- IDENTIFICATION OF PARTNERS
The Rush University Medical Center (RUMC) Phase One and Two Transformation
Projects (the Project) are designed to expand and renovate the existing
hospital, and to provide for the demolition of outdated existing buildings.
Phase One of the program includes the construction of a new parking garage and
central energy plant, a new loading dock, a new medical office building, and a
utility/materials management tunnel. Phase Two of the program is addition of the
Atrium East tower. Rush University Medical Center is both the client and general
contractor for the project, which is being delivered under multiple prime
contractors.
The level of activity needed to complete the project on schedule will
necessitate a cooperative effort to assure that a safe and healthy work
environment is maintained at all times. This Partnership will expand OSHA’s
reach into this project, allowing OSHA to work with the companies involved to
promote safety programs, management systems, and work methods utilizing the
latest technologies and the safest available methods. This Partnership supports
the Agency’s Strategic Plan by developing strategies to improve safety and
health in the construction industry.
The partners in this program include:
Rush University Medical Center (RUMC)
Vice President, Office of Transformation
Risk Management Director
Occupational Safety Director
Calumet City Area Office of the Occupational Safety and Health Administration
(OSHA)
Chicago Regional Council of Carpenters
Illinois Onsite Safety and Health Consultation Program / DCEO
Contractors as listed on Appendix A.
(Note: Within this document, the term “Contractor” identifies any company at The
Project under a contractual agreement with RUMC, and the term
“Tier-Subcontractor” identifies any company at The Project under a contractual
agreement with a prime contractor or another subcontractor.)
- PURPOSE and SCOPE
This Partnership represents a voluntary agreement, which affords Rush University
Medical Center and its contractors an alternative to traditional OSHA
enforcement. The purpose of this Partnership is to promote the projects safety
efforts and foster a relationship between OSHA, Rush University Medical Center,
and its contractors and subcontractors working on the project.
- GOALS AND MEASUREMENT
- Injury and Illness rates:
The 2006 Bureau of Labor Statistics (BLS) for Construction (Specialty Trade
Contractors) under the North American Industrial Classification System (NAICS)
code 238000 lists a total recordable case rate of 6.3, and a Days Away from
Work, Job Transfer, or Restriction (DART) rate of 3.5. While RUMC realizes that
accidents, operational mishaps, and injuries can occur, these occurrences are
not considered acceptable. The only acceptable safety performance goal is zero
incidents. Therefore, it is the intent of this Partnership to eliminate
construction fatalities and serious injuries by establishing a foundation of
pro-active measures with a goal of zero injuries and illnesses. We can achieve
this objective through a combination of concerned management, responsible and
knowledgeable supervision, and conscientious well-trained work force acting in a
proactive approach to manage safety.
This will be accomplished by:
- Creating a working relationship between OSHA and the Partnership
participants
- Increasing everyone’s safety awareness and participation in the overall
safety program.
- Promoting a cooperative relationship between labor and management to achieve
a safe worksite.
- Contractors developing and providing training necessary to enhance safety
awareness and proactively addressing job-related hazards.
- Eliminating repeat violations by workers and contractors.
- Developing, implementing and maintaining effective comprehensive safety and
health programs in accordance with industry best practices, 29 CFR 1926, OSHA
interpretations and guidelines, ANSI Standards and the OSHA multi-employer
policy.
- Providing each project with guidelines for uniform implementation of a safety
system that promotes strict compliance with Rush requirements.
- Establishing lines of communication, responsibility and accountability for
the safety system at each worksite.
- Developing safety policies for areas or activities not covered by federal,
state, or local standards.
- Requiring the planning of tasks to identify potential hazards and the methods
that will be used to control identified hazards.
Injury and illness rates will be monitored and measured through a project–wide
log of work- related injury and illness, and comparing them to the total number
of man-hours worked at the project. This data will be compiled through the
Partnership Committee (the committee).
- Safety Programs:
The requirement to develop and maintain a safety program (1926.20 and 1926.21)
consistently ranks among the most frequently violated OSHA construction
standards. The importance of safety programs in the development of a safety
culture at a worksite is well established. This Partnership will require 100% of
the contractors working on this project to have effective safety and health
programs. This will be accomplished through RUMC doing the following:
- Use the project-specific safety program requirements (PSSP) it developed
(which is also required by contract) for Contractors to use as a model for them
to develop their own site-specific programs.
- Require all Contractors to develop and implement a comprehensive
site-specific safety and health program that will comply with the criteria of
the PSSP and OSHA’s safety and health program guidelines.
- Inform and explain to potential Contractors at pre-bid meetings the RUMC’s
safety requirements.
- Review its requirements with contractors at the pre-construction meetings,
and require Contractors to submit their site-specific plans prior to working on
site. The pre-construction meeting will take place only after the Contractor’s
plan has been submitted and considered acceptable.
- Require Contractors to develop and submit a Safe Plan of Action (SPA) prior
to performing tasks.
- Require Contractor work crews to conduct a daily Task Safety Analysis (TSA),
as part of the Contractors SPA requirement.
- Implement a Safety Observation Report (SOR) program that allows individuals
to anonymously report to management and RUMC issues relative to the safe or
unsafe execution of work tasks, or physical characteristics of the work
environment.
- Conduct layered auditing to review matters relative to safety issues at the
project sites.
- Require Contractor personnel to pass substance abuse testing prior to
working on site, attend an RUMC project safety orientation and, attend a Contractor
safety orientation.
- Inform all Contractor personnel that they will be subject to substance abuse
testing for cause and post incident.
- Require all supervisory personnel and designated competent persons to
complete the OSHA 10-Hour hazard recognition course for construction.
- Require all Contractors to provide a qualified safety representative as
required by RUMC.
- Require all Contractors to investigate all non-injury, injury, and property
damage incidents to determine abatement methods for the prevention of future
incidents.
- Require all Contractors to implement a disciplinary program for those
individuals who fail to comply with RUMC safety requirements.
Prime Contractors must submit to the Project Safety Manager (PSM) written
confirmation that each of their tier-subcontractor’s site-specific safety
programs has been reviewed and meets the requirements of the Rush University
Medical Center Construction/Maintenance Contractor Requirements, or that the
tier-subcontractor has adopted the prime contractor’s program and received
training on the same. This written confirmation must also include verification
that the prime contractor’s Safety Representative (SR) will be responsible for
safety issues involving their tier-subcontractors, including weekly audits of
tier-subcontractor worksites and pre-task audits. The prime contractor must
identify the tier-subcontractor’s Safety Representative, who will perform these
duties. These confirmations will be tracked by the Committee to assure that all
contractors have effective safety and health programs.
Completion and review of contractor safety programs will be monitored through
the Project Safety Manager and their duties as chairperson of the “Committee”.
- Safety Audits
This Partnership will implement a comprehensive audit program with a goal of
ensuring that employees are not exposed to serious hazards. The identified
hazards found during these audits will be corrected.
The audit program will work to identify hazards, and focus on critical
activities that generate hazards associated with falls, electric shock, being
caught-in or struck-by equipment or materials. If serious hazards are
identified, immediate correction will be required, or, at the discretion of the
Audit Team, employees will be removed from the hazard until abatement is
completed.
The results of safety audits will be reviewed by the Committee, recorded in the
minutes of the Committee meetings, and tracked until hazards identified are
corrected.
- Training
In addition to any training required by specific OSHA standards or regulations,
and prior to working on the project, all employees will receive jobsite
orientation and training on the RUMC Safety Program. Prime contractors and
tier-subcontractors must also provide to their employees site-specific safety
program training. The training will be documented on the “Employee Information
and Training Checklist” as provided for by the Prime Contractor.
Completion of the jobsite orientation and the required prime contractor /
tier-subcontractor employee training will be tracked by RUMC; with the goal that
100 % of the employees working at the project will receive this training.
In addition, all employees will also attend weekly “tool box” talks conducted by
their Safety Representative, or designee. As resources permit, and upon a formal
request by the PSM, OSHA will conduct specific training for employees, safety
managers, and/or contractor management personnel. RUMC will help facilitate and
sponsor these training sessions, and will recommend additional training sessions
as appropriate.
The number of employees receiving the initial jobsite orientation and additional
training through the Partnership will be measured by the Project Safety Manager
(PSM) and OSHA representative on the Committee.
- PARTNERSHIP EVALUATION
This Partnership will include an annual Partnership evaluation to determine
whether modifications are needed, and to review the status. The evaluation will
be completed by RUMC and its representatives. The evaluation will follow OSHA
Directive CSP 03-02 002 (TED 8-0.2, OSHA Strategic Partnerships for Worker
Safety and Health, Appendix C). All required data to monitor the success of the
Partnership goals will be submitted at least quarterly to RUMC. The evaluations
will be completed annually on the anniversary date of the signing of the
Partnership agreement.
- Benefits
All stakeholders will benefit from this Partnership, and OSHA’s involvement.
Contractors on the project will be eligible for incentives during the
verification inspections, including penalty reductions for OSHA citations (25%
good faith, 15% quick fix); focused inspections; and maximum resolution of
complaints through investigation (phone/fax) in lieu of onsite inspections.
- VERIFICATION
OSHA will conduct two unannounced verification inspections per year during the
life of the Project. These inspections will follow the “Focused Inspection”
protocol and be conducted consistent with the provisions of paragraph IX.H.3 of
OSHA TED 8-0.2 by a compliance officer that is familiar with this Partnership.
Violations of standards, regulations or the General Duty Clause found during
verification inspections may result in citations. Inspections conducted in
response to complaints and referrals will qualify as a verification inspection
if, in addition to addressing the complaint/referral item(s), the compliance
officer completes the focused inspection protocol for the entire worksite. OSHA
agrees that during their focused inspections, no citations will be issued for
alleged violations of a non-serious nature if abated immediately. All employee
rights under the OSH Act will be afforded.
- Management and Operation
The RUMC Partnership Committee (the Committee) will consist of one
representative from each of the partners listed above. The Committee will review
contractor compliance and involvement in the Partnership, analyze jobsite
audits, make Partnership improvements, evaluate Partnership modifications,
achievements, and success, and will ensure that specific safety measurements
comply with OSHA regulations. Specifically, the partners will do the following:
Calumet City OSHA Area Office will:
- Provide a representative for the Committee.
- Monitor the audit process
- Advise and assist the Audit Team.
- Attend a minimum of one Committee meeting every three months.
- Assist with safety and health training, and provide additional technical
assistance.
- Assist in data collection and data review.
- Conduct verification inspections.
RUMC will:
- Develop the site-specific safety manual.
- Designate a Project Safety Manager (PSM) to oversee the project, and serve as
chairperson of the Committee,
- Schedule and conduct monthly safety audits, and monthly Committee meetings.
- Collect and summarize data for the Committee, including a jobsite log of
injuries and illness equivalent to the OSHA 300, a list of tasks requiring a
“competent person” (CP), and identity of the competent persons designated by the
prime or tier-subcontractors, weekly contractor and monthly site audits, and
near-miss reports.
Chicago Regional Council of Carpenters will:
- Appoint a representative to the Committee.
- Participate in the monthly safety audits.
- Attend monthly Committee meetings.
Illinois Onsite Safety and Health Consultation Program / DCEO will:
- Provide a representative for the Committee.
- Attend the Committee meeting and participate in the audit a minimum of once
per
quarter.
- Assist with safety and health training, and provide additional technical
assistance as
resources permit.
- Give priority status to formal requests for “Consultation” services received
from the
Project.
Contractors [including Prime Contractors] (See Appendix A) will:
- Appoint a Safety Representative (SR) to the Committee.
- Participate in the monthly safety audits.
- Attend monthly Committee meetings.
- SAFETY AUDITS
Audit Team
- The Audit Team will consist of the PSM and one representative from each
partner identified in Section II.
- Each month, available members of the Audit Team will conduct an audit of the
worksite. Upon invitation by the PSM, additional Safety Representatives and/or
union stewards from contractors at the site may participate in the monthly
audit.
- Following the audit, the Team will meet to discuss the results of the audit,
safety issues, and any near-miss reports.
- The audits and meetings will be scheduled by the PSM, and will be completed in
a reasonable time frame. The PSM may invite representatives of additional
contractors to attend the post-audit meeting and discuss the audits and hazard
abatement.
- Safety Representatives will ensure that their employees are informed of this
information through weekly toolbox discussions.
OSHA will not play an active role in the onsite audits, but commits to
participate in a minimum of one audit meeting every three months for the
duration of the Partnership. The PSM will forward minutes from the monthly
safety audits to OSHA for its review.
Prior to the monthly site audits, the Safe Plan of Action reports for that day
will be reviewed. Safe Plan of Action, Task Safety Awareness reports and
near-miss reports will be used to target specific areas during monthly audits.
- SITE-SPECIFIC SAFETY PROGRAM (SSSP)
Effective workplace safety and health programs are self-sustaining systems that
encompass at least four main criteria: A) management leadership and employee
involvement; B) worksite analysis; C) hazard prevention and control; and D)
safety and health training. This Partnership supports this ideal as identified
in the goal statements. All contractors are required by RUMC to develop and
submit a comprehensive site-specific safety program.
- SAFETY MANAGEMENT
The SSSP shall require each prime contractor engaged in work activity to have a
designated Safety Representative (SR) onsite. Additional qualifications and
requirements for contractors to have full time SRs will be determined by the PSM
and the SSSP.
Prime contractors have the responsibility for the safety of their
tier-contractors. This provision does not alleviate tier-subcontractors from
their responsibility for the safety of their employees.
- EMPLOYEE INVOLVEMENT AND EMPLOYEE RIGHTS
This Partnership does not preclude employees and/or employers from exercising
any right provided under the OSH Act, nor does it abrogate any responsibility to
comply with rules and regulations adopted pursuant to the Act.
Employees will be involved in the day-to-day implementation of worksite safety.
Contractors will participate in safety audits and briefings, and will ensure
that their employees are kept apprised of safety and health issues on the site.
The SSSP will include a system for employees to report hazards and near misses.
The system to be used will be the Safety Observation Report cards (SOR).
- TERMINATION
This agreement shall be in effect until December 31, 2012. 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 party may also propose modification(s) or
amendment(s) to the agreement.
Other signatories to this agreement may terminate their participation by
providing written notice to all other partners. However, such terminations shall
not dissolve the Partnership. Only OSHA and RUMC may terminate the Partnership.
- Signatures
| _______________________________ |
_______________________________ |
Rush University
Medical Center
Vice President
Office of Transformation |
Rush University
Medical Center
Director – Risk Management |
_______________________________ |
_______________________________ |
Rush University
Medical Center
University Medical Center
Director – Occupational Safety |
Gary J. Anderson
Area Director – OSHA
Calumet City Area Office |
_______________________________ |
_______________________________ |
Thomas L.
Kavicky
Assistant to the Vice President
Chicago Regional Council of Carpenters |
Illinois On-Site
Safety and Health
Consultation - DCEO |
|
|
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