VPP Steering Committee 12 July 2017 UNCLASSIFIED//FOR OFFICIAL USE ONLY

Transcription

1 VPP Steering Committee 12 July 2017 UNCLASSIFIED//FOR OFFICIAL USE ONLY

2 Agenda VPP Dept update MCCS Mishap rate trend(?) What role do contractors play in VPP? UNCLASSIFIED//FOR OFFICIAL USE ONLY

3 VPP by Dept VPP by Dept UNCLASSIFIED//FOR OFFICIAL USE ONLY

4 MCCS How many mishaps in June? UNCLASSIFIED//FOR OFFICIAL USE ONLY

5 What is a Contractor? For VPP purposes, a contractor: Is a non-federal employer with employees working under contract to perform labor of some type at the VPP site May provide labor for general services, professional services, repairs, construction, etc., Must perform some kind of labor at the site. Contracts for work that does not involve labor (e.g., material purchases), or that only involve labor that is performed off site, are not considered part of the site VPP effort May be working under the contractual authority of the VPP site, or under an external contracting agent that is not part of the site VPP effort, and may not be physically located at the VPP site 5

6 Is it the Site s Contractor? If the responsible Contracting Officer/Authority is within the VPP site s chain of command, it is the site s contractor All VPP requirements for contractor safety and heath apply Site is responsible to ensure all VPP requirements are met Selection, contract expectations, oversight If the Contracting Officer/Authority is external to the VPP site s chain of command, it is not the site s contractor but even then: Contractor safety cannot be ignored Must be observant for contractor related hazards, disregard for OSHA Standards, or disregard for site/base safety rules Must have effective partnership with the contracting agent to promptly resolve problems/hazards 6

7 Is it an Applicable or Nested Contractor? Applicable Contractor. A contractor whose employees worked at least 1,000 hours for a VPP participant in any calendar quarter within the last 12 months and are not directly supervised by the applicant/participant VPP requirements for selection, contract content, and oversight apply Nested Contractor. A contractor whose on-site employees are intermingled with site employees and supervised by management of the VPP Site For VPP purposes, supervised does not equal personal services OSHA: Supervision generally exists when the employer supervises not only the output, product, or result to be accomplished by the person s work, but also the details, means, methods, and processes by which the work objective is accomplished. Typically have no on-site contractor supervisor 7

8 VPP Requirements Applicable Contractors Consideration of safety during contractor selection Obtain information during solicitation Injury rates OSHA violations and response actions taken Experience modification factor (EMF) Description of contactor s available safety and health resources (trained personnel/supervisors, safety professionals, industrial hygienists, specialized tools/equipment, etc.) Description of how the contractor will manage safety for the work to be performed (supervision, self-inspection, hazard tracking/correction methods, ongoing worker training, regular safety meetings, etc.) Include as a factor in the overall evaluation process 8

9 VPP Requirements Applicable Contractors Inclusion of safety and health requirements in contracts Comply with applicable OSHA standards Comply with other S&H standards cited by the contract Follow site/base safety rules Periodically submit contractor TCIR/DART rates for work performed at the site Ensure contractor employees have basic awareness of VPP and site participation Penalties for failure to meet contract safety requirements Removal of contractor employees from site Work stoppage without compensation Financial penalties Termination of contract 9

10 VPP Requirements Applicable Contractors Oversight of contractor safety and health performance Contracting Officer Representative(s) periodically observe and inspect contractor work areas Document deficiencies and corrective actions taken Assistance/consultation with site/base Safety staff, as needed Safety inspection training is a plus Confirmation, with supporting documentation as needed, of contractor performance of required activities Self inspection and corrective action reports Problem investigation and corrective action reports Documentation of required training Certification of key employee qualifications (safety professionals, IHs, etc.) Meeting minutes 10

11 VPP Requirements Nested Contractors In VPP, OSHA essentially views nested contractor employees as site employees. The site controls the work environment, the assignment of work, and the work methods, tools, procedures, and training. Nested contractor employees who are supervised by host site management are governed by the host s safety and health management system and are included in the host s rates. Therefore, the VPP site must: Include recordable nested contractor injuries in the OSHA 300 Log Include nested contractors in the site s TCIR and DART rates Normally, VPP sites simply include nested contractors in the site s safety and health management system, same as site employees General employee training, new employee orientation, safety standdowns, JHA development and updating, work area self-inspections, emergency drills, safety and health committees, etc. 11

12 VPP and Contractors Assessment Tips Meet with site contracting officials and Safety staff to identify: The site s applicable and nested contractors Other contractors managed by external authorities How are VPP contractor selection requirements being met How are safety and health provisions included in contracts What type of oversight is being provided for contractors Example documents (e.g., evaluation panel report, contract language, oversight reports) for evidence that the selection process, contract provisions, and oversight processes are in place as described 12

13 VPP and Contractors Assessment Tips Be alert for contractor employees and worksites during workplace tours Look for uncontrolled hazards and significant noncompliance Ask contractor workers: Who inspects their work areas for safety. How often? How do they report a hazard in the government facility? What is VPP, and how does it affect them? What kind of safety training do they get from their employer? What kind of safety meetings to they attend? Be alert for externally managed contractors (e.g., NAVFAC), and discuss them with the VPP site s Safety staff Do they generally work safely, or do they cause problems? Do their controlling contracting agents respond promptly and effectively to site safety concerns? 13

14 Pass the word Gap in contracted motorcycle training Training still offered on base at a very reduced capacity At least several weeks before capacity will be increased Unknown when we will be at 100% Other options: Take course at one of the community colleges o Base Safety will reimburse upon successful completion NC Bike Safe o Free of charge offered by Motor Officers o Both JPD and New Bern PD offer courses o Not an entry level course o UNCLASSIFIED//FOR OFFICIAL USE ONLY

15 Number Rate/100K Person per Year MOTORCYCLE PMV FATALITIES Fatality Numbers Fatality Rate Rate UCI* Rate LCI* CLASS A FATALITIES/FATALITY RATE FY COMPARISON: FY16 FATALITIES/FATALITY RATE: 10-YEAR AVERAGE (FY07-16) FATALITIES/FATALITY RATE: 10-Jul-17 16/ / / Jul-16 8/5.42 *see last slide for definition of UCI/LCI

16 Questions/Comments UNCLASSIFIED//FOR OFFICIAL USE ONLY

17 Next Meeting August 9 th Same Bat Time Same Bat Place UNCLASSIFIED//FOR OFFICIAL USE ONLY