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Sands Bethworks Project

Strategic Partnership Agreement

Between

Occupational Safety and Health Administration
Allentown Area Office

And

PA/OSHA Consultation Program
at
Indiana University of Pennsylvania

And

Sands Bethworks Gaming LLC

Partnership - An OSHA Cooperative Program
 
I. Scope/Background

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, Region III of the Occupational Safety and Health Administration ("OSHA") and Sands Bethworks Gaming LLC (Sands) have agreed to implement an OSHA Strategic Partnership (OSP) during construction of the Sands Bethworks Project. OSHA and the Sands are entering into this Partnership to foster a safe and healthful workplace for employees through labor, management and government cooperation as prescribed within the terms and conditions outlined in this agreement.

The Sands is building a state of the art facility which will include a 300-room hotel, 200,000 square feet of retail space, 3,000 slot machines, a multi-purpose meeting and convention area, and a variety of dining, shopping and entertainment options.

Sands Casino Resort Bethlehem will be a mix of old and new. It is being built on the site of the historic Bethlehem Steel, and will incorporate many of the remaining historical elements of the famed plant. For example, the massive ore crane will be part of the casino design and will serve as a reminder of the "old days" when visitors drive under it as they approach the brick, steel, and glass porte cochere. Design elements such as exposed steel, back-lit perforated metal screens and a soaring, transparent glass atrium will be featured within a number of existing buildings.

The goal of this program is to develop a contractor/government partnership that will encourage contractors to improve their safety and health performance, assist them in doing that, strive for the elimination of serious accidents and recognize those contractors with exemplary safety and health programs. Under the Partnership, the contractors expect that OSHA will acknowledge superior performance by providing timely responses to requests for information and requests for clarification of OSHA standards as resources allow.

This agreement between the Sands and OSHA is expected to result in decreased serious injuries and illnesses and fatalities for the site and improve existing safety and health programs. It provides incentives to contractors that voluntarily participate in the Sands Bethworks Project Partnership and demonstrate implementation of effective safety and health programs, for example, technical assistance from OSHA and opportunities for penalty reductions. This agreement will not in any way affect employees’ ability to exercise rights under the OSH Act and OSHA regulations, including walk-around rights.

II. Identification of Partners

The primary participants in this Partnership are,
  1. Sands Bethworks Gaming LLC (Sands)
  2. Occupational Safety and Health Administration, Allentown Area Office ("OSHA")
  3. Pennsylvania OSHA Consultation at Indiana University of Pennsylvania ("PA OSHA Consultation")
III. Project Overview

Over the life of the project contractors and subcontractors will employ approximately 1200 or more individual construction tradespersons at peak construction. The complete work will include, but not be limited to: site construction, concrete, excavation work, pile foundation installation, structural steel and miscellaneous metal work, pre-cast curtain wall, road work, electrical, masonry, mechanical/plumbing, rebar installation, caissons, cranes and lifts use and painting.

IV. Goals, Strategies, Measures

The partnership’s goal is to reduce injuries and illnesses and fatalities through a cooperative relationship between the Sands and OSHA. This goal will be accomplished by implementing and following the plan outlined below and evaluating these actions as indicated:
  1. Develop, implement and maintain effective and comprehensive safety and health programs in accordance with OSHA’s 1989 Safety and Health Program Management Guidelines or its equivalent.
     
      Sands agrees to complete a self-audit and an evaluation of contractors and subcontractors’ safety and health programs using Appendix B (or equivalent).

      OSHA will evaluate Sands, contractors and subcontractors safety and health programs prior to and during the OSHA non-enforcement verification inspection using Appendix B (or equivalent) and will observe whether the safety and health management systems in place are adequately protecting employees, and being implemented in accordance with this Partnership agreement.
  2. Strive to achieve participant recordable illness and injury rates below the national average for the construction industry. A partnership goal is to keep the DART rate (cases with days away from work, job-transfer, or restriction) below the national average for the most recent year published for NAICS(1) 236, which is 2.6 for the year 2006. The partnership goal is to further reduce this level of recordable injuries annually by at least 4% for the duration of the partnership.
     
      Identify and correct primary causal factors in worker injuries and illnesses.

      Establish systems to identify and correct accidents and nears misses.

      OSHA will meet at least quarterly with Sands to examine the injury and illness experience of the partnership’s participants and to make corrections and adjustments as needed.

      DART rates and injury and illness experience will be evaluated through review of the OSHA 300 log(s) and any other relevant accident/incident reports.
V. Statement of Agreement

OSHA agrees to:
  1. Help identify programmatic needs at this site by reviewing the documented safety and health management system and providing practical guidance for implementation. The review will be performed by the project Safety and Health Manager and an OSHA Compliance Specialist (CAS or CSHO).
  2. Help identify, through the review of OSHA 300 logs, accident or near miss reports, primary causal factors in injuries and illnesses, in particular the four top hazards at this site, and recommend the appropriate corrective actions.
  3. Provide information on training resources including available OSHA Training Institute courses and information on other available sources of training.
  4. Assist partners in assessing OSHA interpretations and clarifications as to the meaning and application of OSHA standards and policy.
  5. Participate in training sessions and meetings as resources permit.
  6. Designate an experienced OSHA Compliance Specialist (CAS or CSHO) to serve as a resource and liaison person for the partnership.
  7. Meet with Sands quarterly to review partnership issues and to examine updated DART rates and the focused four injury and illness experiences of Sands and its contractors at this site. OSHA shall provide feedback on any noted incident trends and patterns.
Sands agrees to:
  1. Serve as a safety resource in support of all of the project’s contractors and subcontractors.
  2. Provide notice to all contractors and subcontractors that the Sands Bethworks Project is subject to this strategic Partnership with OSHA. All employees will be informed of the Partnership and provided a fact sheet during orientation. (Appendix A).
  3. Administer the overall Partnership program including, but not limited to, the initial contact and evaluation of contractor and subcontractor applications to determine whether the contractor meets the criteria specified within this Partnership initiative under Section VI, Contractor Eligibility.
  4. Notify the Allentown OSHA Area Office on a regular and recurring basis of the names of the contractors and subcontractors that have pledged to participate in the OSHA-Sands Bethworks Project Partnership agreement.
  5. Maintain a dedicated competent Site Safety and Health Coordinator available to assist contractors and subcontractors with all safety and health issues.
  6. Act as liaison for contractors and subcontractors with OSHA.
  7. Offer on-going information on safety or health topics of importance for contractors and subcontractors, especially on the focused four construction hazards.
  8. Maintain a site injury and illness log of all injuries and illnesses reported by all contractors and subcontractors.
  9. Meet with OSHA quarterly to examine the injury and illness experience of the Partnership’s participants and to make corrections and adjustments as needed.
  10. Manage the following site safety or health issues to reduce the potential for injury or illness in accordance with this Partnership agreement:

      emergency action plan,

      hazard communication plan and inventory of site chemicals reported by contractors and tier subcontractors, crane(s) inspections and operator training/certification,

      fall protection plan and perimeter guards,

      personal protective equipment, including equipment specified by NFPA 70 E, where applicable.
Sands and its contractors and subcontractors agree to:
  1. Apply all relevant components of their respective comprehensive safety and health programs to the Sands Bethworks Project. These programs shall include:
    1. Analysis of new and acquired work, materials, chemicals, and equipment before major construction activity begins to determine potential hazards and to plan for their prevention or control.
    2. Routine examination and analysis of hazards associated with individual jobs, processes, or phases of construction.
    3. Routine self-inspections and hazard abatement.
    4. A system for project workers to notify management, without fear of retaliation, about conditions that appear hazardous.
    5. A system for investigating accidents and near-misses, including procedures for guidance, reports of findings and the tracking of hazard correction to completion.
    6. A system to analyze trends through a review of site injury and illness data, and the hazards identified through inspections so that patterns of common causes can be identified and eliminated.
  2. Strive for compliance with all current OSHA standards by constant monitoring of the site.
  3. Implement and enforce a 6 foot fall protection policy.
  4. Evaluate and inspect all cranes on site in accordance with OSHA standards, manufacturer and design specifications.
  5. Have supervisors provide visible leadership in implementing the safety and health program. This includes:
    1. Supervisors establishing clear lines of communication with project workers.
    2. Supervisors setting an example of safe and healthful behavior.
    3. Creating an environment that allows project workers access to their top management and for contractor management to have access to the prime contractor’s management, and;
  6. Report all site injuries and illnesses to Sands immediately so that the site injury and illness log may be accurately maintained.
  7. Report to the Sands Project Safety and Health Manager all program deficiencies or damage to protective equipment, specifically site fall protection, immediately upon discovery and to take appropriate interim protective measures for protection of their employees.
  8. Contractors and subcontractors will submit to Sands initial and updated records of their site recordable injuries and illnesses, first-aid incidents and Root Cause investigation findings.
  9. In accordance with the Sands Bethworks Gaming and Retail Complex Safety Plan (Section 1.0 - Contractor Safety Responsibilities) contractors and subcontractors must have a person on site that is responsible for, possesses the authority over, and is capable of effectively implementing the site safety and health program.
  10. In accordance with the Sands Bethworks Gaming and Retail Complex Safety Plan (Section 1.0 - Contractor Safety Responsibilities) all contractors and subcontractors must submit a site-specific safety plan that is specific to the hazards their employees will potentially be exposed to while conducting work on the project. The Sands Safety Manager will conduct an assessment of the plans with consideration for the following:
    1. the comprehensiveness of the program
    2. the degree to which it has been implemented
    3. the presence of competent persons as required by relevant standards
    4. the means by which the program is enforced
  11. Verify that a comprehensive written safety and health program exists or that it will be implemented prior to starting work, which is at least equivalent to the criteria referenced herein, including the contractor’s implementation of policies and procedures to ensure that safety rules and procedures are enforced at the site.
  12. Certify that their policy and procedures hold supervisors and workers accountable for following established safety and health rules and OSHA regulations.
  13. Ensure that employee training covers applicable site hazards and the means to correct them, as well as pertinent standards and regulations. Provide appropriate safety information and training to non-English speaking employees in their native language.
  14. Provide safety related data or statistics, as requested, concerning such issues as man-hours worked, lost work day injuries, accident records and OSHA inspection results. Sands will provide a summary of and analysis of pertinent safety and health related information for review by OSHA. The purpose of such summary information will assist in preparing an annual report necessary for the evaluating the merits of the program and making recommendations for continuous improvement.
PA OSHA Consultation agrees to:
  1. As resources permit, meet with Sands and OSHA, quarterly, to review partnership issues and to examine updated DART rates and the focused four injury and illness experiences of Sands and its contractors at this site. PA OSHA Consultation shall provide feedback on any noted incident trends and patterns.
     
  2. PA OSHA Consultation will strive to ensure that eligible (2) contractors and subcontractors who request services from the OSHA funded free consultation program through their prime contractor, Sands, will receive priority service. This service is part of the PA OSHA Consultation program which can be reached at 1-800-382-1241.
VI. Contractor Eligibility

Contractors and subcontractors wishing to take advantage of this opportunity to partner with OSHA must:
  1. Sign a Support and Cooperation Pledge Agreement (Appendix C) with Sands indicating their intent to participate in this Partnership initiative and to take steps to adopt into their safety program all of the provisions of the Sands Bethworks Gaming and Retail Complex Safety Plan and this Partnership agreement.
VII. On-Site Verification Inspection and Benefits
  1. Non-enforcement Verification

    In order to assist in measuring the success of this partnership, an initial onsite
    non-enforcement verification inspection will be conducted by OSHA after the signing of this agreement and annually thereafter in accordance with OSHA‘s Directive for the Strategic Partnership Program, OSHA Instruction CSP 03-02-002. The onsite non-enforcement verification will consist of a review of written program elements and an inspection of the work site to assess the implementation of the partnership agreement. If OSHA identifies serious hazards that the Sands refuses to correct, OSHA will make a referral for an enforcement inspection.
    Verifications will be timed and conducted to adequately evaluate employee exposure to worksite hazards.
     
      Employees and/or employee representatives will be provided the opportunity to be involved in all onsite non-enforcement verification inspections. If employee and/or employee representatives cannot actively participate in the site verification inspection, then employee interviews conducted during the non-enforcement verification audits will be utilized to determine the sites progress in meeting the goals and objectives stipulated within this agreement.

      The top causes of injuries and illnesses and their corrections will be determined by OSHA and the Sands Project Safety and Health Manager prior to and during the initial OSHA non-enforcement verification inspection. Corrections will be implemented by Sands. Injury and illness incidence in targeted areas will be evaluated through the OSHA 300 log and any other relevant accident reports.

      Additionally, OSHA will meet with Sands quarterly to review partnership issues and to examine updated DART rates and the injury and illness experience of Sands and its contractors at this site. OSHA shall provide feedback on any noted incident trends and patterns.
  2. Benefits

    OSHA will not issue penalties to participating contractors for other-than-serious violations, provided the violations are immediately abated. OSHA reserves the right to issue penalties for regulatory violations for which mandatory penalties are established pursuant to the policy set forth in the Field Inspection Reference Manual (FIRM).
    When calculating initial penalty reductions, OSHA may provide an additional 10% penalty reduction for good faith to participating contractors provided they have taken steps to adopt into their safety program all of the provisions of the partnership agreement. This additional reduction will not apply to high gravity serious, willful, failure to abate or repeat citations. In cases where a contractor’s total penalty reduction is 100 percent or more, the minimum penalty provisions of OSHA’s FIRM will apply.
VIII. OSHA Inspections

This partnership provides for the immediate response to each allegation of a safety or health hazard brought to its attention by any person. Upon a finding that an allegation is valid, the employer shall promptly abate the hazard.
  1. Non-formal Complaints:

    OSHA agrees that a copy of each non-formal complaint related to the work at the site and filed with OSHA will be forwarded by fax or mail to the Sands Bethworks Project site office. In accordance with applicable law, the identity of a complainant requesting confidentiality will not be revealed. Sands agrees to investigate these complaints, regardless of the employer involved and provide OSHA with a written response as follows:
     
      - non-formal complaints/referrals alleging a hazard: 24 hours
    Failure to meet this time frame, or providing a response determined by OSHA to be inadequate, will place the complaint/referral outside the scope of this partnership and OSHA will respond as it would to any complaint of a similar nature.
     
  2. Formal Complaints and Other Investigations:
    OSHA personnel will continue to conduct investigations resulting from program scheduling, formal complaints, referrals, fatalities, catastrophes, other accidents or significant events. OSHA will also investigate contractors whose employees are exposed to or are creating plain view hazards at this site. 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.
IX. Employee Rights

This Partnership does not preclude employees and/or employers from exercising any right provided under the OSH Act (or, for federal employees, 29 CFR 1960), nor does it abrogate any responsibility to comply with rules and regulations adopted pursuant to the OSH Act.

X. Leveraging

This partnership seeks to leverage the resources of both Sands and OSHA by encouraging contractors to develop safety and health programs, implement them in an effective manner, complete self inspections, and evaluate worksite conditions and near misses to prevent accidents. By combining resources, Sands and OSHA expect to have a greater and more positive impact on safe working conditions at this site than could be achieved otherwise.

XI. Evaluation

A joint evaluation of the partnership will be prepared annually by the partners using 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.

XII. Termination

This agreement will terminate three years from the date of the signing or upon completion of the Sands Bethworks Project. If either OSHA or Sands wishes to withdraw its participation prior to the established termination date, the agreement will terminate upon receiving a written notice of the intent to withdraw from either signatory.

XIII. Primary Contacts

OSHA:
  1. Scott G. Shimandle, Compliance Assistance Specialist, USDOL/OSHA - Allentown Area Office, 850 N. 5th Street, Allentown, PA 18102-1731, Phone (610) 776-0592, Fax (610) 776-1913.
Sands:
  1. Joseph Kock, Safety Manager, Sands Bethworks Gaming LLC, Sands Bethworks, 925 East Second Street, Bethlehem, PA 18015, Phone (484) 892-2281, Fax (610) 866-6217.
PA OSHA Consultation Program:
  1. David Rhodes, Program Director, Pennsylvania OSHA Consultation Program, Indiana University of Pennsylvania, Walsh Hall, Room 210, 302 East Walk, Indiana, PA 15705-1066, Phone (800) 382-1241 (toll-free in Pennsylvania, Phone (724) 357-2561, Fax (724) 357-2385, website
Signature Page Sands Bethworks Project
Strategic Partnership Agreement between OSHA and Sands

All undersigned Parties mutually agree to the terms and conditions of this document and commencement of this Partnership Agreement on this day of February 4, 2009.



 
Jean G. Kulp
Area Director
Allentown OSHA Area Office  



 
Date



 
Matthew Harris
Director of Construction
Sands Bethworks Gaming LLC  



 
Date



 
David Rhodes
Program Manager
PA OSHA Consultation Program



 
Date



 
Joseph Koch
Safety Manager
Sands Bethworks Gaming LLC



 
Date

(1) NAICS refers to the North American Industry Classification System which has replaced the U.S. Standard Industrial Classification (SIC) System.

(2) Eligible means that the contractor or subcontractor is a signatory participant of this agreement and meets the criteria defined by CSP 02-00-002 - Consultation Policies and Procedures Manual, dated January 18, 2008.

 
 
APPENDIX A

Sands Bethworks Project Partnership Fact Sheet
A strategic partnership agreement has been developed jointly by the United States Department of Labor, Occupational Safety and Health Administration Allentown Area Office ("OSHA"), and Sands Bethworks Gaming LLC ("Sands"). The common objective and goal of the program is to develop a contractor/government partnership that encourages all construction contractors to improve their safety and health performance, assist them in doing that, strive for the elimination of serious accidents in the construction industry, and to recognize those contractors with exemplary safety and health programs. The specific impetus behind the agreement is to provide a safe and healthful work environment for workers engaged in construction activities for the project.

Expected outcomes of this partnership include: developing criteria for a model multi-employer worksite safety and health program which specifically identifies the responsibilities of each subcontractor; making safety and health materials available to all subcontractors onsite; planning for safety and health in all aspects of the project; providing visible safety and health leadership; achieving participant recordable illness and injury rates below the national average for the construction industry; and focusing OSHA enforcement activity on those contractors and subcontractors who have little or no regard for the safety and health of their workers.

The agreement provides incentives to contractors and subcontractors who voluntarily improve their safety and health performance. Incentives will include technical assistance from OSHA and opportunities for penalty reductions.

This agreement is consistent with OSHA’s long-range effort to develop a contractor/government partnership approach to safety management. It allows for better use of OSHA resources and for innovation in safety management, and it encourages more participation in the safety process by each stakeholder.
 



 
Jean G. Kulp
Area Director
Allentown OSHA Area Office  



 
Date



 
Matthew Harris
Director of Construction
Sands Bethworks Gaming LLC  



 
Date



 
David Rhodes
Program Manager
PA OSHA Consultation Program



 
Date



 
Joseph Koch
Safety Manager
Sands Bethworks Gaming LLC



 
Date
 
Appendix B

Safety and Health Program Evaluation
  1. Contractor has implemented a comprehensive written safety and health program based on ANSI A10.38-1991 or the OSHA 1989 Safety and Health Program Management Guidelines, and has site specific safety plans for all of the contractor’s work sites.
     
  2. Contractor maintains a copy of its specialty contractor’s safety and health plan, hazard communication plan, and fall protection plan (where applicable) or contractor requires specialty contractor to follow participant’s plan.
     
  3. Contractor has designated safety personnel at each site who conduct documented safety inspections of all work on the contractor’s projects, and through training and experience, can recognize hazards and have authority to take prompt corrective action. Training equivalent to the OSHA 10-Hour Construction Outreach Course is satisfactory.
     
  4. Contractor has trained all field supervisory personnel and has provided additional training for competent persons in such areas as scaffolding, excavation, fall protection, crane operations, etc. (This additional training will be dictated by the type and scope of the work the contractor routinely conducts).
     
  5. Contractor provides a safety and health program orientation for all new employees and trains employees for hazard recognition specific to the contractor’s work sites.
     
  6. Contractor involves employees in safety and health program such as, but not limited to, participation in self-audits, site inspections, job hazard analyses, safety and health program reviews, safety training and mishap investigations.
     
  7. Contractor conducts and documents weekly employee safety meetings.
     
  8. Contractor conducts and documents self-audits.
     
  9. Contractor uses a six-foot fall protection policy.
     
  10. Contractor has a written enforcement program.

Appendix C

PLEDGE TO PARTICIPATE
SANDS BETHWORKS PROJECT
SAFETY PARTNERSHIP

 
Region III of the Occupational Safety and Health Administration (OSHA) and the Sands Bethworks Gaming LLC (Sands) have agreed to the joint implementation of a strategic Partnership Agreement (Partnership) during the construction of the Sands Bethworks Project.

The goal of this Partnership is to encourage cooperation between OSHA, the Sands and contractors to foster a safe work environment for all project employees.

This Partnership will not relieve any contractors from or lessen their safety responsibilities nor change any contractual obligations between the Sands, or trade contractor, nor does it lessen any/all affirmative defenses, legal rights or due process afforded with respect to OSHA enforcement action.

This Partnership will not in any way affect employees’ ability to exercise rights under the OSH Act and OSHA regulation.

This agreement is consistent with OSHA’s long-term effort to develop a contractor/government Partnership approach to safety management. It allows for better use of OSHA resources and for innovation in safety management, and it encourages more participation in the safety process by each stakeholder.
We understand the agreement provides incentives to participating contractors who undertake these actions to voluntarily improve their safety and health performance. Incentives will include technical assistance from OSHA and opportunities for penalty reductions.

Based upon the mutual interest to protect construction workers, the below party pledges both support and cooperation to the OSHA/Sands Bethworks Project Partnership Agreement by agreeing to implement an effective safety and health management system in accordance with the OSHA 1989 Safety and Health Program Management Guidelines (or its equivalent) and utilizing the Sands Bethworks Gaming and Retail Complex Safety Plan outlined in Attachment 1.

_______________________________
Authorized Representative (print/type)

_______________________________
Signature

_______________________________
Title (print/type)

_______________________________
Company Name (print/type)
 
Appendix D

OSHA STRATEGIC PARTNERSHIP PROGRAM
ANNUAL PARTNERSHIP EVALUATION REPORT

Cover Sheet
 
Partnership Name


 
 
Purpose of Partnership



 
Goals of Partnership
Goal Strategy Measure
     
     
     
     
Anticipated Outcomes




 
Strategic Management Plan Target Areas (check one)
Construction   Amputations in Manufacturing  
General Industry      
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 provided for 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 Inspection    
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)
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
2009          
2010          
2011          
Total          
Three-Year Rate (2009-2011)      
BLS National Average for 2006     2.6
Baseline         2.6
Comments








 
*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 (Check one)
Partnership Completed  
Continue/Renew  
Continue with the following provisions:  




 
Terminate (provide explanation)  




 

 
ATTACHMENT 1

Sands Bethworks Gaming and Retail Complex
Safety Plan
An electronic version of this plan (.pdf document) is on file in the Allentown Area Office with the Primary OSHA Contact person.
 
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Page last updated: 02/20/2009