OSHA Strategic Partnerships Program > Region 5

PARTNERSHIP AGREEMENT
BETWEEN
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
TOLEDO AREA OFFICE
AND
AK STEEL CORPORATION'S MANSFIELD PLANT

I. Identify Partners

In a cooperative effort to foster safe and healthful worksites and meet the Occupational Safety and Health Administration's (OSHA) strategic goal of improving the safety, health, and well-being of the nation's workforce, OSHA and AK Steel Corporation's Mansfield Plant have agreed to the joint implementation and are signatories of this partnership.

II. Purpose/Scope

The partners agree to construct a partnership based on mutual respect and trust that leverages the resources of all the parties through the systematic anticipation, identification, evaluation and control of health and safety hazards at AK Steel's Mansfield Plant thereby continuously reducing worker injury and illnesses.

III. Goals/Strategies/Measurements

The primary goal of this partnership is to reduce injuries and illnesses resulting from exposure to workplace hazards. This goal will be accomplished by implementing the following actions and evaluating these actions as indicated:

Develop, implement, and maintain a program geared toward reducing exposures to hazards.
- The effectiveness of this program will be evaluated by examining safety contacts, minutes of safety team meetings, and auditing of Pre-Job Hazard Reviews. The OSHA 300 log will also be evaluated on an annual basis for identification of injury/illness trends and calculation of TCIR, DART, and severity rates.
Increase employee involvement in the safety and health program.
- Employee involvement will be analyzed by reviewing employee participation with safety projects, safety committees/meetings, safety suggestions and workplace audits.
Perform monthly safety audits of all shifts including weekends/holidays to identify and eliminate employee exposure to hazards.
- Review monthly safety audit documents for hazards identified and response time for correcting identified hazards.

IV. Evaluation

A joint evaluation of the partnership will be prepared annually by the partners. The evaluation will be consistent with the latest annual partnership evaluation format provided in Appendix C of the OSPP Directive, CSP 03-02-002.

V. Benefits

OSHA Enforcement Benefits:

When calculating the initial penalty reduction, an additional 10% reduction for good faith beyond those provided in the FIRM where the employer, in implementing the OSP, has taken specific significant steps beyond those provided in the FIRM to implement the Act and achieve a high level of employee protection (see FIRM, Chapter IV.C.2.i.5 [b]). This additional reduction will not apply to high gravity serious, willful, failure to abate or repeat citations. In cases where a partner's total penalty reduction is 100 percent or more, the minimum penalty provisions of the FIRM will apply (see FIRM, Chapter IV.C.2.b).
In the event that a citation with penalty is issued, the Regional Administrator (RA) has the authority to negotiate the amount of penalty reduction as part of an informal settlement agreement.

OSHA Non-Enforcement Benefits:

OSHA personnel may be available for a variety of onsite/offsite activities such as review of the safety and health management system and assistance to develop or improve the system, and guidance in conducting audits and evaluations.
Informational materials such as safety and health brochures, pamphlets, and electronic tools may be available.

VI. Verification

In order to assist in measuring the success of this partnership, an onsite enforcement inspection, including, but not limited to, a review of the safety and health program including review of OSHA 300 logs, employee involvement and tracking of identified hazards to completion, will be conducted annually. Violations of standards, regulations, or the General Duty Clause found during the inspection may result in citations. All employee rights under the OSHA Act will be afforded.

VII. Management and Operation of Partnership

A Partnership Management Team (PMT) will oversee and coordinate the Partnership. The PMT will consist of persons from Toledo OSHA Office, AK Steel, and union representation. The roles and responsibilities of the PMT are as follows:

holding regular meetings/conference calls to ensure the OSP remains on track to meet OSP goal/metrics;
collecting and analyzing data, including the development of the annual written evaluations;
resolving disagreements that arise during the course of the OSP.

VIII. Employee and Employer Rights

This partnership does not preclude employees and/or employers from exercising any right provided under the OSH Act, nor does it abrogate any responsibility to comply with rules and regulations adopted pursuant to the Act.

IV. Term of Partnership

This agreement will terminate on February 28, 2010, which is three years from the date of the signing. If any signatory of this agreement wishes to terminate their participation prior to the established termination date, written notice of the intent to withdraw must be provided to all other signatories.

If OSHA chooses to withdraw its participation in the partnership, the entire agreement is terminated. Any signatory may also propose modification or amendment of the agreement.

X. Signatures

OSHA Jule Hovi, Area Director Toledo OSHA Office	AK Steel Corporation Craig Mauro, General Manager Mansfield Works
AK Steel Partnership Measurements

GOAL	STRATEGY	MEASUREMENT
Reduce injuries and illnesses resulting from exposure to workplace hazards	A) Develop, implement, and maintain a program geared toward reducing hazards	Examine safety contacts Examine safety team meeting minutes TCIR DART Severity rates
	B) Increase employee involvement in the safety and health program	Review employee participation with safety projects, safety committees/meetings, safety suggestions, workplace audits
	C) Perform monthly safety audits of all shifts including weekends/holidays to identify and eliminate employee exposure to hazards	Review monthly safety audits and track the hazards identified and response time for correction of hazards identified.