management Leadership |
Visible management leadership provides the motivating
force for an effective safety and health program. [1989
Voluntary Safety and Health Program Management Guidelines, (b)(1) and (c)(1)] |
1 |
Management demonstrates no policy, goals, objectives, or interest
in safety and health issues at this worksite. |
2 |
Management sets and communicates safety and health policy and
goals, but remains detached from all other safety and health efforts. |
3 |
Management follows all safety and health rules, and gives visible
support to the safety and health efforts of others. |
4 |
Management participates in significant aspects of the site's
safety and health program, such as site inspections, incident reviews, and program reviews.
Incentive programs that discourage reporting of accidents, symptoms, injuries, or hazards are
absent. Other incentive programs may be present. |
5 |
Site safety and health issues are regularly included on agendas of
management operations meetings. Management clearly demonstrates--by involvement, support, and
example--the primary importance of safety and health for everyone on the worksite. Performance is
consistent and sustained or has improved over time. |
MANAGEMENT LEADERSHIP and EMPLOYEE
PARTICIPATION |
Employee Participation |
Employee participation provides the means through
which workers identify hazards, recommend and monitor abatement, and otherwise participate in
their own protection. [Guidelines, (b)(1) and (c)(1)] |
1 |
Worker participation in workplace safety and health concerns is
not encouraged. Incentive programs are present which have the effect of discouraging reporting of
incidents, injuries, potential hazards or symptoms. Employees/employee representatives are not
involved in the safety and health program. |
2 |
Workers and their representatives can participate freely in safety
and health activities at the worksite without fear of reprisal. Procedures are in place for
communication between employer and workers on safety and health matters. Worker rights under the
Occupational Safety and Health Act to refuse or stop work that they reasonably believe involves
imminent danger are understood by workers and honored by management. Workers are paid while
performing safety activities. |
3 |
Workers and their representatives are involved in the safety and
health program, involved in inspection of work area, and are permitted to observe monitoring and
receive results. Workers' and representatives' right of access to information is understood by
workers and recognized by management. A documented procedure is in place for raising complaints of
hazards or discrimination and receiving timely employer responses. |
4 |
Workers and their representatives participate in workplace
analysis, inspections and investigations, and development of control strategies throughout
facility, and have necessary training and education to participate in such activities. Workers and
their representatives have access to all pertinent health and safety information, including safety
reports and audits. Workers are informed of their right to refuse job assignments that pose
serious hazards to themselves pending management response. |
5 |
Workers and their representatives participate fully in development
of the safety and health program and conduct of training and education. Workers participate in
audits, program reviews conducted by management or third parties, and collection of samples for
monitoring purposes, and have necessary training and education to participate in such activities.
Employer encourages and authorizes employees to stop activities that present potentially serious
safety and health hazards. |
MANAGEMENT LEADERSHIP and EMPLOYEE
PARTICIPATION |
Implementation |
Implementation means tools, provided by management,
that include:
-- budget
-- information
-- personnel
-- assigned responsibility
-- adequate expertise and authority
-- means to hold responsible persons accountable (line accountability)
-- program review procedures.
[Guidelines, (b)(1) and (c)(1)] |
1 |
Tools to implement a safety and health program are inadequate or
missing. |
2 |
Some tools to implement a safety and health program are adequate
and effectively used; others are ineffective or inadequate. Management assigns responsibility for
implementing a site safety and health program to identified person(s). Management's designated
representative has authority to direct abatement of hazards that can be corrected without major
capital expenditure. |
3 |
Tools to implement a safety and health program are adequate, but
are not all effectively used. Management representative has some expertise in hazard recognition
and applicable OSHA requirements. Management keeps or has access to applicable OSHA standards at
the facility, and seeks appropriate guidance information for interpretation of OSHA standards.
Management representative has authority to order/purchase safety and health equipment. |
4 |
All tools to implement a safety and health program are more than
adequate and effectively used. Written safety procedures, policies, and interpretations are
updated based on reviews of the safety and health program. Safety and health expenditures,
including training costs and personnel, are identified in the facility budget. Hazard abatement is
an element in management performance evaluation. |
5 |
All tools necessary to implement a good safety and health program
are more than adequate and effectively used. Management safety and health representative has
expertise appropriate to facility size and process, and has access to professional advice when
needed. Safety and health budgets and funding procedures are reviewed periodically for adequacy. |
MANAGEMENT LEADERSHIP and EMPLOYEE
PARTICIPATION |
Contractor Safety |
Contractor safety: An effective safety and health
program protects all personnel on the worksite, including the employees of contractors and
subcontractors. It is the responsibility of management to address contractor safety.
[Guidelines, (b)(1) and (c)(1)] |
1 |
Management makes no provision to include contractors within the
scope of the worksite's safety and health program. |
2 |
Management policy requires contractor to conform to OSHA
regulations and other legal requirements. |
3 |
Management designates a representative to monitor contractor
safety and health practices, and that individual has authority to stop contractor practices that
expose host or contractor employees to hazards. Management informs contractor and employees of
hazards present at the facility. |
4 |
Management investigates a contractor's safety and health record as
one of the bidding criteria. |
5 |
The site's safety and health program ensures protection of
everyone employed at the worksite, i.e., regular full-time employees, contractors, temporary and
part-time employees. |
WORKPLACE ANALYSIS |
Survey and Hazard Analysis |
Survey and hazard analysis:
An effective, proactive safety and health program will seek to identify and analyze all hazards.
In large or complex workplaces, components of such analysis are the comprehensive
survey and analyses of job hazards and changes in conditions.
[Guidelines, (c)(2)(i)] |
1 |
No system or requirement exists for hazard review of
planned/changed/new operations. There is no evidence of a comprehensive survey for safety or
health hazards or for routine job hazard analysis. |
2 |
Surveys for violations of standards are conducted by knowledgeable
person(s), but only in response to accidents or complaints. The employer has identified principal
OSHA standards which apply to the worksite. |
3 |
Process, task, and environmental surveys are conducted by
knowledgeable person(s) and updated as needed and as required by applicable standards. Current
hazard analyses are written (where appropriate) for all high-hazard jobs and processes; analyses
are communicated to and understood by affected employees. Hazard analyses are conducted for jobs/
tasks/workstations where injury or illnesses have been recorded. |
4 |
Methodical surveys are conducted periodically and drive
appropriate corrective action. Initial surveys are conducted by a qualified professional. Current
hazard analyses are documented for all work areas and are communicated and available to all the
workforce; knowledgeable persons review all planned/changed/new facilities, processes, materials,
or equipment. |
5 |
Regular surveys including documented comprehensive workplace
hazard evaluations are conducted by certified safety and health professional or professional
engineer, etc. Corrective action is documented and hazard inventories are updated. Hazard analysis
is integrated into the design, development, implementation, and changing of all processes and work
practices. |
WORKPLACE ANALYSIS |
Inspection |
Inspection: To identify new
or previously missed hazards and failures in hazard controls, an effective safety and health
program will include regular site inspections.
[Guidelines, (c)(2)(ii)] |
1 |
No routine physical inspection of the workplace and equipment is
conducted. |
2 |
Supervisors dedicate time to observing work practices and other
safety and health conditions in work areas where they have responsibility. |
3 |
Competent personnel conduct inspections with appropriate
involvement of employees. Items in need of correction are documented. Inspections include
compliance with relevant OSHA standards. Time periods for correction are set. |
4 |
Inspections are conducted by specifically trained employees, and
all items are corrected promptly and appropriately. Workplace inspections are planned, with key
observations or check points defined and results documented. Persons conducting inspections have
specific training in hazard identification applicable to the facility. Corrections are documented
through follow-up inspections. Results are available to workers. |
5 |
Inspections
are planned and overseen by certified safety or health professionals. Statistically valid random
audits of compliance with all elements of the safety and health program are conducted.
Observations are analyzed to evaluate progress. |
WORKPLACE ANALYSIS |
Hazard Reporting |
A reliable hazard reporting system enables employees,
without fear of reprisal, to notify management of conditions that appear hazardous and to receive
timely and appropriate responses.
[Guidelines, (c)(2)(iii)] |
1 |
No formal hazard reporting system exists, or employees are
reluctant to report hazards. |
2 |
Employees are instructed to report hazards to management.
Supervisors are instructed and are aware of a procedure for evaluating and responding to such
reports. Employees use the system with no risk of reprisals. |
3 |
A formal system for hazard reporting exists. Employee reports of
hazards are documented, corrective action is scheduled, and records maintained. |
4 |
Employees are periodically instructed in hazard identification and
reporting procedures. Management conducts surveys of employee observations of hazards to ensure
that the system is working. Results are documented. |
5 |
Management responds to reports of hazards in writing within
specified time frames. The workforce readily identifies and self-corrects hazards; they are
supported by management when they do so. |
ACCIDENT and RECORD ANALYSIS |
Accident Investigation |
Accident investigation: An effective program will
provide for investigation of accidents and "near miss"
incidents, so that their causes, and the means for their prevention, are identified.
[Guidelines, (c)(2)(iv)] |
1 |
No investigation of accidents, injuries, near misses, or other
incidents is conducted. |
2 |
Some investigation of incidents takes place, but root cause may
not be identified, and correction may be inconsistent. Supervisors prepare injury reports for lost
time cases. |
3 |
OSHA-101 is completed for all recordable incidents. Reports are
generally prepared with cause identification and corrective measures prescribed. |
4 |
OSHA-recordable incidents are always investigated, and effective
prevention is implemented. Reports and recommendations are available to employees. Quality and
completeness of investigations are systematically reviewed by trained safety personnel. |
5 |
All loss-producing accidents and "near-misses" are investigated
for root causes by teams or individuals that include trained safety personnel and employees. |
ACCIDENT and RECORD ANALYSIS |
Data Analysis |
Data Analysis: An effective
program will analyze injury and illness records for indications of sources and locations of
hazards, and jobs that experience higher numbers of injuries. By analyzing injury and illness
trends over time, patterns with common causes can be identified and prevented.
[Guidelines, (c)(2)(v)] |
1 |
Little or no analysis of injury/illness records; records (OSHA
200/101, exposure monitoring) are kept or conducted. |
2 |
Data is collected and analyzed, but not widely used for
prevention. OSHA - 101 is completed for all recordable cases. Exposure records and analyses are
organized and are available to safety personnel. |
3 |
Injury/illness logs and exposure records are kept correctly, are
audited by facility personnel, and are essentially accurate and complete. Rates are calculated so
as to identify high risk areas and jobs. Workers compensation claim records are analyzed and the
results used in the program. Significant analytical findings are used for prevention. |
4 |
Employer can identify the frequent and most severe problem areas,
the high risk areas and job classifications, and any exposures responsible for OSHA recordable
cases. Data are fully analyzed and effectively communicated to employees. Illness/injury data are
audited and certified by a responsible person. |
5 |
All levels of management and the workforce are aware of results of
data analyses and resulting preventive activity. External audits of accuracy of injury and illness
data, including review of all available data sources are conducted. Scientific analysis of health
information, including non-occupational data bases is included where appropriate in the program. |
HAZARD PREVENTION and CONTROL |
Hazard Control |
Hazard Control: Workforce
exposure to all current and potential hazards should be prevented or controlled by using
engineering controls wherever feasible and appropriate, work
practices and administrative controls, and personal
protective equipment (PPE). [Guidelines, (c)(3)(i)] |
1 |
Hazard control is seriously lacking or absent from the facility. |
2 |
Hazard controls are generally in place, but effectiveness and
completeness vary. Serious hazards may still exist. Employer has achieved general compliance with
applicable OSHA standards regarding hazards with a significant probability of causing serious
physical harm. Hazards that have caused past injuries in the facility have been corrected. |
3 |
Appropriate controls (engineering, work practice, and
administrative controls, and PPE) are in place for significant hazards. Some serious hazards may
exist. Employer is generally in compliance with voluntary standards, industry practices, and
manufacturers' and suppliers' safety recommendations. Documented reviews of needs for machine
guarding, energy lockout, ergonomics, materials handling, bloodborne pathogens, confined space,
hazard communication, and other generally applicable standards have been conducted. The overall
program tolerates occasional deviations. |
4 |
Hazard controls are fully in place, and are known and supported by
the workforce. Few serious hazards exist. The employer requires strict and complete compliance
with all OSHA, consensus, and industry standards and recommendations. All deviations are
identified and causes determined. |
5 |
Hazard controls are fully in place and continually improved upon
based on workplace experience and general knowledge. Documented reviews of needs are conducted by
certified health and safety professionals or professional engineers, etc. |
HAZARD PREVENTION and CONTROL |
Maintenance |
Maintenance: An effective
safety and health program will provide for facility and equipment maintenance, so that hazardous
breakdowns are prevented.
[Guidelines, (c)(3)(ii)] |
1 |
No preventive maintenance program is in place; break-down
maintenance is the rule. |
2 |
There is a preventive maintenance schedule, but it does not cover
everything and may be allowed to slide or performance is not documented. Safety devices on
machinery and equipment are generally checked before each production shift. |
3 |
A preventive maintenance schedule is implemented for areas where
it is most needed; it is followed under normal circumstances. Manufacturers' and industry
recommendations and consensus standards for maintenance frequency are complied with. Breakdown
repairs for safety related items are expedited. Safety device checks are documented. Ventilation
system function is observed periodically. |
4 |
The employer has effectively implemented a preventive maintenance
schedule that applies to all equipment. Facility experience is used to improve safety-related
preventative maintenance scheduling. |
5 |
There is a comprehensive safety and preventive maintenance program
that maximizes equipment reliability. |
HAZARD PREVENTION and CONTROL |
Medical Program |
An effective safety and health program will include a
suitable medical program where it is appropriate for the size and nature of the workplace and its
hazards.
[Guidelines, (c)(3)(iv)] |
1 |
Employer is unaware of, or unresponsive to medical needs. Required
medical surveillance, monitoring, and reporting are absent or inadequate. |
2 |
Required medical surveillance, monitoring, removal, and reporting
responsibilities for applicable standards are assigned and carried out, but results may be
incomplete or inadequate. |
3 |
Medical surveillance, removal, monitoring, and reporting comply
with applicable standards. Employees report early signs/symptoms of job-related injury or illness
and receive appropriate treatment. |
4 |
Health care providers provide follow-up on employee treatment
protocols and are involved in hazard identification and control in the workplace. Medical
surveillance addresses conditions not covered by specific standards. Employee concerns about
medical treatment are documented and responded to. |
5 |
Health care providers are on-site for all production shifts and
are involved in hazard identification and training. Health care providers periodically observe the
work areas and activities and are fully involved in hazard identification and training. |
EMERGENCY RESPONSE |
Emergency Preparedness |
Emergency preparedness: There should be appropriate
planning, training/drills, and equipment for response to emergencies. Note:
In some facilities the employer plan is to evacuate and call the fire department. In such cases, only applicable items
listed below should be considered. [Guidelines, (c)(3)(iii) and (iv)] |
1 |
Little or no effective effort to prepare for emergencies. |
2 |
Emergency response plans for fire, chemical, and weather
emergencies as required by 29 CFR 1910.38, 1910.120, or 1926.35 are present. Training is conducted
as required by the applicable standard. Some deficiencies may exist. |
3 |
Emergency response plans have been prepared by persons with
specific training. Appropriate alarm systems are present. Employees are trained in emergency
procedures. The emergency response extends to spills and incidents in routine production. Adequate
supply of spill control and PPE appropriate to hazards on site is available. |
4 |
Evacuation drills are conducted no less than annually. The plan is
reviewed by a qualified safety and health professional. |
5 |
Designated emergency response team with adequate training is
on-site. All potential emergencies have been identified. Plan is reviewed by the local fire
department. Plan and performance are reevaluated at least annually and after each significant
incident. Procedures for terminating an emergency response condition are clearly defined. |
EMERGENCY RESPONSE |
First Aid |
First aid/emergency care
should be readily available to minimize harm if an injury or illness occurs.
[Guidelines, (c)(3)(iii) and (iv)] |
1 |
Neither on-site nor nearby community aid (e.g., emergency room)
can be ensured. |
2 |
Either on-site or nearby community aid is available on every
shift. |
3 |
Personnel with appropriate first aid skills commensurate with
likely hazards in the workplace and as required by OSHA standards (e.g., 1910.151, 1926.23) are
available. Management documents and evaluates response time on a continuing basis. |
4 |
Personnel with certified first aid skills are always available
on-site; their level of training is appropriate to the hazards of the work being done. Adequacy of
first aid is formally reviewed after significant incidents. |
5 |
Personnel trained in advanced first aid and/or emergency medical
care are always available on-site. In larger facilities a health care provider is on-site for each
production shift. |
SAFETY and HEALTH TRAINING |
Safety and health training
should cover the safety and health responsibilities of all personnel who work at the site or
affect its operations. It is most effective when incorporated into other training about
performance requirements and job practices. It should include all subjects and areas necessary to
address the hazards at the site.
[Guidelines, (b)(4) and (c)(4)] |
1 |
Facility depends on experience and peer training to meet needs.
Managers/supervisors demonstrate little or no involvement in safety and health training
responsibilities. |
2 |
Some orientation training is given to new hires. Some safety
training materials (e.g., pamphlets, posters, videotapes) are available or are used periodically
at safety meetings, but there is little or no documentation of training or assessment of worker
knowledge in this area. Managers generally demonstrate awareness of safety and health
responsibilities, but have limited training themselves or involvement in the site's training
program. |
3 |
Training includes OSHA rights and access to information. Training
required by applicable standards is provided to all site employees. Supervisors and managers
attend training in all subjects provided to employees under their direction. Employees can
generally demonstrate the skills/knowledge necessary to perform their jobs safely. Records of
training are kept and training is evaluated to ensure that it is effective. |
4 |
Knowledgeable persons conduct safety and health training that is
scheduled, assessed, and documented, and addresses all necessary technical topics. Employees are
trained to recognize hazards, violations of OSHA standards, and facility practices. Employees are
trained to report violations to management. All site employees--including supervisors and
managers--can generally demonstrate preparedness for participation in the overall safety and
health program. There are easily retrievable scheduling and record keeping systems. |
5 |
Knowledgeable persons conduct safety and health training that is
scheduled, assessed, and documented. Training covers all necessary topics and situations, and
includes all persons working at the site (hourly employees, supervisors, managers, contractors,
part-time and temporary employees). Employees participate in creating site-specific training
methods and materials. Employees are trained to recognize inadequate responses to reported program
violations. Retrievable record keeping system provides for appropriate retraining, makeup
training, and modifications to training as the result of evaluations. |
Appendix C - Safety and Health Program
Assessment Worksheet |
Request Number |
|
Visit Number |
|
Visit Date |
|
Employer |
|
File No. |
|
Overall Score (circle one): 0
1 2 3 |
Legend: |
0 = No; 1 = No, Needs major improvement; 2 = Yes, Needs minor
improvement; 3 = Yes;
NA = Not Applicable; NE = Not Evaluated; * = Stretch Items Attribute of Excellence |
|
1. Hazard Anticipation and Detection |
1. A comprehensive, baseline hazard survey has been
conducted within the past five (5) years. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
2. Effective safety and health self-inspections are
performed regularly. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
3. Effective surveillance of established hazard
controls is conducted. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
4. An effective hazard reporting system exists. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
5. Change analysis is performed whenever a change in
facilities, equipment, materials, or processes occurs. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
6. Accidents are investigated for root causes. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
7. Material Safety Data Sheets are used to reveal
potential hazards associated with chemical products in the workplace. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
8. Effective job hazard analysis is performed. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
9. Expert hazard analysis is performed. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
10. *Incidents are investigated for root causes. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
2. Hazard Prevention and Control |
11. Feasible engineering controls are in place. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
12. Effective safety and health rules and work
practices are in place. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
13. Applicable OSHA-mandated programs are effectively
in place. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
14. Personal protective equipment is effectively
used. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
15. Housekeeping is properly maintained. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
16. The organization is properly prepared for
emergency situations. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
17. The organization has an effective plan for
providing competent emergency medical care to employees and others present at the site. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
18. *Effective preventive maintenance is performed. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
19. An effective procedure for tracking hazard
correction is in place. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
3. Planning and Evaluation |
20. Workplace injury/illness data are effectively
analyzed. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
21. Hazard incidence data are effectively analyzed. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
22. A safety and health goal and supporting
objectives exist. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
23. An action plan designed to accomplish the
organizations safety and health objectives is in place. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
24. A review of in-place OSHA-mandated programs is
conducted at least annually. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
25. *A review of the overall safety and health
management system is conducted at least annually. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
4. Administration and Supervision |
26. Safety and health program tasks are each
specifically assigned to a person or position for performance or coordination. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
27. Each assignment of safety and health
responsibility is clearly communicated. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
28. *An accountability mechanism is included with
each assignment of safety and health responsibility. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
29. Individuals with assigned safety and health
responsibilities have the necessary knowledge, skills, and timely information to perform their
duties. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
30. Individuals with assigned safety and health
responsibilities have the authority to perform their duties. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
31. Individuals with assigned safety and health
responsibilities have the resources to perform their duties. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
32. Organizational policies promote the performance
of safety and health responsibilities. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
33. Organizational policies result in correction of
non-performance of safety and health responsibilities. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
5. Safety and Health Training |
34. Employees receive appropriate safety and health
training. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
35. New employee orientation includes applicable
safety and health information. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
36. Supervisors receive appropriate safety and health
training. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
37. *Supervisors receive training that covers the
supervisory aspects of their safety and health responsibilities. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
38. Safety and health training is provided to
managers. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
39. *Relevant safety and health aspects are
integrated into management training. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
6. Management Leadership |
40. Top management policy establishes clear priority
for safety and health. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
41. Top management considers safety and health to be
a line rather than a staff function. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
42. *Top management provides competent safety and
health staff support to line managers and supervisors. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
43. Managers personally follow safety and health
rules. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
44. Managers delegate the authority necessary for
personnel to carry out their assigned safety and health responsibilities effectively. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
45. Managers allocate the resources needed to
properly support the organizations safety and health system. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
46. Managers assure that appropriate safety and
health training is provided. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
47. Managers support fair and effective policies that
promote safety and health performance. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
48. Top management is involved in the planning and
evaluation osafety and health performance. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
49. Top management values employee involvement and
participation in safety and health issues. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
7. Employee Participation |
50. There is an effective process to involve
employees in safety and health issues. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
51. Employees are involved in organizational decision
making in regard to safety and health policy. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
52. Employees are involved in organizational decision
making in regard to the allocation of safety and health resources. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
53. Employees are involved in organizational decision
making in regard to safety and health training. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
54. Employees participate in hazard detection
activities. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
55. Employees participate in hazard prevention and
control activities. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
56. *Employees participate in the safety and health
training of co-workers. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
57. Employees participate in safety and health
planning activities. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
58. Employees participate in the evaluation of safety
and health performance. |
0 |
1 |
2 |
3 |
NA |
NE |
Comments:
|
Appendix D
OSHA Strategic Partnership Program Annual Partnership Evaluation Report
Warehousing Logistics and Material Handling Safety Partnership
Partnership I.D. #299
Cover Sheet |
Partnership Name |
Purpose of Partnership |
|
|
Goals of Partnership |
Goal |
Strategy |
Measure |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Strategic Management Plan Target
Areas (check one) |
|
Construction |
|
Manufacturing Amputations |
|
Non-Construction |
|
|
Strategic Management Plan Areas of
Emphasis (check all applicable) |
|
Amputations in Construction |
|
Oil and Gas Field Services |
|
Blast Furnaces and Basic Steel Products |
|
Preserve Fruits and Vegetables |
|
Blood Lead Levels |
|
Public Warehousing and Storage |
|
Concrete, Gypsum and Plaster Products |
|
Ship/Boat Building and Repair |
|
Ergo/Musculoskeletal |
|
Silica-Related Disease |
|
Landscaping/Horticultural Services |
|
|
Section 1 General Partnership Information |
Date of Evaluation Report |
|
Evaluation Period |
Start Date |
|
End Date |
|
Evaluation Contact Person |
|
Originating Office |
|
Partnership Coverage |
# Active Employers |
|
# Active Employees |
|
Industry Coverage (note range or
specific SIC and NAICS for each partner) |
Partner |
SIC |
NAICS |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Section 2 Activities Performed |
Note whether an activity was
required by the OSP and whether it was performed |
|
Required |
Performed |
a. Training |
|
|
b. Consultation Visits |
|
|
c. Safety and Health Management Systems
Reviewed/Developed |
|
|
d. Technical Assistance |
|
|
e. VPP-Focused Activities |
|
|
f. OSHA Enforcement Inspections |
|
|
g. Offsite Verifications |
|
|
h. Onsite Non-Enforcement Interactions |
|
|
i. Participant Self-Inspections |
|
|
j. Other Activities |
|
|
2a. Training (if performed,
provide the following totals) |
Training sessions conducted by OSHA staff |
|
Training sessions conducted by non-OSHA staff |
|
Employees trained |
|
Training hours provided to employees |
|
Supervisors/managers trained |
|
Training hours provided to supervisors/managers |
|
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
2b. Consultation Visits (if
performed, provide the following total) |
Consultation visits to partner sites |
|
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
2c. Safety and Health Management
Systems (if performed, provide the following total) |
Number of systems implemented or improved using the 1989
Guidelines as a model |
|
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
2d. Technical Assistance (if
performed, note type and by whom) |
|
Provided by OSHA Staff |
Provided by Partners |
Provided by Other Party |
Conference/Seminar Participation |
|
|
|
Interpretation/Explanation of Standards or OSHA Policy |
|
|
|
Abatement Assistance |
|
|
|
Speeches |
|
|
|
Other (please specify) |
|
|
|
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
2e. VPP-Focused Activities (if
performed, provide the following totals) |
Partners/participants actively seeking VPP participation |
|
Applications submitted |
|
VPP participants |
|
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
2f. OSHA Enforcement Activity (if
performed, provide the following totals for any programmed, unprogrammed, and verification-related
inspections) |
OSHA enforcement inspections conducted |
|
OSHA enforcement inspections in compliance |
|
OSHA enforcement inspections with violations cited |
|
Average number of citations classified as Serious, Repeat, and
Willful |
|
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
2g. Offsite Verification (if
performed provide the following total) |
Offsite verifications performed |
|
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
2h. Onsite Non-Enforcement
Verification (if performed provide the following total) |
Onsite non-enforcement verifications performed |
|
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
2i. Participant Self-Inspections
(if performed provide the following totals) |
Self-inspections performed |
|
Hazards and/or violations identified and corrected/abated |
|
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
2j. Other Activities (briefly describe other
activities performed) |
|
Section 3 Illness and Injury Information* |
Year |
Hours |
Total Cases |
TCIR |
# of Days Away from Work Restricted and
Transferred Activity Cases |
DART |
2002 |
|
|
|
|
|
2003 |
|
|
|
|
|
2004 |
|
|
|
|
|
Total |
|
|
|
|
|
Three-Year Rate (2002-2004) |
|
|
|
BLS National Average for 2003 |
|
|
|
Baseline |
|
|
|
|
|
*Sample Chart – not required format
Section 4 Partnership Plans, Benefits, and Recommendations |
Changes and Challenges
(check all applicable) |
|
Changes |
Challenges |
Management Structure |
|
|
Participants |
|
|
Data Collection |
|
|
Employee Involvement |
|
|
OSHA Enforcement Inspections |
|
|
Partnership Outreach |
|
|
Training |
|
|
Other (specify) |
|
|
Comments |
|
Plans to Improve
(check all applicable) |
|
Improvements |
N/A |
Meet more often |
|
|
Improve data collection |
|
|
Conduct more training |
|
|
Change goals |
|
|
Comments |
|
Partnership Benefits (check all
applicable) |
Increased safety and health awareness |
|
Improved relationship with OSHA |
|
Improved relationship with employers |
|
Improved relationship with employees or unions |
|
Increased number of participants |
|
Other (specify) |
|
Comments |
|
Status Recommendation |
Partnership Completed |
|
Continue/Renew |
|
Continue with the following provisions: |
|
|
Terminate (provide explanation) |
|
|
|