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Printing Instructions

COMPREHENSIVE SAFETY AND HEALTH PARTNERING AGREEMENT

BETWEEN

THE UNITED STATES DEPARTMENT OF LABOR
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
TARRYTOWN AREA OFFICE,

THE NEW YORK STATE DEPARTMENT OF LABOR
DIVISION OF SAFETY AND HEALTH
ON-SITE CONSULTATION PROGRAM.

THE BUILDING AND CONSTRUCTION TRADES COUNCIL OF
WESTCHESTER AND PUTNAM COUNTIES, INC.,

THE BUILDING CONTRACTORS ASSOCIATION OF
WESTCHESTER AND MID-HUDSON, INC.

and

WORTH CONSTRUCTION CO., INC.

PARTNERSHIP - An OSHA Cooperative Program

Table of Contents

Section 1.0 Background
Section 2.0 Definitions
Section 3.0 Project History
Section 4.0 Partnership Goals and Objectives
Section 5.0 Performance Criteria
Section 6.0 Measurement and Evaluation of Performance
Section 7.0 Communication of Results
Section 8.0 Employee Involvement and Employee Rights
Section 9.0 OSHA Inspections
Section 10.0 Incentives
Section 11.0 Termination of Partnership
Section 11.1 OSHA Strategic Partnership Program
Section 12.0 Signatures

1.0 Background

In an effort to eliminate serious hazards and achieve a high level of worker safety and health on the Ridge Hill Project, Phase I (Buildings A1, A2, A3, B&C with Pedestrian Bridge A2-B, A3-C & B-C), Worth Construction Co., Inc. and the above named groups have developed a comprehensive partnering agreement. Participants include project stakeholders from government, industry employers, labor, and trade associations. This partnering agreement will facilitate the process of: identifying project health and safety performance goals; developing plans for achieving those goals; cooperation in hazard control implementation; measuring and establishing a vehicle to communicate the successes; and ultimately learning from the process.

This partnering agreement shall be limited to the Worth Construction Co., Inc., (WCCI), OSHA’s Tarrytown Area Office (OSHA), the New York State Department of Labor Division of Safety and Health On-Site Consultation Program (NYS Consultation), the Building and Construction Trades Council of Westchester and Putnam Counties, NY (BCTC), and the Building Contractors Association of Westchester and Mid-Hudson, Inc. (BCA). It is anticipated that at the peak of this project, Worth Construction Co., Inc. and its 22 subcontractors will employ over 250 trade employees.

This partnership is consistent with OSHA’s long-range efforts to develop a contractor/government partnership approach to safety and health management. It allows for better use of OSHA resources, innovation in safety and health management, and encourages more participation in the safety and health process from the construction/trade association communities.

2.0 Definitions

DART: Days away from work, restricted work activity, or job transfer

Investigations: The procedure for responding to non-formal complaints described on OSHA’s Field Inspection Reference Manual. This procedure mandates that OSHA contact an employer and inform them of the safety and/or health hazards that are alleged, by a complainant, to exist in that employer’s workplace. OSHA then faxes a copy of the allegations to the employer. The employer must satisfactorily respond to the allegations within five calendar days, or an OSHA enforcement inspection may be initiated.

TCIR: (Total Case Incident Rate) This injury and illness rate is calculated by dividing the number of lost work time events by the total number of employees hours worked, and then multiplying by 200,000. The resultant rates reflect the injury and illness rate per 100 fulltime workers.

Other-than-Serious Violations: This type of violation references situations where the most serious injury or illness that would be likely to result from a hazardous condition cannot reasonably be predicted to cause death or serious physical harm to exposed employees but does have a direct and immediate relationship to their safety and health.

Qualified Safety and Health Representative: For the purpose of this Partnership only, a Qualified Safety and Health Representative will, as a minimum, be certified in the OSHA- 30 hour Construction Course, or have substantial construction safety and health experience.

Serious Violations: Section 17(k) of the Act provides “…a serious violation shall be deemed to exist in a place of employment if there is a substantial probability that death or serious physical harm could result from a condition which exists, or from one or more practices, means, methods, operations, or processes which have been adopted or are in use, in such place of employment unless the employer did not, and could not with the exercise of reasonable diligence, know of the presence of the violation.”

Verification Inspection: A limited scope inspection that will focus on the following areas: a comprehensive review of the required safety and health programs and a site review of: fall, struck-by, electrocution, and caught-between hazards.

Voluntary Protection Programs: The Voluntary Protection Programs (VPP) promotes effective worksite-based safety and health. In the VPP, management, labor, and OSHA establish cooperative relationships at workplaces that have implemented a comprehensive safety and health management system. Approval into VPP is OSHA’s official recognition of the outstanding efforts of employers and employees who have achieved exemplary occupational safety and health.

VPPPA: The VPPA promotes the benefits of cooperative programs among employees, management and labor through educational and outreach services, as well as an active government affairs program. Educational opportunities include workshops, conferences and presentations throughout the United States. Outreach programs include the Association’s quarterly magazine The Leader, electronic newsletters, the VPPA Mentoring Program and the VPPA Web site.

3.0 Project History

Worth Construction Co., Inc. has a workforce of 50 employees, is involved in heavy construction and is headquartered in Bethel, Connecticut.

Worth Construction Co., Inc. is the general contractor for the Ridge Hill, Phase I Project (Construction of Core & Shell for 5 buildings, with 3 attaching Pedestrian Bridges. These buildings and bridges consist of structural steel frames with poured concrete floors on metal decks. External components consist of pre-cast concrete, panel, masonry, EIFS and other façade materials), the construction of pile and grade beam foundations, a steel frame with long span steel trusses, masonry partitions, metal panel wall system and standing seam metal roofing. Construction of this project will commence on February 12, 2008 and is scheduled to be completed on, or about December 31, 2009.

During construction Worth Construction Co., Inc. will provide a full time safety manager and ensure compliance with construction environmental, health, and safety practices. This includes federal, state, local, projects and owner rules and regulations.

4.0 Partnership Goals and Objectives

4.1 The goals of this Partnership include:

Developing a contractor/government partnership that will encourage local construction subcontractors involved in the project to improve their safety and health performance;

Assisting the participating local construction subcontractors in achieving the objectives listed below;

Implementing strategies to eliminate serious accidents, including the four primary construction hazards (falls, electrical, caught in/between, and struck-by);

Ensuring employee safety and health training;

Recognizing those subcontractors with exemplary safety and health programs;

A project DART rate that is 25% less than the national average for Standard Industry Code 1542

4.2 The objectives of this Partnership include:

Reducing the number of conditions that have the potential to result in worker injury/illness to the lowest reasonable level through employee training and hazard(s) identification and correction;

100% compliance with project-required incident prevention activities;

Zero (0) fatalities;

Zero (0) exposure of employees to walking/working surfaces (horizontal and vertical) with unprotected sides or edges, which are 6 feet or more above a lower lever.
(Structural steel erection process will be guided by OSHA’s subpart R).

Conducting a gap analysis of all participating contractors’ site-specific safety and health programs and, through resource sharing, enhance these programs to meet the Partnership Agreement performance criteria. “Gap analysis” is the difference between the contractor’s site-specific programs and WCCI’s requirements for work procedures each contractor is to perform. WCCI will evaluate each contractor’s site-and-task specific analysis to ensure that it meets the required safety and health performance criteria for the site prior to commencement of their on-site activities. WCCI will provide reasonable assistance to subcontractors to improve their safety program.

Fostering a sustainable working relationship between WCCI, OSHA , local contractors, building and construction trades, and other entitles involved in this project;

Partnering with the BCA, the BCTC, and the union representative framework to encourage positive change within the local construction industry with respect to betterment of construction safety and health during the Project.

Discussions of the benefits of participation in the VPP, and initiation of the VPP Application process.

To achieve the goals and objectives cited above, OSHA, WCCI, BCA, NYS Consultation, and the BCTC will form an Implementation Team (IT) comprised of representatives of their organizations. These representatives will work together to develop a plan of action, determine the working procedures of the IT, identify the roles and responsibilities of the participants, and develop a time-line for the goals and objectives described in this Partnership document. This time-line will also establish the dates for submission of data and other records to OSHA by WCCI, as described in this Partnership document.

The IT will meet within 30 working days of the signing of this Partnership to review the goals and objectives described herein. It will meet three times per year thereafter, for the duration of the Partnership, to evaluate progress toward the Goals and Objectives. Annually, at least one of these meetings will be in person

5.0 Performance Criteria

5.0.1 Safety and Health Contract Language

Worth Construction Co., Inc. shall incorporate safety and health program performance requirements into all contracts including new hire orientations and weekly safety and health craft meetings.

5.0.2 Experience Modification Rates

Only contractors with an Experience Modification Rating (EMR) rating of 1 or less will be employed at the site. Worth Construction Co., Inc. may make an exception to this condition for contactors under the following conditions:

The Contractor has made significant progress in safety and health since receiving the EMR that exceed 1.0, and agrees to comply with all provisions of the Worth Construction Co., Inc. “Safety, Health and Environmental Policy” manual.

Worth Construction Co., Inc. determines that the elevated EMR was not due to serious, consistent infractions of OSHA safety and health standards.

5.0.3 Bidding Period

The bid packages, distributed by Worth Construction Co., Inc. to all potential bidders, include a copy of Worth Construction Co., Inc.’s “Safety, Health and Environmental Policy” manual.

5.0.4 Pre-Construction Meetings

Prior to the start of construction work, Worth Construction Co., Inc. shall conduct a pre-construction meeting with each successful bidder which shall include discussion regarding requirements for the successful bidder to integrate Worth Construction Co., Inc.’s “Safety, Health and Environmental Policy” into their standard safety and health programs and performance expectations.

5.0.5 Coordination Meetings

Worth Construction Co., Inc. shall hold a weekly meeting with all Project Managers, Company Owners, and/or Foremen that shall include focused discussion addressing site safety and health issues.

5.0.6 Monthly Meeting

Worth Construction Co., Inc. shall hold a monthly project safety and health meeting to discuss program status and participant performance. OSHA is welcome to attend these meetings. Invitations to attend the meetings will be extended to Shop Stewards, as well as Foremen.

5.0.7 Qualified Safety and Health Representatives

Worth Construction Co., Inc. shall assign a qualified safety and health representative to administer its safety and health program.

5.0.8 Risk Assessment

WCCI and/or its designated safety and health representative shall conduct a comprehensive risk assessment of project work and incorporate the findings of the assessment into the Project Operations Plan.

5.0.9 Project-Specific Safety and Health Plan Guidelines

WCCI and/or its designated safety and health representative shall prepare a project-specific safety and health plan to be used as a baseline for contractor programs to meet or exceed. This plan shall incorporate the following minimum elements:

Fall exposure potential greater than six feet requires 100% fall protection

Mandatory use of Ground Fault Interrupters (GFCIs) throughout the project

All cranes, hoists, and scissor/aerial lifts will be inspected and safe prior to use

Use of appropriate personal protective equipment

Site-specific safety and health training

Workplace surveillance

Employee involvement

Management commitment

5.0.10 Weekly Safety and Health Audits

Worth Construction Co., Inc shall ensure that weekly safety and health audits are conducted and documented by Worth Construction Co., Inc.’s safety and health representative.

5.0.11 Training

Worth Construction Co., Inc. and /or its designated safety and health representative shall provide safety and health training resources for all project participants as needed. Another objective of this training will be to familiarize all employees with the Safety Management System. This will include the methods and contacts employees can use to address safety and health concerns.

Employees should be encouraged at the time of this training and during other safety and health – related training to utilize this reporting system as a pre-cursor to filing a complaint with OSHA.

5.0.12 Incident Recordkeeping Database

Worth Construction Co., Inc. or its designated safety and health representative shall maintain a project OSHA-300 Log (or equivalent database). This shall be maintained in accordance with 29 CFR 1904 -Recording and Reporting Occupational Injuries and Illnesses. Worth Construction Co. Inc. also agrees to compile and maintain a database that describes “near miss” events, and hazards or hazardous conditions that were discovered and corrected during the safety audits/inspections described in 5.0.10 and 5.1.5 of this Partnership Agreement. Information in this database will be used as a training tool and made available to all the Contractors.>

5.1 Project Contractor’s Role

5.2 OSHA’s Role

5.3 Craft Labor’s Role

6.0 Measurement and Evaluation of Performance

6.1 Worth Construction Co., Inc. and/or its designated safety and health representative will compile and track a monthly summary of contractor injury and illness performance statistics at the job site. This data will be compared to Worth Construction Co., Inc.’s historical data, the historical data (if available) of the participating employers, and national data for comparison and evaluation.

6.2 Worth Construction Co., Inc. and/or its designated safety and health representative will collect documentation from contractors in order to ensure procedural performance of project requirements.

6.3 Within 30 days of the initiation of this partnership agreement OSHA and Worth Construction Co., Inc. shall conduct a verification inspection of the Ridge Hill Phase I, as defined in Section 2.0: Definitions, and Section 9.1: Verification Inspections.

6.4 At the end of each quarter, Worth Construction Co., Inc. and/or its designated safety and health representative will compile and submit to OSHA a report that evaluates the partnership agreement’s achievements and identifies areas for continued improvement. Near misses are an integral part of the accident prevention program and will be evaluated by the safety and health team.

This quarterly report will also include a list of all employees that have received safety and health training as a result of and during the term of this Partnership Agreement. The employee’s name, employer, and topic and length of training shall be included in this quarterly report.

7.0 Communication of Results

The signatories or their designated representative(s) will meet at least three times annually to review partnership agreement status and progress. At least one of these meetings will be in person, and this meeting will take place at the Site Field Office or Worth Construction Co., Inc’s main office and may be combined with the Implementation Team meetings.

The partners will prepare a joint evaluation of the partnership annually. The evaluation will review the success of the partnership, lessons learned, and changes that will be made to meet the goals of the partnership. The annual performance evaluation report format from Appendix C of the OSHA Strategic Partnership Program (OSPP) Directive CSP 03-02-002 will be used. Performance measures listed in Section 4.0: Partnership Goals and Objectives of this partnership agreement will be collected and analyzed to determine the partnership’s progress toward meeting its goals.

8.0 Employee Involvement and Employee Rights

This partnership agreement fully supports and recognizes the importance of employee participation in matters concerning safety and health in the workplace. As a vital component of an effective safety and health programs, the ability of employees to exercise their rights, which are guaranteed under the OSHA Act, will not be infringed. Employee involvement in the worksite safety and health program will be encouraged, including employee participation in safety and health program reviews, site inspections, employee safety and health training, accident investigations, and freedom to report hazards, including near misses. The building trade organizations most directly involved or effected by the partnership will be consulted and encouraged to suggest improvements and further enhancements of this partnership. Worth Construction Co., Inc. will document all employee, trade organization, and union involvement in this Partnership.

9.0 OSHA Inspections and Investigations

9.1 Verification Inspections – Qualifications for this OSHA Partnership requires that OSHA conduct a Verification Inspection of WCCI and the Ridge Hill Phase I site within 30 days of the signing of this agreement, and annually thereafter for the term of this Partnership Agreement. This verification inspection will determine Worth Construction Co., Inc. and contractor compliance and include a comprehensive review of the effectiveness of each subcontractor’s safety and health program. Subcontractors who are determined, by OSHA, to be outside the aforementioned criteria for inclusion under this Partnership Agreement will be subject to traditional OSHA inspections and enforcement actions. Serious hazards discovered during the Verification Inspection may result in the issuance of citations and penalties. Other than regulatory violations (e.g., 29CFR 1903 and 1904), no penalties will be assessed for other-than-serious violations provided they are abated the same day as the inspection.

Enforcement verification inspections are performed in accordance with the applicable sections of the OSHA FIRM and other enforcement guidance documents. As such, a focused inspection, concentrating on the project safety and health program/plan, and the four leading hazards may be done where upon initial inspection of the site the OSHA compliance officer (CSHO) determines that the contractor meets the requirements of the Focused Inspection Initiative.

9.2 Formal Complaints / Referrals / Imminent Danger

This partnership calls for the immediate response by Worth Construction Co., Inc. to each allegation of a safety and health hazard brought to the attention of management by any person. Upon finding that an allegation is valid, the employer shall promptly correct the hazard.

Worth Construction Co., Inc. and the participating contractors recognize and accept that OSHA will investigate formal complaints and referrals, and alleged imminent danger hazards in accordance with OSHA’s CPL-02-00-140-Complaint Policies and Procedures. These inspections will be conducted outside the scope of this partnership agreement in accordance with normal enforcement procedures and practices. Hazards indentified may result in the issuance of citations and penalties. All formal complaints, referral, and imminent danger situations will be discussed by Worth Construction Co., Inc. at the next scheduled job safety and health meeting.

9.3 Investigations

OSHA will investigate non-formal complaints in accordance with OSHA’s CPL-02-00-140-Complain Policies and Procedures. Worth Construction Co., Inc will immediately investigate all allegations and correct any hazards identified. The effected subcontractor, if any, as well as effected unions will also be notified of the alleged hazard. Worth Construction Co., Inc. will notify OSHA of its findings and abatement within five calendar days of the original complaint notification. Failure to meet this time frame will place the complaint/referral outside the scope of this partnership agreement and result in an OSHA on-site inspection of the allegations.

All non-formal complaints and investigation results will be discussed by Worth Construction Co., Inc, at the next scheduled job safety and health meeting.

9.3 Accident/Incident Inspections

Worth Construction Co., Inc. and the participating contractors recognize and accept that OSHA will fully inspect incidents involving employee deaths, incidents resulting in the hospitalization of three or more employees, or other serious incidents that come to the attention of OSHA. These inspections will be conducted outside the partnership in accordance with normal enforcement procedures and practices. Hazards identified may result in the issuance of citations and penalties.

9.4 Programmed Inspections

Programmed inspections may be initiated if there has not been a verification inspection during the 12 previous months. These inspections will be conducted in accordance with
normal enforcement procedures and practices. Hazards identified may result in the issuance of citations and penalties. Worth Construction Co., Inc. and the contractors participating in this partnership will receive a deferral from programmed inspections, for 12 months, after successful completion of the Verification Inspection.

9.5 Follow-up Inspections

If OSHA issues citations as a result of any inspection, it may conduct a follow-up inspection to verify abatement.

10.0 Incentives

10.1 Worth Construction Co., Inc. and the participating contractors will receive a deferral, for 12 months, from programmed inspections following successful completion of a verification inspection.

10.2 No penalties will be assessed for other-than-serious violations provided they are abated the same day as the inspection.

10.3 A maximum “Good Faith” and “History” penalty adjustment factor will be applied as allowed under OSHA’s Field Instruction Reference Manual (FIRM) in the event that citations are issued to the Worth Construction Co., Inc. and the participating contractors.

10.4 OSHA will work with the Partnership participants to maximize recognition of the Partnership through various media outlets and the OSHA web site.

11.0 Termination of Partnership Agreement

This agreement will expire when Worth Construction Co., Inc’s Ridge Hill Phase I activities are completed. Should either OSHA or Worth Construction Co., Inc. choose to withdraw prior to that date, thirty (30) days written notice will be given, and the partnership would terminate. If OSHA chooses to withdraw its participation in the partnership, the entire agreement in terminated. Either party may also propose modification or amendment of the agreement.

OSHA Strategic Partnership Program
Annual Partnership Evaluation Report

Partnership Name

Ridge Hill Phase 1: Worth Construction Company, Inc.

Purpose of Partnership

To provide a guideline for all Contractor’s, Subcontractors, Suppliers and vendors in establishing site specific safety plans for the execution of work at the Ridge Hill, Phase 1 Project.

Partnership ID Number

Goals of Partnership

Provide a safe work environment for all.
Standardize a health and safety plan for all participants that outlines site specific safety issues.
Insure that the focus on safety is a daily event on this project.

Anticipated Outcomes

Zero accident project.
Education of trades people through the establishment of safety communication and education.

Strategic Management Plan Areas of Emphasis (check all applicable)
	Construction	X	Concrete, Gypsum and Plaster Products
	General Industry		Blast Furnaces and Basic Steel Products
	Amputations in Manufacturing		Ship and Boat Building and Repair
	Amputations in Construction		Public Warehousing and Storage
	Landscaping/Horticultural Services		Ergo/Musculoskeletal
	Oil and Gas Field Services		Blood Lead Levels
	Preserve Fruits and Vegetables	X	Silica-Related Disease

Section 1 General Partnership Information

Date of Evaluation Report
Evaluation Period
Start Date	February 12, 2008	End Date	December 31, 2009

Evaluation Contact Person	Tom McCarthy
Originating Office	Tarrytown, New York

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)

Note whether an activity was required by the OSP and whether it was 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 (1)

Year	Hours	Total Cases	TCIR	# of Days Away from Work Restricted and Transferred Activity Cases	DART
2005
2006
2007
Total
Three-Year Rate (2005-2007)
BLS National Average for 2006
Baseline

(1) 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)

Signed this 15th day of July, 2008,

Louis Ricca, Jr. Acting Regional Administrator USDOL/OSHA - Region 2		John Bigham Safety Director Worth Construction Co., Inc.
Diana Cortez Area Director, Tarrytown Area Office USDOL/OSHA		James Rush Program Manager NYS Department of Labor Onsite Consultation Program
Edward Doyle President Building and Construction Trades Council of Westchester and Putnam Counties, NY		Ross Pepe President Building Contractors Association of Westchester and Mid-Hudson, Inc.

Paperwork Reduction Act Notice Form Approved: OMB# 1218-0244 Expires 01-31-2009
Public reporting burden for the time needed to develop the Partnership requirements, craft agreement language,
And conduct an internal review process is estimated to be an average of 11 burden hours per respondent.

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