I. Objective
To facilitate OSHA’s goal of reducing occupationally related fatalities by 3%
each year, and reducing the total Rate of Days Away from Work by 4% each year, the Norfolk Area
Office in Region III of the Occupational Safety and Health Administration (OSHA) and the Virginia
Ship Repair Association, Inc. (VSRA) have agreed to joint implementation of the Shipyard Safety
Training Partnership.
This agreement is consistent with OSHA’s long range efforts to develop a business / labor /
government partnership approach to safety and health management, allows for better use of OSHA
resources, and encourages more participation in the safety process by VSRA members. Representatives
of the shipyard activities most directly involved or affected by this partnership have been
consulted and encouraged to provide continuous improvements and enhancements to this partnership
agreement.
Expected outcomes of the program include developing and implementing model shipyard occupational
safety and health and training programs for all participants.
II. Background
The Virginia Ship Repair Association (VSRA) has over 170 member companies that
work in or support the ship repair industry in Virginia and along the Mid-Atlantic coast of the
United States. The association works closely with a variety of government agencies, federal and
state, as well as other maritime organizations, to create a high standard of excellence in and for
the ship repair industry. In this regard, VSRA has a long-standing commitment to promote safety and
health awareness to its members, which includes a strong training commitment to educational courses
and seminars.
Joint efforts by OSHA and VSRA, through this partnership agreement, will leverage each others’
resources to target larger populations in the ship repair industry for safety and health focus and
will promote a voluntary, cooperative effort between OSHA and the VSRA membership to reduce
occupational accidents and save lives.
III. Identification of Partners and the Geographical Boundaries of the
Partnership Agreement
Partners:
U.S. Department of Labor, Occupational Safety and Health Administration, Norfolk
Area Office (OSHA)
Virginia Ship Repair Association, Inc. (VSRA)
150 Boush Street, Suite 802
Norfolk, Virginia 23510
Geographical Boundary of the Partnership Agreement:
Available to VSRA participants in the State of Virginia
IV. OSHA Primary Contact
Leo Edwards, Acting Area Director, U.S. Department of Labor, Occupational
Safety and Health Administration, Norfolk Area Office
V. Goals/Strategies/Measures
- Increase the number of ship repair employers who develop, implement, and maintain comprehensive
safety and health programs in accordance with OSHA’s 1989 Safety and Health Program Management
Guidelines or the equivalent.
- Achieve participant recordable illness and injury rates below the national average for the SIC
3731/SIC 3732 (NAICS 336611/NAICS 336612). A partnership goal is to keep the DART rate (cases with
days away from work, job-transfer, or restriction) below the most recently published national
average for the industry which was 6.0 for the year 2005. The partnership goal is to further
reduce this level of injuries by at least 4% annually for the life of the agreement, and to
facilitate OSHA’s goal of reducing fatalities by 3% annually.
| (Strategy) |
Participants’ safety and health programs will be
evaluated using Appendix A, the VSRA Safety & Health Self Assessment Checklists.
|
| (Strategy) |
Develop and maintain systems for the early
identification and correction of the hazards which have resulted in serious injuries in the ship
repair industry. The primary causes of injuries and illnesses among participants will be
determined by all parties (VSRA, OSHA, VSRA participants) through quarterly review of
self-assessments, injury and illness records, and any other relevant accident reports. If
necessary during the partnership, the focused hazards will be adjusted based on experience.
|
| (Strategy) |
Develop and provide safety and health training,
technical assistance, operating procedures, and abatement methods that accurately target and
reduce the primary causes of injury and illness in the shipbuilding and ship repair industry as
identified by the partners.
|
| (Strategy) |
Share best practices in occupational safety and
health for the ship repair industry.
|
| (Measure) |
Injury and illness rates will be evaluated annually
by review of OSHA 300 logs and any other relevant accident reports. |
VI. Partnership Management
A. OSHA Agrees To:
1. Assist VSRA in the development of criteria to be used for safety and health training.
2. Provide technical information and assistance to VSRA regarding the grant process in order to
apply for funding for Safety and Health Training Programs.
3. Participate in VSRA annual training seminars.
4. Provide an OSHA representative to meet with VSRA members on a quarterly basis to review
partnership issues, examine the injury and illness experience of participants, suggest corrective
measures to eliminate hazards and share best practices.
5. Share information on current violations and statistics, including relevant interpretations,
proposed standards and similar information, which may be of interest to VSRA members.
6. Assist participating members who have established and implemented a comprehensive safety and
health program (such as referenced in Safety and Health Program Management Guidelines, FRN
54:3904-3916, January 26, 1989 and/or American National Standards Institute (“ANSI”) A 10.38, “Basic
Elements of an Employer Program to Provide a Safe and Healthful Work Environment”).
B. VSRA Agrees To:
Administer the partnership agreement, as outlined below, and serve as the principal safety and
health resource in support of VSRA members. Additionally, VSRA will:
1. Assist participating members in developing, implementing and maintaining comprehensive safety and
health programs through the administration of VSRA’s self- assessment program.
2. Maintain participant signatory letters and certifications, Appendix B, and verify certifications
with OSHA upon request.
3. Review with OSHA and VSRA participants, on a quarterly basis, the primary causes of injuries and
illnesses among the participants, suggest corrective measures to eliminate hazards and share best
practices.
4. Act as liaison for VSRA members with OSHA. Members will be able to contact VSRA or OSHA with
questions.
5. Offer quality training on topics of importance to participants and VSRA membership, especially
the focused hazards determined by the partners.
6. Through the Safety Committee provide safety and health meetings with members to assist with their
training efforts. Members can use this information for site-specific and topical training. To
further assist members, the Safety Committee and VSRA will undertake the development of a safety and
health awareness program that includes lectures as well as a specific safety slogan that members may
utilize.
7. Obtain and provide to members, upon request, current informational materials, brochures, and
publications from available resources.
8. Organize and provide OSHA standards interpretations as well as local inspection perspectives to
assist members in understanding and properly applying standards to their work sites.
C. VSRA Participants Agree To:
1. Sign a letter of agreement, Appendix B, with VSRA indicating their intent to participate in this
partnership.
2. Certify that their company has not been cited by the Norfolk Area Office within the
past three (3) years for alleged violations classified as “repeated” and/or “willful.”
3. Ensure employee training in the program, including supervisory personnel, utilizing
VSRA supported safety and health training programs or equivalent training.
4. Provide written affirmation using Appendix B that a comprehensive written safety and health
program is in place, which is at least equivalent to the criteria referenced in Section VI,
Paragraph A.6 as the minimum established criteria for participation, including implementation of
policies and procedures to ensure that safety rules and procedures are enforced at their work sites.
5. Complete Safety & Health Self Assessment Checklists, Appendix A, upon
entry into partnership with review and certification by President/CEO that deficiencies have been
corrected.
6. Provide written affirmation using Appendix B that their policy and procedures hold line
supervisor and employee accountable for following established safety and health rules and OSHA
regulations.
7. Provide the level of training required by OSHA regulations to their employees either through
VSRA, their own training personnel or other consultant/trainers.
8. Provide annual safety related data or statistics to the VSRA office concerning man- hours worked,
lost day work injuries, and accident records. This data will be used to determine primary causes of
injury and illness among participants in order to develop training, sound operating procedures, and
abatement methods. VSRA shall maintain this information’s confidentiality as to company and shall
release only compiled “group wide” data that does not reveal the statistics for any individual
participating members.
VII. Benefits
Give priority service to VSRA participating members requiring OSHA technical
assistance.
OSHA will not issue penalties for other-than-serious violations, provided that the abatement of
violations is observed.
OSHA will recognize and consider VSRA safety and health training programs when inspecting work sites
of partnering members (participating in this partnership with required safety and health program
fully implemented), consider the extent of employee training and instruction and the VSRA member’s
safety and health program.
If cited by OSHA, participating contractors will be eligible for the maximum penalty reduction for
good faith, currently outlined within OSHA Instruction CPL 2.103 (Field Inspection Reference
Manual).
VIII. Verification
In order to assist in measuring the success of this partnership, the Norfolk
Area Office will verify that all current participants have completed their self-assessments,
Appendix A, and have corrected deficiencies where appropriate.
IX. Evaluation
A joint evaluation of the partnership will be prepared annually by the Norfolk
Area Office and VSRA using Appendix C. The evaluation will review the success of the partnership,
lessons learned, and changes that will be made to meet the goals of the partnership.
X. Employee/Employer Rights and OSHA Investigations
Employee rights which are guaranteed under the OSH Act shall not be infringed
upon as a result of this partnership. 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.
OSHA personnel will continue to investigate under local and national emphasis programs, workplace
complaints, referrals, fatalities, catastrophes, other accidents or significant events, and
contractors whose employees are exposed to or are creating plain view hazards at partnering
worksites. These investigations will be conducted outside of this partnership agreement in
accordance with established OSHA enforcement policy. Violations documented during such
investigations may result in the issuance of citations and penalties.
XI. Indemnification and Hold Harmless
OSHA, VSRA, and all Participating VSRA Members hereby agree that their sole
remedy for any alleged defaults under this Agreement or under the Program set forth therein shall be
the Termination of the Agreement as set forth above. Each party hereto and each Participating VSRA
Member expressly agrees to hold the other parties harmless and to indemnify them for any claim
brought by themselves or any employees, agents, or invitees of such entity as a result of any
alleged violation of this Agreement; provided, however, that nothing in this release language shall
in any way limit any Participating Member’s liability for violation of any Federal or State safety
laws or regulations.
XII. Termination
This agreement will terminate on December 19, 2009 which is three years from
the date of the signing. If any signatory of this agreement wishes to terminate its 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.
For non-signatory participants of the strategic partnership, OSHA may terminate the participant's
involvement at any time with written notice. Additionally, the participant may withdraw its
participation from the strategic partnership at any time with a written notice of the intent to
withdraw to OSHA.
XIII. Signatories
Leo Edwards
Acting Area Director
USDOL/OSHA
Norfolk Area Office |
Malcolm P. Branch
President
Virginia Ship Repair Association, Inc. |
Date: _______________________________ |
Date: _______________________________ |
APPENDIX A
| Serial No.__________ |
SAFETY & HEALTH SELF ASSESSMENT CHECKLISTS
VIRGINIA SHIP REPAIR ASSOCIATION, INC. |
These Safety and Health Self Assessment Checklists were developed by the Virginia Ship Repair
Association, Inc. (VSRA) and are offered to VSRA member companies as a guide only. They are not
intended to supplant any applicable government regulations or specific guidelines for individual
member companies. VSRA members are encouraged to use the checklists to foster safer work practices.
VSRA cannot and does not accept any responsibility for the use or non-use of these safety
checklists.
VSRA gratefully acknowledges the assistance of the members of the VSRA Safety Committee who helped
publish the Safety and Health Self Assessment Checklists.
A. Asbestos Awareness
B. Confined Space Program
C. Diving Operations
D. Fire Prevention and Hot Work
E. Hazard Communication
F. Hearing Conservation
G. Lead and Heavy Metals
H. Rigging and Materials Handling
I. Lockout and / or Tagout
J. Medical Services
K. Portable Tools
L. Powered Industrial Trucks; Aerial Lifts
M. Personal Protective Equipment
N. Respiratory Protection
O. Safety Management
P. Scaffolds
Q. Fall Protection
Reference: 1915.1001
| A 1. |
Does the company train employees about general
asbestos awareness? (Training includes health effects, labeling at barriers, materials, etc.)
__________
|
| A 2. |
Are employees able to recognize the types of
materials that may contain asbestos? Can employees recognize PACM (Presumed Asbestos Containing
Materials)? __________
|
| A 3. |
Are they trained to not disturb suspect materials
until their content is accurately determined? __________
|
| A 4. |
Do you have a resource that is certified to remove
asbestos containing materials such as gaskets, insulation, lagging, wallboard, and flooring?
__________
|
| A 5. |
If your employees conduct bulk sampling, have they
received training as an accredited building inspector for asbestos containing materials according
to EPA rules? __________
|
| A 6. |
Is the content of suspect materials determined by
employees of the prime contractor prior to the start of your work? __________
|
| A 7. |
Do you look to the prime contractor to remove suspect
materials prior to your work? __________ |
Reference CFR 29 1915.7-16, NFPA 306
General
| B 1. |
Does your company have a confined space program?
__________
|
| B 2. |
Does your company train all employees who have to
enter a confined space to recognize the characteristics of a confined space? __________
|
| B 3. |
Does your company train all employees on the hazards
associated with confined spaces? __________
|
| B 4. |
Does your company train all production employees
about the health effects of the hazards (oxygen deficiency, explosive atmospheres, and toxic
atmospheres) that exist in confined spaces? __________
|
| B 5. |
Does your company train all employees on the
atmospheric monitoring and logging requirements of a confined space program? __________
|
| B 5.5 |
Are records of completed tests and inspections kept
on file for a period of at least three months from the completion date of the specific job from
which they were generated? __________ |
Confined Space Entry
The following components of a confined space program pertain to those employees that enter confined
spaces and are in addition to the general training elements listed above.
| B 6. |
Does your company train employees to anticipate and
be aware of the hazards faced during entry? __________
|
| B 7. |
Does your company train employees to recognize the
adverse health effects that may be caused by the exposure to the hazard? __________
|
| B 8. |
Does your company train employees to know what
personal protective equipment is needed for safe entry into and exit from the space? __________
|
| B 9. |
Are all confined spaces initially inspected by a SCP
or certified safe for entry / safe for hot work by a certified marine chemist? __________
|
| B10. |
Are all confined spaces checked by a shipyard
competent person as often as specified on the marine chemist certificate prior to entry?
__________
|
| B11. |
Are employees required to inspect the work area after
entry for spills, leaks, and combustible materials prior to the start of hot work? __________
|
| B12. |
Are all gas hoses and gas leads removed from the
confined space and enclosed spaces at breaks and at the end of the shift? __________
|
| B13. |
Are supervisors required to make frequent checks of
personnel working in confined spaces? __________ |
The following questions pertain to Shipyard competent persons.
Reference: 29CFR1915.7
| B14. |
Has the company designated one or more competent
persons or does a Marine Chemist perform tests or inspections which require a competent person?
__________
|
| B15. |
Do the competent persons meet the criteria set forth
in 1915.7 (c)? __________
|
| B16. |
Is a list maintained that includes the name of each
competent person and the date of last training? __________ |
Reference: 29 CFR 1910.400-440
| C 1. |
Does your company perform diving operations or
contract companies to perform diving operations? __________
|
| C 2. |
Does the dive team consist of a minimum of three
personnel? Is one of the dive team personnel designated in writing as the Designated Person in
Charge? __________
|
| C 3. |
Do all dive team personnel have the training and / or
experience necessary to complete their assigned duties as a dive team member? __________
|
| C 4. |
Do all dive team personnel have a current and valid
First Aid and CPR certification from a nationally recognized organization? __________
|
| C 5. |
Is the diving equipment in use appropriate for the
task? __________
|
| C 6. |
Have all breathing gas supply hoses, compressors, air
receivers, and depth gauges been tested in accordance with the standard, and the results recorded
in a maintenance log? __________
|
| C 7. |
Are two-way voice communications provided for all
surface-supplied diving operations? __________
|
| C 8. |
Has the Designated Person in Charge completed an
evaluation for the presence of hazardous energy to include differential pressure? Have procedures
been completed by the Designated Person in Charge to control any hazardous energy which may effect
the safety of the diver? __________
|
| C 9. |
Has the Designated Person in Charge notified all
nearby vessels and facilities of the impending dive operation so that their activities will not
affect the safety of the diver? __________
|
| C10. |
Has the dive flag “Code Alpha” been hoisted to signal
vessels in the vicinity of the diving operation? __________
|
| C11. |
Are the following maintained at the dive location?
- Safe Practices Manual containing dive procedures, checklists, and emergency procedures
__________
- Emergency Phone Numbers __________
- First Aid Supplies & Bag-Type Manual Resuscitator __________
- First Aid Handbook or equivalent __________
- Record of Dive __________
|
| Fire Prevention & Hot Work |
Reference: 29 CFR 1915.7 - 57
| D 1. |
Does your company have procedures in place addressing
fire prevention and hot work? __________
|
| D 2. |
Do company procedures mandate an inspection of hot work sites to verify the removal or
protection of combustibles? __________
|
| D 3. |
Are positive measures taken during all hot work to confine all sparks, slag and heat?
__________
|
| D 4. |
Are all cutting torch gas leads shut off at some point outside of a confined/enclosed space
when a torch will be left unattended? __________
|
| D 5. |
Are gas hoses removed from confined spaces and enclosed spaces overnight, at shift changes and
anytime the torch is removed from the hoses? __________
|
| D 6. |
Are fire watches trained and assigned to both (all) sides of a bulkhead or deck being welded
and required to remain on station for 30 minutes afterwards to ensure no possibility of fire exists?
__________
|
| D 7. |
Are fire watches required to have a properly sealed fire extinguisher ready for instant use?
__________
|
| D 8. |
Are fuel gas and oxygen manifolds maintained either on the pier or on the weather decks of
ships being worked? __________
|
| D 9. |
Are flammable/combustible preservative coatings
removed in the way of welding or hot work? __________
|
| D10. |
Are flammable liquids required to be kept in closed
containers when not actually in use? __________
|
| D11. |
Is mechanical ventilation mandated for all hot work
conducted within a ship? __________
|
| D12. |
Are a ‘Safe for Workers, Safe for Hot Work’
inspections and/or certification required prior to all hot work in confined spaces? __________ |
Reference: 29 CFR 1910.1200.
| E 1. |
Does the company have a written Hazard Communication
(HAZCOM) Program? __________
|
| E 2. |
Who is designated as responsible for the program or
its included elements? __________
|
| E 3. |
Do you have a complete list of hazardous chemicals to
which an employee might be exposed? __________
|
| E 4. |
Is this list kept by the work area or in a
centralized form at some location? __________
|
| E 5. |
How do you provide for remote site locations?
__________
|
| E 6. |
Where are Material Safety Data Sheets (MSDS)
maintained? __________
|
| E 7. |
Have your employees been trained in this program?
__________
|
| E 8. |
How often is refresher training provided? __________
|
| E 9. |
Are there provisions in your training for?
- Non-routine tasks? __________
- Other contractor or subcontractor notification at multi-employer sites? __________
|
| E10. |
Are all containers properly labeled? __________
|
| E11. |
Do labels contain the following information?
- Identification of contents? __________
- Hazard Warnings? __________
|
Reference: 29 CFR 1910.95
| F 1. |
Does the company have a Hearing Conservation Program
for employees who are or may be exposed to an 8-hour time-weighted average (TWA) that equals or
exceeds 85 decibels? __________
|
| F 2. |
Who is designated as responsible for the program?
__________
|
| F 3. |
Is workplace noise monitoring conducted to determine
who needs to be in the program? __________
|
| F 4. |
For those in the program are baseline and annual
audiograms conducted? __________
|
| F 5. |
Is hearing protection required and provided where
noise exposure equals or exceeds 85 db? __________
|
| F 6. |
Is a training program in place which covers, on at
least an annual basis, the effects of noise and the use of protectors? __________
|
| F 7. |
Are noise exposure records maintained for two years?
__________
|
| F 8. |
Are audiometric test records maintained for the
duration of employment? __________ |
Reference: Lead (1910/1915.53, 1018, 1025, and 1027)
Heavy metals (various)
| G 1. |
If your work involves the removal/disturbance of
surface coatings, does your company have a written Lead Program that meets the requirements of
1910.1025? __________
|
| G 2. |
Is your written program readily available? __________
|
| G 3. |
Is grit material analyzed as to content prior to use?
__________
|
| G 4. |
Does the company provide employees training in
general lead awareness? __________
Does training include health hazards, postings of barriers and materials? __________
|
| G 5. |
Are your employees trained in the recognition of potential lead containing materials/coatings?
__________
|
| G 6. |
Are suspect materials analyzed prior to the start of
work activities that could create harmful lead levels? If your employees are sampling suspect
materials, are they properly trained? __________
|
| G 7. |
Are employees trained to not disturb suspect material
until they have been analyzed for lead content? __________
|
| G 8. |
Does the company have programs in place that address
exposure to other heavy metals, such as cadmium (1915.1027), arsenic (1915.1018) and hexavalent
chromium? __________
|
| G 9. |
Does the company’s policy on hotwork on preservative
coatings comply with the requirements listed in 1915.53? __________ |
| Rigging and Materials Handling |
Reference: 29 CFR PART 1915 Subpart G
| H 1. |
Does your company perform rigging and/or materials
handling operations? If yes, are your employees trained in safe lifting procedures? __________
|
| H 2. |
Is all gear and equipment used for material handling
physically inspected at the beginning of each shift? __________
|
Chains and chain slings 1915.112
|
| H 3. |
Are chain slings being used? If so, do they bear an
indication of the month in which it was last thoroughly inspected? __________
|
Shackles and hooks 1915.113 (b) (1)
|
| H 4. |
Is there a certification record being maintained and
kept readily available for testing of hooks where manufacturers weight recommendations are not
available? Does it include the date of weight test, the signature of the person who performed the
test, and an identifier for the hook tested? __________
|
Chain falls and pull-lifts 1915.114
|
| H 5. |
Are chain falls and pull-lifts clearly marked to show
the capacity? __________
|
| H 6. |
Are chain fall hooks moused with a safety latch?
__________ |
Reference: 29 CFR 1910.147
| I 1. |
Does the company utilize equipment/procedures
requiring a lockout / tagout program? __________
|
| I 2. |
Does the company maintain a Written Lockout/Tagout
program consisting of energy control procedures, employee training, and periodic inspections?
__________
|
| I 3. |
Are locks provided to authorized persons and required
to be used for no other use than Lockout? __________
|
| I 4. |
Are all personnel trained to understand and respect
the Danger tags associated with Lockout/Tagout? __________
|
| I 5. |
Are periodic inspections of the Energy Control
Program conducted on at least and annual basis? __________
|
| I 6. |
Are lockout devices other than locks provided to
employees to lockout specific devices, such as; group lockout devices, valve devices or circuit
breaker devices? __________
|
| I 7. |
Do you work aboard Navy ships? If yes, are employees
trained in the requirements of the Navy’s Tagout system? __________ |
References:
29 CFR 1915.98 First Aid
46 CFR Part 40 Department of Transportation Drug & Alcohol
46 CFR Part 16 U.S. Coast Guard Drug & Alcohol Testing
41 USC §701 Drug Free Workplace Act of 1988
29 CFR 1904 Recording and Reporting of Occupational Injuries & Illnesses
| J 1. |
Is your company required to comply with the Drug Free
Workplace Act as a result of receiving $25,000 or more from federal contracting? __________
|
| J 2. |
Do you require pre-employment drug screening?
__________
|
| J 3. |
If your firm currently performs drug screening, what
drugs of abuse do you test for? __________
|
| J 4. |
Does the company perform random drug screening on
“safety sensitive” or high-risk job classifications? __________
|
| J 5. |
For the hypothetical situation where a company
employee is suspected of using or possessing illegal drugs on the work site (for example a drug
dog alert or uncharacteristic behavior), describe your company’s response. __________
|
| J 6. |
Do you have people trained in first aid and CPR?
__________
|
| J 7. |
Is a first aid kit available and maintained at each
work site? __________
|
| J 8. |
Do your employees know what to do in the event of a
work-related injury? __________
|
| J 9. |
Do you maintain an OSHA 300 log? __________ |
Reference: 29 CFR 1910.241 – 244, 334
| K 1. |
Does the company use portable tools? __________
|
| K 2. |
Does the company have a training program that
includes the safe use of portable tools? __________
|
| K 3. |
Are portable tools inspected or safety checked prior
to issue? __________
|
| K 4. |
Are portable grinders with abrasive wheels greater
than 2” issued with wheel guards and manufacturer-provided handles in place? __________
Are employees required to keep guards in place during use? __________
|
| K 5. |
Is use of compressed air for cleaning or blow-down
limited to situations where it can be and is regulated to less than 30 psi? __________
|
| K 6. |
Are all portable electric tools which require
grounding provided with a continuous ground? __________
|
| K 7. |
Are portable tool cords and electrical extension
cords inspected for cuts in the insulation or loose connections prior to use in any shift?
__________
|
| K 8. |
Are pneumatic air hoses inspected prior to use and
checked for leaks, while in use? __________
|
| K 9. |
Are Chicago type couplings wired together? __________
|
| K10. |
Is the PPE appropriate for use with specific tools
required to be used and is it provided (e.g. gloves with sharp edges or face protection with
grinders)? __________ |
| Powered Industrial Trucks; Aerial Lifts |
Reference: 29 CFR 1910.178
8 CCR § 3668
29 CFR 1910.67
| L 1. |
Does the company use powered industrial trucks and
aerial lifts? __________
|
Forklifts
|
| L 2. |
Has the employer implemented a training program?
(1910.178(l)(2)) __________
|
| L 3. |
Does the employer have a training program for
operating? (1910.178(l)(3)) __________
|
| L 4. |
Has the employer certified that each operator has
been trained and evaluated? Certification shall include name of operator, date of training, date
of evaluation and identity of person(s) performing training or evaluation? (1919.178(l)(6))
__________
|
| L 5. |
Does the employer have a refresher training and
evaluation program? (1910.178(l)(4)) __________
|
| L 6. |
Are operators reevaluated at least every three years?
(1910.178(l)(4)iii) __________
|
| L 7. |
Are operators required to use seat beats where
provided? __________
|
| L 8. |
Are vehicles inspected daily before use?
(1910.178(q)(7)) __________
|
Aerial Lifts
|
| L 9. |
Are all aerial lift operators trained in safe
operating procedures? (1910.67) __________
|
| L10. |
Are employees required to wear safety harnesses and
lanyards while operating a boom type aerial lift? (1910.67) __________
|
| L11. |
Have employees been instructed in proper attachment
point of a lanyard? __________
|
| L12. |
Have employees been instructed to wear life vests
when working in aerial lift basket over water? __________
|
| Personal Protective Equipment |
Reference: 29CFR Parts 1910 & 1915 as indicated
| M 1. |
Has the employer completed the required workplace
hazard assessment to determine if hazards are present or are likely to be present? (1915.152)
__________
|
| M 2. |
Are eye or face protection devices provided and worn
where there is a danger of flying particles or corrosive materials? (1915.153) __________
|
| M 3. |
Are approved safety glasses required to be worn at
all times in areas where there is risk of eye injuries such as punctures, abrasions, contusions or
burns? (1915.153) __________
|
| M 4. |
Are employees who need corrective lenses (glasses,
contact lenses) in working environments with harmful exposures, required to wear only approved
safety glasses, protective goggles, or to use other medically approved precautionary procedures?
(1915.153) __________
|
| M 5. |
Are protective gloves, aprons, shields, or other
means provided against cuts, corrosive liquids and chemicals? (1915.157) __________
|
| M 6. |
Are hard hats provided and worn where danger of
falling objects exists? (1915.155) __________
|
| M 7. |
Is appropriate foot protection required where there
is risk of foot injuries from falling or rolling objects, or objects piercing the sole? (1915.156)
__________
|
| M 8. |
Are all reissued protective equipment maintained in a
sanitary condition and ready for use? (1915.152) __________
|
| M 9. |
Do you have eye wash facilities and a quick drench
shower within a work area where employees are exposed to injurious corrosive materials? (1910.151)
__________
|
| M10. |
Where special equipment is needed for electrical
workers, is it available? (1910.335) __________
|
| M11. |
Are adequate work procedures, protective clothing and
equipment provided and used when cleaning up spilled toxic or otherwise hazardous materials or
liquids? (1910.120 (g)) __________ |
Reference: 29 CFR 1910.134
| N 1. |
Does the company use respiratory protection?
__________
|
| N 2. |
Does the company have a written Respiratory
Protection Program? __________
|
| N 3. |
Who is designated as the Program Administrator or
Manager? __________
|
| N 4. |
Have fit test personnel been themselves trained in
proper fit procedures? __________
|
| N 5. |
Are different types and sizes of respirators
available in order to establish a comfortable and effective fit? __________
|
| N 6. |
Is the Medical Evaluation Questionnaire of 29 CFR
1910.134 Appendix C used prior to respirator fit testing? __________
|
| N 7. |
Do you have a Physician or other Licensed Health Care
Professional (PLHCP) who evaluates personnel prior to fit testing? __________
|
| N 8. |
What are your requirements relative to facial hair
and respirator use? __________
|
| N 9. |
Is training and fit testing provided prior to use and
at least annually thereafter? Does training include proper use, wear, care, storage, cleaning, and
limitations? __________
|
| N10. |
What is your change-out procedure for filters and
cartridges? __________
|
| N11. |
Upon what do you base change-out guidance for
cartridges which do not have an end of service life indicator? __________
|
| N12. |
What type of fit test do you conduct? Quantitative or
Qualitative? __________
|
| N13. |
What is your policy with respect to personally owned
respirator use on the job? __________
|
| N14. |
What cleaning procedures, if any, are in effect for
reissued respirators? __________
|
| N15. |
Are any respirators maintained for emergency use and
how often are they inspected? __________
|
| N16. |
Does your company use any supplied air respirators?
__________
|
| N17. |
Is grade D breathing air supplied? __________
|
| N18. |
Is fit testing protocol performed using 1910.134 or
manufacturer’s instructions? __________ |
Reference: 29 CFR 1910.241 – 244, 334
| O 1. |
Does the company have a written safety policy?
__________
|
| O 2. |
Is a safety manager or designated technician
employed? __________
|
| O 3. |
Are periodic safety meetings, gangbox or tailgate
sessions held with employees? __________
|
| O 4. |
Is first line supervision responsible for the safety
of employees assigned to them? __________
|
| O 5. |
What is the company’s procedure for dealing with a
report of a safety violation at another contractor’s site? __________
|
| O 6. |
Do you require that your subcontractors comply with
the same safety rules to which you are held? __________
|
| O 7. |
Do you have a program for New Employee Orientation
that includes all job related safety concerns? __________
|
| O 8. |
Are accidents and incidents investigated promptly
with reports forwarded to your management and to the prime contractor for whom you are working?
How long after the accident should one expect to receive such a report? __________
|
| O 9. |
Are lessons learned from accidents / incidents
communicated to other supervisors and workers within your organization? __________
|
| O10. |
Do you require a subcontractor supervisor
investigation form to be submitted in the event of an accident / incident at your site? __________ |
Reference: 29 CFR 1915 & 1926
| P 1. |
Is scaffolding erected & dismantled under the
supervision of a competent person? (1915.71(b)(7)) __________
|
| P 2. |
Are the scaffolds maintained in a safe secure
condition? (1915.71(b)(5)) __________
|
| P 3. |
Is scaffolding constructed in accordance with
recognized principles of design and accepted standards? (1915.71(b)(1)) __________
|
| P 4. |
Are toe boards installed where needed to prevent
tools and materials from falling on persons below? (1915.71(j)(5)) __________
|
| P 5. |
Where required, are toprails and midrails utilized?
(1915.71(j)(1)) __________
|
| P 6. |
Are scaffolds and their support capable of supporting
the load with a safety factor of not less than 4? (1915.71(b)(1)) __________
|
| P 7. |
Does access to scaffolds consists of well secured
stairways, cleated ramps, fixed or portable ladders? (1915.71(k)(1)) __________
|
| P 8. |
For marine hanging staging, contact VSRA for
assistance. __________ |
Reference: 29 CFR 1915 § 71-74, 91, 152, 158-159
| Q 1. |
At what height above the deck below are personnel
required to wear Personal Fall Arrest Systems (safety harnesses with lanyards)? (1915.159)
__________
|
| Q 2. |
Does the company provide safety harnesses and
lanyards for unguarded work situations? (1915.152) __________
|
| Q 3. |
Are personnel trained in the use of safety harnesses
and lanyards before use? (1915.159) __________
|
| Q 4. |
Are personnel working near unguarded edges over water
provided with and required to properly wear personal flotation devices? (1915.73 & 1915.158)
__________
|
| Q 5. |
If ship lifeline removal is required in the course of
work, what fall protection is required? (1915.71(j)) __________
|
| Q 6. |
Where deck plates or false decks are removed, what
minimum planking is required? (1915.73) __________
|
| Q 7. |
Are employees visually restricted by blasting hoods,
welding helmets, and burning goggles required to work from scaffolds and not from ladders?
(1915.74) __________
|
| Q 8. |
Are all hoses, lines and leads elevated, tied up, or
covered with planks where they might cause a trip hazard? (1915.91) __________
|
| Q 9. |
Are work areas kept clean of debris such as welding
rod tips, bolts, nuts, flashlight batteries and the like? (1915.91) __________
|
| Q10. |
Is ladder safety covered in employee training or
orientation? (1915.72) __________
|
| Q11. |
For hopper platform fall protection, contact VSRA for
assistance. __________ |
Appendix B
VSRA Member Participation in the VSRA and OSHA Partnering Program to Protect Shipyard Workers in
Safety and Health Matters |
This company, ______________________, hereby voluntarily agrees to participate in the Virginia Ship
Repair Association and Occupational Safety Health Administration Partnering Agreement dated December
19, 2006.
By signature below we indicate our intent to participate in this partnership and that said company:
- Has not been cited by the Norfolk Area Office within the past three (3) years for alleged
violations classified as “repeated” and/or “willful.”
- Will ensure employee training in the program (including supervisor personnel) utilizing VSRA
supported safety and health training programs or equivalent training.
- Has a comprehensive written safety and health program in place, which is at least equivalent to
the criteria referenced in Section VI, Paragraph A.6 as the minimum established criteria for
participation, including implementation of policies and procedures to ensure that safety rules and
procedures are enforced at their work sites.
- Will complete Safety & Health Assessment (Appendix A) upon entry into partnership with review and
certification by President/CEO that deficiencies have been corrected.
- Has policy and procedures that hold line supervisors and employees accountable for following
established safety and health rules and OSHA regulations.
- Provides the level of training required by OSHA regulations to its employees either through VSRA,
its own training personnel or other consultant/trainers.
- Will provide annual safety related data or statistics to the VSRA office by the 1st of March for
the previous year concerning man-hours worked, lost day work injuries, accident records and training
hours for employees. This data will be used to determine primary causes of injury and illness among
participants in order to develop training, sound operating procedures, and abatement methods.
| ______________ (Date) |
_______________________________________
(Print – Name of Authorizing Official)
_______________________________________
(Print – Title of Authorizing Official)
_______________________________________
(Authorizing Official’s Phone Number)
_______________________________________
(Authorizing Official’s Email Address) |
Appendix C
Annual Partnership Evaluation Report
Cover Sheet |
| 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 |
| 2006 |
|
|
|
|
|
| 2007 |
|
|
|
|
|
| 2008 |
|
|
|
|
|
| Total |
|
|
|
|
|
| Three-Year Rate (2006-2008) |
|
|
|
|
BLS National Average for 2005 |
|
|
6.0 |
| Baseline |
|
|
|
|
6.0 |
*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) |
|
|
|
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