MIOSHA Consultation Education and Training Division Michigan Occupational Safety and Health Administration Department of Licensing and Regulatory Affairs DOCUMENT IDENTIFIER: CET-ADM–08-01R1 SUBJECT: Award Instruction DIVISION INSTRUCTION DATE: April 1, 2014 ABSTRACT I. Purpose: This instruction establishes award criteria and procedures for processing and issuing awards. II. Scope: This instruction applies to all Consultation Education and Training (CET) staff submitting recommendations for CET awards. III. References: A. Agency Instruction, MIOSHA-ADM-14-1, Vetting and Entity Check Requests. B. Bureau of Labor Statistics (BLS), Industry Injury and Illness Data, http://www.bls.gov/iif/. C. Occupational Safety and Health Administration (OSHA), Safety and Health Program Assessment Worksheet (Form 33). D. U.S. Census Board, North American Industry Classifications System (NAICS), http://www.census.gov/eos/www/naics/. IV. Distribution: MIOSHA Staff, OSHA Lansing Area Office; S-drive Public Folder Accessible; and MIOSHA Weekly. V. None. Cancellations: VI. History History of previous versions include: CET-ADM-08-01, October 21, 2008. VII. Contact: Chris Passamani, Onsite Health Supervisor, Consultation Education and Training Division CET-ADM–08-01R1 April 1, 2014 Award Instruction VIII. Originator: /Nella Davis-Ray/ Nella Davis-Ray, Division Director Consultation Education and Training Division Executive Summary On October 21, 2008, the CET Division issued CET-ADM-08-1 to establish procedures for assessing and qualifying companies for safety and health recognition awards. The Federal OSHA program expressed concern that rewarding safety performance as measured by low recordable injury rates could have the unintended effect of incentivizing some employees to under-report injuries. This revised instruction requires increased attention to proactive safety indicators (e.g., participation on safety committees, conducting self-inspections, reporting nearmisses, thorough root cause analyses, etc.). This revised procedure places greater weight on the elements that comprise a safety and health management system (SHMS) and allows for slight variance in meeting the revised criterion of achieving a better-than-average industry injury rate. Significant Changes Eliminated the criteria to have zero lost-time to qualify for some awards. Eliminated the Platinum and Ergonomic Innovation awards. For the Silver award, specified that the Total Case Incident Rate (TCIR) and the Days Away, Restricted and Transfer (DART) rate criteria are for the current and last complete year. For the Gold award, specified that the TCIR and DART criteria are for the current plus the last two complete years. Deleted requirement to have a designated safety person. A functioning safety committee was viewed as an acceptable minimum investment. Added a Form 512-GI evaluation requirement to the Ergonomic Success award. Added minimum injury rate criteria (within 25% of average) and Form 512-GI criteria to the Bronze Certificate of Recognition award. 2 CET-ADM–08-01R1 April 1, 2014 Award Instruction I. Purpose. This instruction establishes award criteria and procedures for processing and issuing awards. II. Scope. This instruction applies to all Consultation Education and Training (CET) staff submitting recommendations for CET awards. III. References. A. Agency Instruction, MIOSHA-ADM-14-1, Vetting and Entity Check Requests. B. Bureau of Labor Statistics (BLS), Industry Injury and Illness Data, http://www.bls.gov/iif/. C. Occupational Safety and Health Administration (OSHA), Safety and Health Program Assessment Worksheet (Form 33). D. U.S. Census Board, North American Industry Classification System (NAICS), http://www.census.gov/eos/www/naics/. IV. Distribution. MIOSHA Staff; OSHA Lansing Area Office; S-drive Public Folder Accessible; MIOSHA Weekly. V. Cancellations. None. VI. History. History of previous versions include: CET-ADM-08-01, October 21, 2008. VII. Contact. Chris Passamani, Onsite Health Supervisor. VIII. Originator. Nella Davis-Ray, Division Director, Consultation Education and Training Division. IX. Background. Recognition is a powerful tool for achieving business goals. Organizations perform at higher levels when their contributions are recognized and appreciated. Effective recognition practices consistently correlate with increased: Employee satisfaction and morale Productivity Profitability Retention The CET Division has various recognition awards which are given to companies who have achieved outstanding safety and health records and have implemented an effective safety and health management system (SHMS). In addition, the agency gives special awards for ergonomic successes. The award criteria and procedures have been in place for many years 1 CET-ADM–08-01R1 April 1, 2014 Award Instruction and revised several times. CET awards available today include: Ergonomic Success, Bronze Certificate of Recognition, Silver, and Gold. The CET awards program is designed to motivate organizations to maintain and improve their safety performance as well as promote cooperation with MIOSHA. In conjunction with the implementation of a SHMS, recognizing an organization’s efforts help keep safety and health in the minds of workers. One of several criteria in recognizing a company’s efforts can be the number of hours worked without a lost time accident or how their injury rates compare to their industry average. This criteria must be carefully evaluated to ensure that there is not a bias toward under-reporting accidents, which can undermine the SHMS. X. Responsibilities. A. Agency Director/Deputy Director. 1. Review and approve press release of the award ceremony. 2. Participate in award ceremonies when available. B. Agency Senior Executive Management Assistant (SEMA). Forward vetting requests for the Department of Licensing and Regulatory Affairs (LARA) approval to proceed. Vetting shall be done in accordance with Agency Instruction, MIOSHA-ADM-14-1, Vetting and Entity Check Requests. C. Division Director. 1. Grant final approval for all awards. 2. Participate in award ceremonies as needed. D. Communications Representative. 1. Contact awardees regarding ceremony details. 2. Inform agency SEMA and CET division director when a second LARA vetting is needed. 3. Communicate ceremony details to appropriate agency personnel. 4. Draft press release for the award ceremony. 5. Take or procure photos of ceremony. 6. Report award and ceremony details in the MIOSHA News, MIOSHA E-News, and to the MIOSHA Twitter, and Facebook page. 2 CET-ADM–08-01R1 April 1, 2014 Award Instruction E. F. Safety and Health Program Manager. 1. Confirm MIOSHA 300 Log data. For ergonomic awards, submit ergonomics packet to MIOSHA Ergonomics Committee chairperson. 2. Request a history check from appropriate enforcement division. 3. Review history check, update packet, and forward application to division director. 4. Notify recommending consultant, supervisor, communications representative, division secretary, and desktop publisher of approved awards. 5. Forward final, approved award application packet to division secretary. 6. Participate in award ceremonies as needed. Consultant’s Supervisor. 1. Review award packet to ensure eligibility, review documentation of SHMS, ensure the Federal employer identification number (FEIN) is present in the award packet, ensure the name of the controlling entity is present in the award packet, sign off, and give award packet to safety and health program manager. 2. If disapproved, review with consultant, initiate denial letter, and file packet. 3. Participate in award ceremonies, as needed. G. Division Secretary/Staff Support. 1. Obtain a safety and health history check and LARA vetting request for the recommended awardee. Vetting shall be done in accordance with Agency Instruction, MIOSHA-ADM-14-1, Vetting and Entity Check Requests. 2. Forward award packet to safety and health program manager for review. 3. Procure the award plaque when award is approved. H. Consultant. 1. Assist employer and complete the award application. All serious hazards identified during the hazard survey must be corrected before an award recommendation is submitted. Take photographs, or videos, as needed or required. 2. Submit completed award application packet to supervisor. Ensure the FEIN is present in the award packet; ensure the name of the controlling entity is present in the award packet. The FEIN number must be provided for each named entity. 3 CET-ADM–08-01R1 April 1, 2014 Award Instruction I. J. 3. Notify employer of decision: approved or disapproved. 4. Participate in award ceremony, when possible. 5. In the absence of the communications representative, acquire photos of ceremony. Desktop Publisher. 1. Maintain all award documentation. 2. Update cumulative awards list. 3. Create award layout for plaque. MIOSHA Ergonomics Committee Chairperson. 1. Review ergonomics packet and confirm ergonomics data. 2. Submit ergonomics award application and photographs to the MIOSHA Ergonomics Committee. 3. Review history check, update packet, forward application to CET division. 4. Participate in award ceremonies, as needed. K. MIOSHA Ergonomics Committee. 1. Review all completed ergonomic award applications and verify that any new innovation does not create a safety hazard. 2. Approve all completed Ergonomic Success award applications. XI. Award Descriptions and Criteria. A. Bronze Certificate of Recognition. The Bronze Certificate of recognition is issued to an establishment that does not meet the criteria for the Silver or Gold award. The certificate may be granted for other significant safety and health achievements or for major contributions or service that has resulted in a positive impact on worker safety and health. However, the company must have a current Total Case Incident Rate (TCIR) and the Days Away, Restricted and Transfer (DART) rate that is within 25% of their industry averages. The company must also have implemented at least 16 of the 32 attributes on the Safety and Health Program Evaluation form (Form 512-GI or Form 33). The Form 512-GI will be used for both general industry and construction. B. Silver Award. The Silver award is issued to an establishment whose current and last complete year’s TCIR and DART rate are below the industry average. The Silver award criteria also includes having the company implement at least 20 of 32 attributes 4 CET-ADM–08-01R1 April 1, 2014 Award Instruction in their SHMS as evaluated by the consultant using the Form 512-GI or Form 33. The Form 512-GI will be used for both general industry and construction. The Silver award company must have at least one implemented attribute in each of the five categories and also meet the goal of 20 total attributes. The company must also have an established safety and health committee. C. Gold Award. The Gold award is issued to an establishment who’s current and last two complete years’ TCIR and DART rates are below the industry average. The Gold award criteria also includes having the company implement at least 24 of 32 attributes in their SHMS as evaluated by the consultant using the Form 512-GI or Form 33. The Form 512-GI will be used for both general industry and construction. The Gold award company must have at least two implemented attributes in each of the five categories and also meet the goal of 24 total attributes. The company must also have an established safety and health committee. D. Ergonomic Success Award. The Ergonomic Success award will be given to an establishment who has instituted ergonomic improvements and have substantially reduced Musculoskeletal Disorders (MSDs). The criteria for the Ergonomic Success award includes the following: E. 1. The employer’s last 12 month TCIR shall be below the industry average rate and the employer must have implemented at least 20 of the 32 attributes on the Form 512-GI or Form 33. 2. The employer has had at least a 25% reduction of MSD incidence rate over the previous 12-month period, with no increase in their total case incidence rates. 3. The improvement must be brought about through ergonomic engineering controls, administrative controls, and/or incentives. 4. The employer should have a method for obtaining input from employees, and have employee involvement in the improvement process. Award Recommendations. 1. Consultant’s Recommendation. A consultant’s decision to recommend a company for an award should be based on their first-hand knowledge of the company’s achievements. If there has not been prior CET activity with a company, a hazard survey and an assessment of their safety and health system must be conducted to verify that the company meets the award criteria. All serious hazards identified during the hazard survey must be corrected before an award recommendation is submitted. 2. Enforcement Referrals. When working with employers, MIOSHA enforcement staff may become aware of safety and health system improvements worthy of recognition. With the employer’s approval, MIOSHA enforcement staff should 5 CET-ADM–08-01R1 April 1, 2014 Award Instruction gather as much award application data as possible for their supervisor’s review and referral to CET. 3. F. Company Request. By publicizing the awards, companies become aware of the opportunity for recognition and may request consideration for an award. The request will be assigned to a CET consultant for follow-up to assess eligibility. (See E.1. above.) Submitting Award Documentation. 1. Bronze Certificate of Recognition, Silver and Gold Awards. a) With the company’s approval, the consultant will complete the CET Award Worksheet, HO-35, (see Appendix A). Whenever possible, the employee representative should signoff or be indicated by name on the worksheet. If employees are represented by a bargaining agreement, the name of the union and representative shall also be included. The consultant must also submit the company’s FEIN and ensure the name of the controlling entity is present in the award packet so that award applicants can be vetted. b) The HO-35 worksheet has web links to NAICS information and BLS, Industry Injury and Illness Data. c) For all applicants, DART rate and TCIR calculations will be based on the 300 Log information of the applicable calendar year(s). Copies of the MIOSHA 300 log as well as the 300A summaries showing hours worked shall be submitted with the HO-35. d) Compare the applicant’s calculated DART and TCIR rates against the most specific NAICS rates available. If Michigan data is unavailable, the comparison will be made to the national data. Whichever data has more digits of the NAICS code available (Michigan or national) that data will be used for comparison purposes. The latest data from Michigan and nationally may be one year behind the actual year completed. In this case the most recent data available will be used for comparison. e) A copy of a recently completed Form 512-GI or Form 33, and a copy of a recently completed CET Onsite or Training and Consultation hazard survey shall accompany the HO-35. Documentation of the company’s SHMS shall be submitted by showing written evidence of meeting the required number of attributes on the Form 512-GI or Form 33. Examples include submitting copies of: site specific safety and health programs, accident and near miss incident investigations, internal inspection check lists, mission statement that show safety and health as a primary goal, injury and illness analysis, safety or health training schedules, safety equipment purchase orders, safety committee minutes, private consultant survey reports, root cause analysis of 6 CET-ADM–08-01R1 April 1, 2014 Award Instruction an accident or near miss incident, a tracking log showing evidence of follow-up correction of hazards discovered on a self-inspection, MIOSHA Training Institute certificates for employees, evidence of implemented safety suggestions. If a copy of the evaluation or survey is not being submitted with the award application, the consultant shall indicate in the notes section of the application when the evaluation and survey was conducted so the reviewing supervisor can locate the reports (evaluation and survey must be within one year or less). f) Occupational Disease Reporting. Michigan Public Health code requires physicians, hospitals, clinics, or employers to report all known or suspected cases of occupational diseases (ODs) within ten days of discovery of the disease or condition. Before submitting an award request, the consultant should check the 300 Log for ODs. If there are no ODs on the log, the consultant should take the opportunity to educate the employer regarding reporting requirements, should they experience any ODs in the future. If there are ODs on the log, the consultant should ask if they have been reported. If they have not been reported, inform the employer of the reporting requirements and give them a form or lead them to the instructions and forms on the MIOSHA website. 2. Ergonomic Award. There is an application form for the MIOSHA Ergonomic Success Award (see Appendix B). This form is a Word file that includes definitions and stand-alone instructions. All applications for this award should be completed jointly by the employer and the MIOSHA staff working with the company. Whenever possible, an employer representative should sign off or be indicated by name in the narrative section of the application. If employees are represented by a bargaining agreement, the name of the union and representative should also be included. G. Processing the Award Application. 1. Approval Path a) Bronze Certificate of Recognition, Silver, and Gold Awards. The consultant’s supervisor reviews the application for completeness. Consultants will be contacted by the supervisor if the application is incomplete or if the supervisor has questions about the application. If an application is submitted that does not meet the award criteria, the supervisor will notify the consultant. A letter will be sent to the applicant explaining the reason for denial. When the supervisor determines that the application is complete, a CET 7 CET-ADM–08-01R1 April 1, 2014 Award Instruction Award Process Checklist (see Appendix C) is added to the packet and given to the CET program manager. The CET program manager has the CET division secretary initiate MIOSHA history check and department vetting. With verification of applicant’s satisfactory department and agency history, the application is presented to CET division director for approval. b) Ergonomics Award. The completed application and photos should be sent through the supervisor for review. If an application is submitted that does not meet the award criteria, the consultant will be notified and a letter of denial will be sent to the applicant explaining the reason for denial. When the supervisor determines that the application is complete, a CET Award Process Checklist, HO-41 is added to the packet and given to the division secretary for vetting. Upon receipt of vetting results, the packet will be given to the MIOSHA Ergonomics Committee chairperson. Vetting shall be done in accordance with Agency Instruction, MIOSHA-ADM-14-1, Vetting and Entity Check Requests. With verification of applicant’s satisfactory department and agency history, the chairperson will discuss the application with the MIOSHA Ergonomic Committee. The committee shall further review and by majority vote, approve the application; return the application for clarification; or disapprove the application and return with explanation. For approved ergonomic success applications, the application is presented to the CET division director for approval. 2. Notification. a) Bronze Certificate of Recognition, Silver, Gold, and Ergonomic Awards. (1) Approved Award. Once the award application is approved, the CET division director notifies the consultant, supervisor, communications representative, division secretary, and desktop publisher. A copy of the award packet goes to the communications representative who works with the consultant, supervisor and company on award presentation arrangements. Original documentation goes to the desktop publisher to file. (2) Disapproved Award. If the MIOSHA history check and department vetting review identifies any concerns, the division director will discuss the application with the program manager. An award application may be disapproved even though the award criteria has been met. In this case the recommending consultant and supervisor will be informed. The employer will also be notified. Original documentation will go to the desktop publisher to file. The employer will receive a letter informing them of the reason for denial (see Appendix D). 8 CET-ADM–08-01R1 April 1, 2014 Award Instruction Appendix A CET Award Worksheet (HO-35) 9 CET-ADM–08-01R1 April 1, 2014 Award Instruction APPENDIX B Michigan Department of Licensing and Regulatory Affairs MIOSHA Ergonomic Success Award Application Form Date: To: From: MIOSHA Ergonomics Committee Nominee Information Company Name: Controlling Entity: Address: City: Contact Name: Contact Phone: NAICS Code: Union Name: FEIN #: State: MI Title: Contact e-mail: # of employees: Union Contact: Zip: Before Improvement Narrative (See instructions): After Improvement Narrative: Last 12 Months Ending: Previous 12 Months Ending: Total Hours Worked Recordable Cases Musculoskeletal Disorders Cases Total Case Incident Rate Industry TCIR Musculoskeletal Disorder Case Incidence Rate Please attach photographic documentation of the ergonomic innovation. Permission is given to MIOSHA to share the application information with others as examples of ergonomic best practice on their website, in their newsletter, and/or in CET training programs. Employer Signature: Date: MIOSHA Ergonomic Committee Disposition: Date: Completed Application Received and Reviewed by Immediate Supervisor Completed Application Received by Committee Chairperson Completed Application Reviewed by Ergonomics Committee Ergonomic Success Award Approved Ergonomic Committee Chairperson Signature: Date: CET Division Director Signature: Date: See Application Instructions on Back HO-39 (Rev. 8-06) 10 CET-ADM–08-01R1 April 1, 2014 Award Instruction ERGONOMIC SUCCESS AWARD PROCESSING INSTRUCTIONS Employers who have instituted ergonomic improvements and have reduced musculoskeletal disorders substantially may be eligible for an Ergonomic Success Award. A. MIOSHA staff who feel that an employer qualifies for such an award should assist them in completing the application and taking the photographs. B. The narrative of the application should provide before and after improvement task descriptions, the ergonomic impact of the improvement, details of the improvement process, and the estimated costs to purchase or manufacture the ergonomic improvements. C. The criteria for the award include all of the following for: 1. The establishment’s last 12-month total case incidence rate should be at or below their industry’s total case incidence rate. 2. The establishment must demonstrate at least a 25% reduction of their musculoskeletal disorder case incidence rate over at least the previous 12-month period of time, with no increase in their total case incidence rate. 3. The improvement must be brought about through ergonomic engineering controls and not solely by administrative controls. 4. The employer should have a method for obtaining input from employees and have employee involvement in the improvement process. D. Supervisors review, initial, and date the application before submission to the chairperson of the MIOSHA Ergonomics Committee. E. The MIOSHA Ergonomics Committee will review and approve all completed award applications. As part of the approval process, the application and photographs will be reviewed by the committee’s enforcement division representative(s). F. The chairperson of the MIOSHA Ergonomics Committee will notify the nominating MIOSHA staff and the awardee when the award has been approved. DEFINITIONS 1. Establishment – a single physical location where business is conducted or where services or industrial operations are performed. 2. Musculoskeletal Disorder (MSD) Case Incidence Rate - Total number of MSD cases x 200,000 ÷ Number of hours worked by all employees. 3. Musculoskeletal Disorders Cases – all recordable cases that are MSDs. MSDs are disorders of the muscles, nerves, tendons, ligaments, joints, cartilage, and spinal discs. Examples of MSDs include: Carpal tunnel syndrome, Rotator cuff syndrome, De Quatrain’s disease, Trigger finger, Tarsal tunnel syndrome, Sciatica, Epicondylitis, Tendonitis, Reynard’s phenomenon, Carpet layers knee, herniated spinal disc, and low back pain. 4. Recordable Cases – all work-related injuries and illnesses that resulted in: death, loss of consciousness, days away from work, restricted work activity or job transfer, or medical treatment beyond first aid. 5. Total Case Incident Rate - Total number of recordable cases x 200,000 ÷ Number of hours worked by all employees. 6. Total Hours Worked - the number of full-time employees for the year. 11 CET-ADM–08-01R1 April 1, 2014 Award Instruction Appendix C CET Award Process Checklist Timelines: Total: 7-8 weeks: 4 Weeks from submittal to approval. 3 Weeks from approval to plaque made. Award Type __________ Company Name: _____________________________________________________________ Date & Initial ______ 1. Award packet submitted to the consultant’s supervisor. ______ 2. Supervisor reviews packet for completeness and assures eligibility criteria is met. Approved - gives packet to CET S&H program manager after signing off. Not eligible – returns award application to Consultant – initiates a denial letter. ______ 3. CET S&H Program Manager. Rechecks data from log. Gives packet to division secretary/support staff to conduct a history check. ______ 4. Division Secretary/Staff Support conducts history checks. Sends e-mails for history checks, with cc to MIOSHA director for department vetting. NOTE: If an award ceremony is planned and scheduled 60 days or more after the initial department vetting, the agency’s senior executive management assistant (SEMA) will initiate 2nd department vetting. Add history check to task list for one-week follow-up. Results of history check are attached to award packet and returned to CET S&H program manager. ______ ______ 5. S & H Program Manager reviews history checks. Award approved and packet forwarded to CET division director. Award denied and packet returned to consultant’s supervisor, with comments. 6. Division Director. Reviews packet. Approves. Denies. Returns packet to S&H program manager. 12 CET-ADM–08-01R1 April 1, 2014 Award Instruction ______ 7. S & H Program Manager. Notifies consultant’s supervisor. Notifies consultant, discusses “next steps” with awardee. a. Company to be notified that they will receive a call or email from the CET staff support to confirm name of company for plaque. b. Company will also receive a call from communications representative to discuss the type of ceremony, potential dates, etc. c. Communication representative may ask consultant for additional information about the company. Packet is forwarded to desktop publisher. ______ 8. Desktop Publisher. Copies award packet and gives to communications representative. Contacts company to confirm how company name should appear on award. ______ 9. Desktop Publisher. Adds company name to cumulative awards list. Creates the layout for the award. ______ 11. Support Staff handles award procurement. CET Silver and Gold Awards: DOT, Departmental Services, Mapping & Graphics, Photography Unit CET Ergo, MSHARP, and MVPP Awards: On The Spot Engraving Allow 2 weeks for return from DOT or On The Spot. Follow up if award is not complete. Notifies Communications Representative that award is ready. Holds award at Desktop Publishing Station. ______ 12. Desktop Publisher. Files packet in appropriate award file. Create an Outlook task to add a copy of the MIOSHA News article to back of award packet, as soon as it appears in the next printing of the MIOSHA News. ______ 13. Communications representative contacts the company to discuss: ceremony, potential dates, and make arrangements for presentation, including media advisory and press release. Ceremony date should be no later than three weeks from the date approval packet is received. The following will be communicated with once date is selected: agency director, division director, consultant, consultant’s supervisor, division S&H program manager, others attending ceremony. 13 CET-ADM–08-01R1 April 1, 2014 Award Instruction ______ 14. Communications representative will take pictures of ceremony. In the absence of the communications representative the consultant will bring camera, setup for shot, and ask for someone at the ceremony to take the picture. --------------------------Consultant Supervisor S & H Program Manager Not approved Back to Supervisor Back to Consultant Approved Division Director Division Secretary/Staff Support Desktop Publisher Division Secretary/Staff Support DOT/On the Spot/Print & Graphics Desktop Publisher Communications Representative 14 CET-ADM–08-01R1 April 1, 2014 Award Instruction APPENDIX D Sample Denial Letter Date: Name Address Dear Mr./Mrs. : The Michigan Occupational Safety and Health Administration (MIOSHA) has implemented recognition programs to acknowledge Michigan employers and employees committed to creating a workplace culture that makes safety their top priority. A Consultation Education and Training (CET) (name of award) Award Recommendation was submitted for (company name). CET (name of award) award criteria is as follows: (list award criteria) Written and implemented safety and health policies and procedures. Established safety and health committee. Appointed safety and health designee. Company Restricted Case Rate is below 50% of Industry Restricted Case Rate. No entries in “Days Away From” column on 300 Log. On (date), the MIOSHA CET Division completed the review of a CET “(name of award) award recommendation” packet for (company name). (List specifics for company applying for the award) The documentation shows the company met all (name of award) Award requirements except for the TCIR not being below the industry average. MIOSHA commends (name of company) for their hard work. We encourage your company to continue in their efforts to maintain a safety and health management system and improve safety and health performance. MIOSHA encourages your company to continue to strive to qualify for a CET award. CET services offer employers free assistance with improving existing safety and health programs and with identifying and solving tough safety and health problems. Participation with CET services is not required to qualify for a CET award. If CET can be of assistance in helping your company to achieve its safety and health goals, please contact us at (517) 322-1809. Thank you for your commitment to workplace safety and health. Sincerely, XXXX Division Director XXX:xx 15