Develop, issue, and communicate S&H Vision Statement and S&H Policy Statement.

Communicate Vision and Policy Statements to all company and subcontractor employees; incorporate into new employee/subcontractor orientation.

Include the vision and policy in bid packages.

Take proactive steps to ensure company and subcontractor employees understand the S&H Vision and Policy Statements.

Ensure policies becomes an integral part of routine activities and decision making during all phases of construction.

Establish a policy requiring company and subcontractor, if applicable, executives, managers, and supervisors to participate and demonstrate leadership in S&H activities.

Continue participation by top executives and managers.

Require subcontractors to adopt and begin implementing leadership policies and increase frequency of management participation in S&H activities.

Continue to ensure total involvement in S&H of all company and subcontractor senior management, supervisors and lead persons.

Develop safety and health budget and commit and ensure utilization of adequate resources.

Establish and implement a policy that integrates S&H into the overall company management planning and budgeting process.

Provide additional resources for S&H activities, including access to certified S&H professionals, if necessary, and licensed health care professionals, and improve integration of S&H into other planning activities.

Continue committing and ensuring the utilization of adequate resources by company and subcontractors.

Ensure integration of S&H in all company and subcontractor planning and budget processes in the company.

Set and communicate annual S&H goals and objectives based on findings from baseline hazard and trend analyses, and S&H perception survey results.

Review progress towards achievement of S&H goals & objectives; establish & communicate new goals, as appropriate.

Require subcontractors to develop goals and objectives consistent with Challenge participation.

Company and subcontractors review, revise, and communicate S&H goals and objectives.

Ensure S&H goals and objectives are routinely considered in company's and subcontractor's activities and programs.

Establish clear lines of communication throughout all aspects of company operations.

Provide reasonable access to senior management on S&H issues.

Maintain clear lines of communication with company and subcontractor employees re: S&H issues.

Continue open dialogue between company and subcontractor management staff and employees.

Develop a S&H accountability plan for managers/supervisors and non-supervisory employees.

Communicate and implement accountability plan.

Assign additional responsibilities to non-supervisory employees as appropriate.

Encourage subcontractors to adopt and begin implementing similar accountability plan or establish equivalent process.

Fully implement accountability system for all company and subcontractor workers, including incorporating S&H responsibilities into job descriptions and performance plans.

Begin measuring performance of S&H responsibilities in annual performance appraisal processes.

Establish a company disciplinary policy for all employees re: compliance with S&H regulation, rules, procedures, etc.

Continue to implement disciplinary plan with an implementation schedule for managers and employees.

Require subcontractors, if applicable, to adopt company disciplinary policy or establish equivalent policies.

Ensure discipline is equally enforced for company and subcontractor employees.

No action required.

Develop a written plan/procedure for conducting annual self evaluations and other evaluations, including a requirement for narrative reports.

Encourage subcontractors to adopt a similar policy or establish an equivalent process.

Company and subcontractors implement systems and written procedures to annually evaluate the S&H management systems.

Company and subcontractors complete at least one annual self-evaluation of the S&H management system.

Complete an evaluation prior to completion of construction.

Conduct S&H Perception Survey for employees and subcontractor employees, if applicable.

Review and respond to survey findings and conclusions.

Conduct follow-up S&H Perception Survey to identify further needed improvements.

Develop an action plan to address findings from the S&H Perception Survey.

Implement steps defined in the company's action plan to improve S&H culture.

Require subcontractors to develop action plan to address findings related to them.

Continue implementing action plan.

Notify all employees of their S&H rights under the OSH Act and inform them of the company's participation in Challenge program. Discuss the VPP principles.

Encourage the reporting of hazardous conditions.

Notify new employees of their S&H rights, company participation in Challenge, & VPP principles.

Incorporate into new employee/subcontractor orientation.

Require the reporting of hazards.

Inform all employees annually of worker rights and include elements in company/project site orientation for new company and subcontractor employees.

Reinforce as appropriate.

Develop a plan and implementation schedule for involving employees in developing a company safety and health program (e.g. S&H teams) and begin involving employees in S&H activities (e.g. safety audits).

Increase participation on teams, and/or form additional teams.

Involve employees in S&H activities (e.g., accident/near-miss investigations).

Require subcontractors to adopt and begin implementing company policy, participate in company activities, or equivalent processes.

All teams are functioning and meaningfully contributing to S&H.

Ensure teams are routinely conducting audits, accident/incident investigations, self- inspections, and job hazard analyses.

Utilize team input to improve and continue the company's hazard reporting system.

Encourage more active and open subcontractor participation.

Develop and begin implementing a plan for how subcontractors will provide their employees with equal S&H protection.

Work with subcontractor to improve and continue implementing subcontractor program.

Work with subcontractor to improve and continue implementing subcontractor program.

Require subcontractors and their employees to comply with OSHA and company S&H rules. Inform all subcontractor employees of this requirement before work begins.

Develop a system to handle S&H violations of subcontractor employees working on-site.

Improve and continue to enforce company policy for S&H violations.

Establish a requirement that subcontractors promptly correct hazards involving their work activities.

Formalize and begin implementing methods to ensure that hazards are identified, corrected, & tracked in subcontractors' work areas including assignment of responsibility.

Ensure subcontractors effectively implement systems to identify and correct hazards in their work areas and include responsibility for hazard correction in writing.

Require in bid documents to include subcontractor injury and illness records for past three years (if available), and copies of their written S&H program.

Consider the above information in when selecting subcontractors for work.

Implement policy and process for addressing S&H performance of potential bidders.

Continue to encourage and reinforce the importance for subcontractors to develop and implement good effective S&H management systems.

No action required.

Establish and communicate a formal policy on subcontractor S&H violations, including removal and possible financial penalties.

Include policy in the company contract requirements.

Hold subcontractors responsible for correcting hazards created by their work and ensure any penalty policies are understood by all subcontractors and tier contractors described in their contracts.

Conduct a S&H baseline analysis including a review of previous accidents, injuries, and illnesses; complaints; previous studies; etc.

Require subcontractors to perform baseline analysis as necessary in accordance with OSHA and company requirements and share pertinent information with the general contractor, or other subcontractors.

Repeat baseline surveys, if warranted, by significant changes in tasks, equipment, or processes.

Review routine tasks to ensure compliance with local, state, and Federal safety and health regulations.

Begin to formalize system to ensure employees are properly trained on routine jobs, tasks, and processes.

Conduct hazard analysis for work and recommend controls for routine jobs, tasks, & processes that have potential to cause an injuries/illnesses or significant incidents; are perceived as high-hazard; or are required by a regulation or standard.

Update the company hazard analysis, as appropriate.

Require subcontractors to adopt and implement hazard analysis of routine work tasks.

Conduct hazard analysis and recommend controls for routine jobs, tasks, and processes that have written procedures, have been recommended for more in-depth analysis, or are determined by the Challenge participant to warrant hazard analysis.

Ensure subcontractors continue implementing similar processes.

Establish and begin implementing systems for identification and documentation of S&H hazards of significant changes, new processes, and changes in design/engineering plans.

Require subcontractors, if applicable, to adopt and begin implement similar systems.

Continue conducting hazard analysis for significant changes (e.g., non-routine tasks or new processes, materials, equipment and facilities/project site) and recommend controls prior to the activity or use per company requirements and OSHA standards.

Subcontractors implement a policy and begin identify and document hazards of significant changes.

Continue conducting and documenting hazard analysis for significant changes (e.g., non-routine tasks or new processes, materials, equipment and facilities/project sites) and recommend controls prior to the activity or use.

Establish and begin implementing a pre-use analysis of new equipment, chemicals, facilities/project sites, or significantly different operations or procedures and recommend controls prior to the activity or use.

Require subcontractors to develop and implement similar systems.

Continue conducting pre-use analysis of new equipment, chemicals, facilities/project sites, or significantly different operations or procedures and recommend controls prior to the activity or use.

Subcontractors begin performing pre-task analysis of work they are contracted to perform.

Continue pre-task hazard analysis of new equipment, chemicals, facilities/project sites, or significantly different operations or procedures and recommend controls prior to the activity or use.

No action required.

Establish, document, & implement future sampling schedule, strategy, and rationale, e.g., develop a formal written IH program.

Follow-up on results of baseline IH study.

Conduct more in-depth analysis if warranted to determine actual employee exposures.

Require subcontractors to participate in the company IH program where necessary.

Follow-up on results of subcontractor baseline IH study, if applicable, and conduct more in-depth analysis, if warranted.

Continue implementing the written IH programs taking proactive steps to improve control of health hazards to prevent occupational disease.

Establish a routine self-inspection program that ensures S&H inspections are performed as often as necessary.

Train company employees in the recognition and avoidance of hazards in their work area

Develop a system for scheduling routine self-inspections of the workplace; conduct inspections with S&H staff. The entire site must be self-inspected as often as necessary, but never less than weekly.

Require subcontractors to adopt similar policies.

Conduct routine self-inspections covering entire worksite as often as necessary, but at least weekly.

Ensure subcontractor processes implement similar self-inspection processes.

Use data collected from accident incident reports and other sources to determine areas to concentrate on.

Obtain supervisor and employee input for suggested plan of action in developing a hazard reporting system

Develop & begin implementing hazard-reporting system for employees (maybe anonymous), requiring timely responses back to employees.

Require subcontractors to participate in the company process or establish equivalent processes.

Continue implementing hazard reporting systems and encouraging more active reporting by both company and subcontractor employees; ensure timely investigations of the hazard reported, ensure regular feedback, using different media, to all employees on status of hazards reported.

Develop and implement requirements to report and investigate incidents/accidents.

Investigate accidents and prepare and maintain written reports of investigations.

Involve employees in the investigations.

Require subcontractors, if applicable, to adopt and begin implementing similar systems.

Company and subcontractors expand investigation activities to include near misses and make findings available to employees.

Continue reporting and investigating accidents/incidents and near-misses.

Conduct initial trend analysis of 3 previous years' injury & illness rates and begin developing a plan for conducting analysis of other S&H-related information.

Conduct trend analysis of other S&H information not yet studied; conduct one of injury & illness history if a year has gone by since initial analysis.

Require subcontractors to develop and implement similar systems.

Conducts trend analysis regularly (at least annually) of company and subcontractor S&H information and use results in setting future goals to address trends.

Ensure outside sources are available in needed to conduct baseline hazard analysis.

Ensure adequate resources (e.g., access to certified S&H professionals, licensed health care professionals).

Subcontractors ensure adequate resources, as well.

Continue to provide necessary resources (e.g., Certified Safety Professionals, Certified Industrial Hygienists).

Establish systems to prioritize and implement controls for identified hazards, through the baseline S&IH study, trend analysis of OSHA logs, and accident investigations.

Identify options and selection most appropriate option or combination for hazard elimination and control.

Require subcontractors to adopt company hazard elimination and control system or implement equivalent.

Develop an action plan to prioritize and implement controls for hazards identified through self-inspections, employee reports of hazards, and near-Miss investigations.

Selects most appropriate control methods.

Implement hazard controls (or interim protection) for top priority hazards before moving onto Stage III.

Subcontractors implement equivalent systems for hazard elimination and control methods.

Complete long term abatement projects from Stage II.

Continue to identify, prioritize, and implement control for hazards identified through all means (hazard analysis, trend analysis, accident and near miss investigation, self-inspections, employee reports of hazards, pre-use analysis, etc) so that there is a continuous loop of hazard identification and control.

Inventory existing hazard control programs required by OSHA standards. Develop missing programs or modify if necessary.

Develop appropriate company S&H rules, standards, manuals, etc.

Require subcontractors, if applicable, to develop and implement similar effective programs.

Continue to implement hazard control programs developed or modified in Stage I and train all workers on these programs.

Subcontractors implement effective hazard control programs, standards, rules, etc.

Continue to maintain hazard control programs required by OSHA standards, and other rules and regulations.

Review hazard control programs annually and update them as new processes, jobs, and tasks are begun.

Develop and begin implementing a hazard tracking system for hazards identified through the baseline hazard analysis, trend analysis of OSHA logs, and accident investigations.

Require subcontractors to adopt and implement company tracking system or establish equivalent.

Continue implementing and improving tracking system.

Subcontractors implement effective systems to track hazard identified in baseline hazard analysis, trend analysis, and self-inspections.

Company and subcontractor tracking systems are fully functioning and include hazards identified through all methods.

Communicate with workers throughout the process on the status of hazards until they are abated.

Conduct an inventory of equipment and machinery requiring preventive maintenance (PM).

Require subcontractors, if applicable, to develop a similar PM program.

Review equipment inventory. Establish and implement a preventive maintenance schedule.

Subcontractors implement preventive maintenance program to ensure the safe upkeep of equipment operating the project site.

Continue to perform preventive maintenance as scheduled.

Schedule is routinely observed and preventive maintenance is regularly conducted.

Subcontractors have preventive maintenance inventory and schedule and it is being conducted.

Conduct thorough review of injury/illness records.

Compare with insurance claims loss runs to ensure records are in order.

Utilize licensed health care professionals if needed.

Require subcontractors to provide access to health care services based on baseline S&H analysis, including physician and emergency medical care.

Continue to provide access to licensed health care providers, health services, physician care, and emergency medical care as needed. Arrange for services based on the outcomes of the baseline S&H analysis.

Subcontractors determine how licensed health care providers, health services, physician care, and emergency medical care will be provided for their employees working on-site and communicate this information to their employees.

Continue providing services listed in Stage I and II.

Consider seeking health care providers to visit the site/project, and assist in identifying causes and symptoms of injury/illness.

Care provided is within the scope of contracts, licensure, and standard operating procedures.

Establish and communicate to company and subcontractor employees written procedures for addressing responses responding to all types of emergencies.

Conduct at least one evacuation drill to assess effectiveness of how procedures.

Make emergency services available on all shifts such as emergency transportation, EMT's, emergency clinics, or hospital emergency rooms.

Ensure at least one employee trained in first aid & CPR for each shift.

Require subcontractors to adopt the company emergency procedures or equivalent.

Continue communicating emergency procedures and providing emergency medical services.

Establish an Emergency Response Team including first aid and CPR trained employees and subcontractors.

Conduct at least one drill with company and subcontractor employees and assess its effectiveness and follow-up on recommendations to improve emergency evacuation drills.

Continue to improve written emergency procedures for responding to emergencies on all shifts.

Review results of previous drills and conduct an annual drill.

Establish one operational emergency response team for each shift.

Ensure full implementation of site's emergency preparedness and response plan.

Observe OSHA guidelines in providing training for required programs.

Continue observing OSHA VPP guidelines in providing training.

Continue observing OSHA VPP guidelines in providing training.

Provide training to all workers on their S&H rights, Challenge, VPP principles, hazards in the workplace, PPE, emergency evacuation procedures, and individual emergency responsibilities.

Ensure training is recorded.

Maintain a record of training conducted.

Continue providing training to all workers, including new workers, on their S&H rights, Challenge, VPP fundamental principles, hazards in the workplace, PPE, emergency evacuation procedures, and individual emergency responsibilities.

Ensure subcontractors are fulfilling their obligations to train their employees to recognize hazards in the workplace.

Continuously improve safety and health training to workers.

Provide specific training to managers and supervisors, to designated S&H staff and others with S&H responsibilities, and provide them with knowledge & skills needed to perform their S&H responsibilities in (i.e., hazard recognition, accident investigation and root cause analysis, hazard controls, OSHA standards, and VPP requirements).

Expand specific training to all selected employees, managers and supervisors, and designated S&H staff.

Subcontractors provide specialized training to their employees on how to perform their assigned and contracted work and control/eliminate its hazards.

Take proactive steps to provide specific training to their employees and share the knowledge & skills and lessons learned.