"If you build it, they will not come."
That's what the U.S. Occupational Safety and Health Administration (OSHA), Washington, D.C., is telling thousands of employers across the country. OSHA inspectors will stay away from companies that implement a safety program that meets federal standards.
Under the agency's Cooperative Compliance Program (CCP), which was introduced last November, OSHA will inspect some 500 of the most dangerous worksites nationwide, while offering other employers the opportunity to escape intrusive watchdog visits.
The program will be available in the 29 states where OSHA enforces workplace safety and health laws. The 21 states that operate their own OSHA-type programs will be obliged to create similar campaigns.
The CCP concept began several years ago in Maine with a pilot project limited to 200 worksites. The project's success led to similar initiatives in other states.
These early efforts had common elements: They targeted the "worst" workplaces in the state and removed intense OSHA scrutiny from employers that voluntarily adopted credible safety and health management programs. OSHA used workers' compensation data to identify the so-called "worst" sites. As a result, facilities with large workforces got closer scrutiny than smaller facilities even if their size-adjusted safety records were comparable.
OSHA also discovered problems in using workers' compensation data in designing a nationwide targeted-inspection program. Variations among the states in workers' compensation systems made it impossible to compare information across state lines.
The agency turned to data on lost workdays due to injury and illness (LWDII), which is kept at worksites in all states. However, the statistics are not entirely reliable in measuring a facility's safety.
First, the process adds up the number of injuries and illnesses that produce lost or limited workdays, but does not measure their severity. Thus, an injury that requires an employee to be reassigned to lighter duties for several days counts the same as an injury that keeps an employee home for a month.
Second, OSHA does not have ready access to LWDII rates. Even though OSHA demands that employers note on their OSHA 200 logs the information that the agency uses to calculate the rates, the rules do not require employers to submit such information to OSHA regularly. Thus, no system existed to gather relevant data from a significant percentage of representative worksites.
Two years ago, when OSHA began a nationwide survey of certain targeted businesses to calculate LWDII rates, trade and business groups successfully challenged the agency's authority to collect data and to use whatever data it had already gathered.
After OSHA got the legal authority it needed to proceed with the survey, it examined some 80,000 worksites in 1997, putting the finishing touches on the CCP.
The first stage targeted 500 worksites for full-scale safety and health inspections, using a combination of LWDII rates and OSHA violations. The agency has since trimmed its "hit" list to about 400 sites with LWDII rates at least eight times the national average (3.6) and another 100 sites with slightly lower LWDII rates but with recent significant OSHA violations.
The 500 targeted facilities can expect wall-to-wall inspections covering all OSHA general industry standards.
Some 14,000 other facilities in the targeted business and industrial categories with LWDII rates greater than 7.0 (almost twice the national average) will have a chance to participate in the CCP.
Participation will require a demonstratable commitment to comprehensive safety and health management, including, for starters, identifying and correcting all workplace hazards - whether or not they are covered by OSHA standards - and reducing workdays lost from job-site injury or illness.
Moreover, employers must show participation by top level management, employee involvement, and beefed-up training programs. CCP participants will reduce their chances of drop-in OSHA inspections significantly.
When such inspections do occur, they are likely to be relatively short. And, routine violations may not even be noted, especially if a facility has a record of working with its employees to identify and correct hazards.
Employers with fewer than 100 employees at a particular worksite can elect to participate in CCP and be monitored by a state consultation service. These employers may thereby reduce the chances of inspection to less than 10 percent.
The CCP represents OSHA's decision on allocating its limited resources for best results. Thus, employers that have not been singled out by OSHA for immediate inspection or have not been offered the option to participate in the program may see or hear little from the agency in the future.
Contracts EMCON, San Mateo, Calif., has been awarded a contract to design a reactive permeable barrier to remediate contaminated groundwater at a manufacturing site in New England.
The U.S. Navy has contracted with NaturTech Composting Systems Inc., St. Cloud, Minn., to install an in-vessel composting facility at the Naval Air Station Whidbey Island.
Roy F. Weston, West Chester, Pa., has been awarded a five-year indefinite delivery order/indefinite quantity contract valued at up to $3.5 million to provide comprehensive Clean Air Act compliance and engineering support for the Naval Facilities Engineering Command Atlantic Division.
Wisconsin Achieves Diversion Goals PRAIRIE VILLAGE, KAN. - A study by Franklin Associates, Prairie Village, Kan., for the Wisconsin Department of Natural Resources shows that the state has achieved dramatic success in its efforts to divert municipal solid waste (MSW) from disposal.
While 17 percent of the state's MSW was estimated as recovered for recycling in 1990, 36 percent was estimated as recovered in 1995. In addition, Wisconsin's ban on landfilling yard trimmings coupled with promotion of managing yard debris at home reduced the quantity of collected yard trimmings to less than half that estimated in 1990.
Together, the recovered recyclables and reduction in yard trimmings resulted in an estimated 41 percent MSW diversion in 1995.
Total generation of Wisconsin's MSW was estimated at 3.71 million tons in 1995 which equals 3.97 pounds per person per day. This compares to 4.34 pounds per person per day generated nationally that year.
About 55 percent of Wisconsin MSW was from residential sources (including multi-family households) and 45 percent was from non-residential sources (most retail, wholesale, office and institutional establishments).
Test Your Buy-Recycled Knowledge 1. Federal, state and local purchases represent approximately what percentage of the Gross National Product? a. 10 b. 20 c. 50
2. The U.S. EPA has developed recycled product guidelines for how many product categories? a. 5 b. 24 c. 36
3. How many states have developed buy-recycled programs? a. 25 b. 40 c. 50
4. What percentage of steel manufactured in the United States contains recycled material? a. 35 b. 65 c. 100
5. Using re-refined oil in your engine will void your warranty. a. True b. False.
Fine The California Integrated Waste Management Board, Sacramento, has fined a Carpinteria-area printing service $3,000 for refusing to disclose how much recycled-content paper it had used from 1994 to 1996.
Merger USA Waste Services Inc., Houston, has entered into a definitive merger agreement with TransAmerican Waste Industries. The equity value of the transaction is approximately $70 million.
New Address Gershman, Brickner & Bratton has moved its corporate headquarters to: 8550 Arlington Blvd., Fairfax, Va. 22031-4620. (703) 573-5800. Fax: (703) 698-1306.