Document JNknL4Omy82eqb51nN1B93gr6

ABD00001387 January 21, 1998 Letter To All Region IV Voluntary Protection Program (VPP) Participants Dear VPP Participant Just a reminder that I need the following information by February 15, 1998 for calendar year 1997, your site's injury incidence data. This includes lost workday injury/restncted work activity cases (the total of column 2 from the OSHA 200 log) and injury incidence cases (the combined total of columns 2 and 6 from the OSHA 200 log) In addition, you must submit the total hours worked, average annual employment, a copy of your 1997 program evaluation, any explanatory information, and any success stones I need an explanation for any increases in your rates and a descnptive plan of action I have included a form that you should use to submit your injury/incidence data This form will also be used to update our records The same information must be submitted for all applicable contractors' employees on the site Please send two (2) copies of all of the required information (injury/incidence data and annual self evaluation) to my attention at the following address Susan J Sikes, Regional VPP Manager U S Department of Labor - OSHA Atlanta Federal Center 61 Forsyth Street, S W - Room 6T50 Atlanta, Georgia 30303 If you have questions, please feel free to contact me or Charlie Anderson. Sincerely, SUSAN J SIKES Regional VPP Manager Attachment Name of Company Site Address ABD00001388 Plant Manager _______________ Site VPP Contact ______________ Telephone Number __________ __ Fax Number _______________ E-mail Address _______________ 1997 Data IIC's LWDC's The total of all injury and incidence cases, with or without lost workdays or restricted activity (The combined total of columns 2 and 6 from the OSHA 200 log) The total of all lost workday cases and workday cases of restricted activity (Please do not send the total number of actual davs away from work) (The total of column 2 from the OSHA 200 log) Average annual employment Average number of full time equivalent workers during 1997 Total hours worked Total of actual person hours worked Year Average Annual Employment Total Hours Worked Injury Incidence Cases Lost Workday Cases 1997 Please include an explanation for any increases in your rates and a descriptive plan of action Also include a copy of your 1997 annual program evaluation as required These evaluations must include assessments of the effectiveness of all elements of your safety and health program and documentation of recommendations completed Remember to address all of the elements under Management Leadership, Employee Involvement, Worksite Analysis, Hazard Prevention and Control, and Safety and Health Training Additional descriptive requirements are listed in the July 12, 1988 VPP Federal Register, Volume 53, No 133, paragraph f Safety and Health Program Evaluation 2 ABD00001389 EVALUATING YOUR SAFETY AND HEALTH PROGRAM FOR THE VPP Participation in the VPP includes the following requirement regarding evaluation of your safety and health program A VPP participant must have a system for evaluating the operation of its safety and health program annually to judge success m meeting the program's goal and objectives so that those responsible can determine and implement changes needed to improve worker safety and health protection (A) The system must provide for an annual written narrative report with recommendations for timely improvements, assignment of responsibility foi those improvements, and documentation of timely follow-up action or the reason no action was taken (B) The evaluation must assess the effectiveness of all required VPP elements and any other of the site's safety and health program (C) The evaluation may be conducted by competent corporate or site personnel or by competent private sector third parties who are trained and/or experienced in performing such evaluations The evaluation should be conducted annually at approximately the same time each year It should follow the format outlined m the VPP requirements described below The effectiveness of each element and sub-element should be assessed briefly in narrative form Recommendations for improvement should follow each narrative Assignments of responsibility for completing recommended improvements may be made after each recommendation or separately at the end of the evaluation Subsequent evaluations should begin with a description of the previous year's recommendation(s) and the follow-up actions taken and should include, in the current narrative, an evaluation of the program changes that resulted from the recommendations The most comprehensive evaluation that you can conduct should include reviewing youi written program, walking through your workplace, and interviewing employees During this process you should be answering the following questions relating to each element and sub-element of your safety and health program 1 Is it comprehensive9 2 Is it operating effectively9 3 What improvements can be made to make it even more effective9 REMEMBER A self-evaluation is NOT an inspection of the worksite, it is a critical review of ALL of the elements of the safety and health program An evaluation that is merely a workplace inspection with a bnef report pointing out hazards or saying that everything is okay is inadequate for purposes of VPP You should be evaluating your program much like the OSHA VPP evaluation team does Incomplete self-evaluations are not acceptable A format for these evaluations is provided in this correspondence For a more comprehensive description of the VPP requirements in each element and its subelements, please refer to the Star Program requirements in the VPP Federal Register Notice 3 ABD00001390 Voluntary Protection Program Format for Annual Self-Evaluations 1. Previous Year Recommendations and Status Report Listed below are the 1996 recommendations and their status A Recommendation Status B Recommendation Status C Recommendation Status D Recommendation Status 4 ABD00001391 2. Safety Performance Rates Hncidence/injurv Data) IIC's The total of all injury and incidence cases, with or without lost workdays or restricted activity (The combined total of columns 2 and 6 from the OSHA 200 log) LWDC's The total of all lost workday cases and workday cases of restricted activity (Please do not send the total number of actual days away from work) (The total of column 2 from the OSHA 200 log) Total hours worked Total of actual person hours worked Year Work Hours Injury Incidence Cases 1995 1996 1997 3 Year Totals & Averages 1995-1997 1996 BLS Rates for SIC Percent Above or Below BLS Rate Lost Workday Cases Injury Incidence Rate Lost Workday Rate A List Total HR and LWDI for current year, previous year and current year objectives B Discuss safety performance in general terms highlighting major accomplishments or deficiencies C List major plans in upcoming year to improve the safety and health program 5 ABD00001392 3. Evaluation of Elements and Sub-elements In narrative form, assess the effectiveness of each of the elements and sub-elements listed on the next page Include in each element recommendations for improvement Follow by the assignment of responsibility for completing each recommendation and a target date for completion Sample 1 Element (1 e , Worksite Analysis) [see next page for list of elements] Sub-element (i e , Comprehensive Safety and Health Surveys-Industnal Hygiene) A 1997 Activities - During 1997 all IH services were contracted to outside firms Quarterly surveys were conducted and the following items completed Audiometnc testing Noise survey Personnel exposure monitoring for lead, asbestos, formaldehyde, wood dust B Evaluation - Narrative evaluation of effectiveness of the element and sub elements Example Recommendations from reports have been completed The 1997 activities in this area are marginally effective Additional monitoring and training will be required in 1998 C Recommendation^ for improvement - Hire a certified industrial hygienist to manage the IH program D Assignment of responsibility for completing recommendation - Susan Sikes E Target date for completion - 3/15/98 6 ABD00001393 ELEMENTS and SUB-ELEMENTS 1 Management Leadership and Employee Involvement a Policy b Goal and Objectives c Planning d Written Safety and Health Program e Management Leadership f Employee Involvement g Contract Worker Coverage h Responsibility, Authority, and Resources j Line Accountability k Enforcement (1 e , rules, policies, procedures, disciplinary actions) 2 Worksite Analysis a Comprehensive Safety and Health Surveys b Pre-use Analysis c Job Safety or Hazard Analysis, Process Hazard Review d Self-inspections e Employee Hazard Reporting Systems f Accident/incident Investigation System g Trend Analysis [for injuries, hazards identified, etc ] 3 Hazard Prevention and Control a Access to Certified Safety and Health Professionals b Means for Eliminating or Controlling Hazards [This is the place to evaluate all of the individual programs on the site such as PPE, Safety and Health Rules, Lockout/tagout, Confined Space Entry, PSM, etc , as well as engineering and administrative controls] c Preventive Maintenance Program d Hazard Tracking System(s) e Occupational Health Program (include Industrial Hygiene monitoring and PPE) f Emergency Response Program and Procedures 4 Safety and Health Training a Managers b Supervisors c Employees d All others on the site [including visitors understand what to do in emergency situations] e PPE Requirements [known and used effectively] 7