AGENCY
INSTRUCTION
MIOSHA
Michigan Occupational Safety and Health Administration
Department of Licensing and Regulatory Affairs
DOCUMENT IDENTIFIER:
DATE:
MIOSHA-GEN-04-1R2
May 22, 2012
SUBJECT: UAW/Ford/ACH/MIOSHA Partnership (Revised)
ABSTRACT
I.
Purpose:
This directive establishes Department of Licensing and
Regulatory Affairs (LARA)/Michigan Occupational Safety and
Health Administration (MIOSHA) policy and instructions for all
LARA responsibilities under the partnership agreement between
the United Automobile Workers (UAW) International Union,
Ford Motor Company, Automotive Components Holding
(ACH), and MIOSHA.
II.
Scope:
This instruction applies program-wide.
III.
References:
None.
IV.
Distribution:
MIOSHA Staff; OSHA Lansing Area Office; General;
MIOSHA Connection (i.e., SharePoint Site); MIOSHA Weekly;
and Internet Accessible.
V.
Cancellations:
All previous versions of this agency instruction.
VI.
History:
History of previous versions include:
MIOSHA-GEN-04-2R2, May 2, 2012.
MIOSHA-GEN-04-1R, January 10, 2006.
MIOSHA-GEN-04-1, May 7, 2004.
VII.
Contact:
Nella Davis-Ray, Division Director
VIII.
Originator:
Martha B. Yoder, Director
Michigan Occupational Safety and Health Administration
MIOSHA-GEN-04-1R2
May 22, 2012
UAW/Ford/ACH/MIOSHA Partnership (Revised)
Executive Summary
In December 2002, MIOSHA created Agency Instruction MIOSHA-GEN-04-1R Application of
the UAW-Ford-Visteon/MIOSHA Partnership Agreement to establish LARA/MIOSHA policy
and procedures for all LARA responsibilities under the partnership agreement between the UAW
International Union, Ford Motor Company, ACH, and MIOSHA.
Significant Changes
The May 2, 2012, version of the MIOSHA-GEN-04-2R2 UAW/Ford/ACH/MIOSHA Partnership
(Revised) was issued using the incorrect document identifier. The document identifier has been
corrected.
In the past, OSHA and MIOSHA had separate agreements with UAW/Ford Company and ACH.
OSHA and MIOSHA together now have one partnership agreement (see Appendix A).
The 2011 UAW/Ford Company and ACH written partnership agreement was added to the
instruction.
The Visteon name was removed from the instruction and replaced with ACH.
In the Responsibilities section of the instruction the roles of the MIOSHA Lead Division and the
MIOSHA Liaison were added and defined.
Removed Appendix C - Ford Acronyms Guide.
Edited and retitled Appendix D as UAW-Ford MIOSHA Partnership Site Documentation
Requirements. The Meet and Greet procedures were moved from this appendix to section XI of
the instruction.
Removed Appendix F - Calculating Total Case Incidence Rate (TCIR) and Days Away from
Work and Restricted Work or Job Transfer (DART) Rate.
Edited Appendix G - MIOSHA Report Outline by adding Outstanding/Overdue Items from
Previous Sharp-SOS Self Assessment and Discussion of SHARP-SOS Results. Also moved the
order of this appendix to Appendix F.
Removed Appendix H – Safety Hazard Survey Form.
Removed Appendix J – UAW/Ford/ACH Partnership Tracking Log.
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MIOSHA-GEN-04-1R2
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
I.
Purpose. This directive establishes Department of Licensing and Regulatory Affairs
(LARA)/Michigan Occupational Safety and Health Administration (MIOSHA) policy
and instructions for all LARA responsibilities under the partnership agreement between
the United Automobile Workers (UAW) International Union, Ford Motor Company,
Automotive Components Holding (ACH), and MIOSHA.
II.
Scope. This instruction applies program-wide.
III.
References. None.
IV.
Distribution. MIOSHA Staff; OSHA Lansing Area Office; General; MIOSHA
Connection (i.e., SharePoint Site); MIOSHA Weekly; and Internet Accessible.
V.
Application. This directive applies to all MIOSHA staff implementing LARA
responsibilities established by the partnership agreement between the UAW International
Union, the Ford Motor Company, ACH, and MIOSHA.
VI.
Cancellations. All previous versions of this agency instruction.
VII.
History. History of previous versions included:
MIOSHA-GEN-04-2R2, May 2, 2012.
MIOSHA-GEN-04-1R, January 10, 2006.
MIOSHA-GEN-04-1, May 7, 2004.
VIII.
Background. In December 2000, Occupational Safety and Health Administration
(OSHA), the UAW, the Ford Motor Company, and Visteon Corporation joined together
in a landmark partnership to improve worker safety and health at Ford and Visteon
facilities. Because this agreement only addressed plants located in federal OSHA states,
a similar agreement was pursued with MIOSHA.
In December 2000, the MIOSHA Director appointed the initial Ford Partnership
Implementation Team (now referred to as the Project Team). The team’s assignment was
to make recommendations to the UAW/Ford/Visteon/MIOSHA Steering Committee on
worksite selection, MIOSHA Day process, resources, compliance protocol, and
partnership performance evaluation.
In December 2003, the partnerships were revised and extended to November 14, 2006.
In July 2007, a new agreement was signed for the partnership with ACH replacing
Visteon as a principal. In June 2011, a new agreement was signed for the partnership
(see Appendix A). The instruction has been updated to reflect the changes to the
partnership and to continuously improve the MIOSHA Day processes.
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IX.
Definitions.
Focused Inspection – Enforcement investigations that utilize the protocols listed in the
partnership agreement. A focused inspection can result from the expansion of a
monitoring visit, a MIOSHA programmed inspection or an unprogrammed inspection
when there is an applicable protocol.
Meet and Greet – Informal meeting or teleconference between the MIOSHA Day team
leader and/or team representative(s), site management, and UAW site representative(s)
that precedes the scheduled MIOSHA Day meeting. Site documentation and injury and
illness data will be requested by MIOSHA during the Meet and Greet or prior to
teleconference.
MIOSHA Day – Meeting at a Ford/ACH location where MIOSHA representatives are
briefed by the plant manager, the union chairperson, and their leadership team. The
briefing will include a review of the injury and illness experience, developing trends, and
the results of the continuous internal comprehensive inspections conducted by the plant
safety engineer and the unit health and safety representative and the corrective actions
taken. This meeting will include a discussion on key protocol(s) that offer opportunities
for improvement in the site’s health and safety performance followed by a plant
walkthrough.
Monitoring Visits – One- or two-day informal walk-through scheduled after a MIOSHA
Day to verify and/or collect additional information about the facility. This visit will
involve a more in-depth records review, plant walk-through, and/or
employee/management interviews in relation to the protocols.
X.
Responsibilities.
A.
B.
Lead Division – A lead MIOSHA division is identified for providing oversight for
each partnership. As lead, the Consultation Education and Training (CET)
Division will:
1
Assign a MIOSHA liaison to work with the partner.
2.
Coordinate partnership activities.
3.
Ensure necessary partnership follow-up and evaluation.
MIOSHA Liaison – Appointed CET Division staff will:
1.
Ensure MIOSHA visit procedures follow UAW/Ford/ACH Partnership flow
chart (see Appendix B).
2.
Schedule MIOSHA Days.
3.
Schedule follow-up to assure corrective actions have been taken.
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C.
D.
E.
4.
Maintain ongoing communications with all parties.
5.
Prepare annual evaluation reports.
6.
Prepare final MIOSHA Day reports.
7.
Submit final reports to MIOSHA director for signature and distribution.
Steering Committee MIOSHA Representative – The MIOSHA director/deputy
director will:
1.
Approve Ford and ACH sites for MIOSHA Day meetings.
2.
Approve MIOSHA Day team leaders and members.
3.
Meet with the project team as appropriate to resolve any issues that arise
during the course of this partnership.
4.
Provide final reports to UAW, Ford, and ACH.
5.
Approve traditional inspections when recommended.
UAW, Ford, ACH, and MIOSHA Project Team – Appointed team member will:
1.
Recommend Ford/ACH sites for MIOSHA Day meetings.
2.
Recommend MIOSHA Day team leaders and members.
3.
Review data and reports from the MIOSHA Day meeting, monitoring
visits, or focused inspections.
4.
Submit final MIOSHA Day summary to MIOSHA director and deputy
director.
5.
Meet as appropriate to resolve any issues that arise during the course of
this partnership.
6.
UAW, Ford, ACH, and MIOSHA Partnership site files will be maintained
by the CET Division.
7.
The original partnership agreement will be maintained in Administration.
MIOSHA Day Team – This site specific group of MIOSHA CET and General
Industry Safety and Health Division (GISHD) staff will:
1.
Attend scheduled MIOSHA Day team meetings.
2.
Attend scheduled MIOSHA Day.
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F.
XI.
3.
Attend MIOSHA Day debriefings.
4.
Draft written MIOSHA Day summary.
MIOSHA Day Team Leader – Appointed MIOSHA CET staff will:
1.
Make initial contact with selected site to request site documentation and
schedule “meet and greet.”
2.
Schedule and facilitate team meetings.
3.
Coordinate MIOSHA Day team site visits.
4.
Distribute materials to MIOSHA Day team for site visits.
5.
Draft written MIOSHA Day report.
6.
Submit final written MIOSHA Day summary report to the partnership
coordinator.
7.
Follow-up with sites to assure corrections have been made.
Pre-MIOSHA Day Procedures.
A.
Site Selection – Sixteen Ford sites and six ACH sites in Michigan are covered by
the partnership agreement. During the three-year term of the agreement each of
the 22 sites will receive at least one MIOSHA Day meeting.
B.
Team Selection and Make-up – Each site selected for a MIOSHA Day meeting
will be assigned a MIOSHA Day team and team leader. Team size and make-up
may vary from site to site.
C.
“Meet and Greet” –This meeting can be done in person at the site or a phone
conference. Approximately two to four weeks prior to the actual MIOSHA Day
visit to the plant, the “meet and greet” will be held between MIOSHA and staff of
the plant to be visited. “Meet and greet” participants will include the following:

Plant Manager, Plant Chairperson, Human Resources Manager, Plant Safety
Engineers, and UAW Plant Health and Safety Representatives.

MIOSHA liaison and MIOSHA team leader.
This meeting is an opportunity for introductions, discussion of MIOSHA Day
scheduling concerns, and to exchange comments. The “meet and greet” is also an
opportunity to identify any special needs; for example, PPE in preparation for
MIOSHA Day. In addition, participants will review and finalize the MIOSHA
Day Agenda (see Appendix C). The MIOSHA Day team leader will follow the
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schedule and facilitate the MIOSHA Day visit. The MIOSHA Day will be
contingent upon receipt and review of requested site documentation (see
Appendix D) preferably within 30 days.
D.
XII.
XIII.
Team Meetings – After the team is selected and requested site documentation is
received, at least one pre-MIOSHA Day team meeting will be held. The purpose
of the meeting will be to review requested site documentation in preparation for
the site’s MIOSHA Day presentation and walk-through. The team will review
data provided by the site and will contact the plant to provide input for MIOSHA
Day presentations related to three Safety and Health Assessment Review ProcessSafety Operating System (SHARP-SOS) elements/protocols (see Appendix E). In
addition to pre-MIOSHA Day team meeting(s) there will be a post team meeting
(MIOSHA Day debriefing) to compile recommendations for the MIOSHA Day
report.
MIOSHA Day Visit.
A.
The purpose of this meeting is to provide the partners of the agreement with a
site-specific briefing on the progress made toward achieving the agreement’s
goals. The Ford and ACH site is responsible for hosting this meeting. The host
site will schedule presenters, provide the meeting location, and facilitate the
meeting. Each host site should request the attendance and participation of a UAW
chairperson and plant manager. MIOSHA will be responsible for paying for their
own lunch and refreshments.
B.
MIOSHA will be afforded the opportunity to conduct an informal walk-through
as part of the MIOSHA Day meeting including, upon request, receiving other
documentation from the partners. The walk-through should focus on SHARP
elements/protocols, include some working operations, and allow for informal
employee interviews. Findings of the walk-through and reasonable abatement
will be discussed during the MIOSHA Day closing session.
MIOSHA Day Debriefing.
A.
Within ten calendar days of the MIOSHA Day meeting, the MIOSHA Day team
will have a debriefing. The purpose of the debriefing is to provide information to
the team leader for the MIOSHA Day report. The MIOSHA Day report is a
concise written summary based on a report outline (see Appendix F). The final
MIOSHA Day report will be submitted to the MIOSHA director within 30 days of
the MIOSHA Day meeting for signature. Copies will be sent to the UAW, Ford,
and ACH Steering Committee members.
B.
The report will include justification for a future monitoring visit if deemed
necessary by the MIOSHA Day team. If no future monitoring visits are needed,
the site’s MIOSHA Day file will be closed once all follow-up issues and
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monitoring are completed. The letter and report may include a request for followup actions.
XIV. Monitoring Visit.
XV.
A.
Based on the MIOSHA Day debriefing and team recommendations, CET and
enforcement staff may return at a later date for a one- or two-day monitoring visit.
Per the partnership agreement, monitoring visits may occur at up to 33 percent of
the Michigan Ford and ACH sites. The monitoring visits shall only address the
inadequacies disclosed during the pre-MIOSHA Day team meeting or the
MIOSHA Day visit. The monitoring visits will involve a more in-depth records
review, site walk-through, and/or employee/management interviews in relation to
the protocols.
B.
MIOSHA staff conducting the monitoring visits should refer to the UAW, Ford,
and ACH partnership protocol document for suggested verification/resources (see
Appendix E). All apparent serious violations shall be brought to the attention of
the site management and employee representatives at the time they are
documented. Citations can be issued. The findings of the monitoring visits may
result in a team recommendation for a focused inspection. Prior to a decision for
a focused inspection, a review will be completed with the deputy director and
appropriate division directors.
Focused Inspection.
A.
A focused inspection can result from the expansion of a monitoring visit, a
programmed inspection, or an unprogrammed inspection when there is an
applicable protocol. The plant will be afforded an opportunity to conduct a
MIOSHA Day presentation during the focused inspection. This presentation may
occur if the plant has not participated in a MIOSHA Day within the last two years.
“Other than serious” (OTS) conditions that are identified in the course of the
focused inspection will be abated immediately, where practicable, and will not
result in MIOSHA citations. Should serious conditions be identified, they will be
abated immediately where practicable and MIOSHA will not be prohibited from
issuing citations.
B.
The focused inspection can be expanded to a traditional inspection with the
approval of the MIOSHA director/deputy director. The on-site findings of the
focused inspection may cause the MIOSHA representative(s) conducting the
inspection to immediately seek approval of the MIOSHA director/deputy director
to expand the focused inspection to a traditional inspection. The results of the
focused inspection will be sent to the facility’s plant manager and UAW plant
chairperson after the inspection is completed. The focused inspection leader will
draft a cover letter for the focused inspection (see Appendix G).
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XVI. Traditional Inspection. A traditional inspection at a Ford or ACH site triggered by the
focused inspection will be conducted in accordance with established MIOSHA
enforcement division procedures.
XVII. Unprogrammed Inspections. Unprogrammed inspections (complaint, fatality,
catastrophe, referral, or accident) when conducted, will use applicable protocols.
XVIII. Evaluating and Measuring Partnership Outcomes. The primary outcome measure for
partnership success is a reduction in injury and illness rates. Annually a MIOSHA
evaluation report will be developed and presented at a corporate meeting between the
parties. The report will address trends noted in data collected and a summary of common
issues identified during MIOSHA Days. In addition, the annual report will include a
review of partnership activities. Report activity measures include:
A.
Number of meet and greet sessions.
B.
Number of MIOSHA Days conducted.
C.
Number of unprogrammed inspections (pre-partnership vs. post-partnership).
D.
Number of programmed inspections (pre-partnership vs. post-partnership).
E.
Number of OTS violations.
F.
Number of consultations.
G.
Number of training programs conducted.
H.
Number of employees affected by all of the above activities.
I.
Number of follow-up actions taken by Ford/ACH.
J.
SHARP scores (pre-partnership vs. post-partnership).
XIX. Public Request for Partnership Information. All requests for information on activities
related to the partnership agreement between MIOSHA, the UAW International Union,
Ford Motor Company, and ACH shall be forwarded to the MIOSHA FOIA coordinator.
The coordinator shall respond to these requests in accordance with the Department FOIA
Procedures and Guidelines.
XX.
Appendices.
A.
UAW/Ford/ACH/MIOSHA Partnership Agreement, Appendix A.
B.
UAW/Ford/ACH/MIOSHA Partnership Flow Chart, Appendix B.
C.
MIOSHA Day Agenda, Appendix C.
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D.
Partnership Site Documentation Requirements, Appendix D.
E.
Partnership Protocols, Appendix E.
F.
MIOSHA Day Report Outline, Appendix F.
G.
Sample Cover Letter for Focused Inspection, Appendix G.
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APPENDIX A
2011 PARTNERSHIP AGREEMENT
BETWEEN
OSHA, MIOSHA, UAW INTERNATIONAL UNION,
THE FORD MOTOR COMPANY, and ACH-LLC
Partners
The following partners to this agreement include the U.S. Department of Labor,
Occupational Safety and Health Administration (OSHA); Michigan Occupational Health
and Safety Administration (MIOSHA), International Union, United Automobile,
Aerospace and Agricultural Implement Workers of America (UAW); the Ford Motor
Company (Ford) and Automotive Component Holdings, LLC (ACH-LLC). This
agreement covers all Ford Motor Company and ACH-LLC locations as described in
Appendix A.
The Ford Motor Company, ACH-LLC, OSHA and MIOSHA recognize that certain Ford
Motor Company and ACH LLC facilities are located in States which have assumed
authority for the enforcement of OSHA standards pursuant to Section 18 of the
Occupational Safety and Health Act.
Purpose/Scope
The partners agree to construct a partnership based on mutual respect and trust that
leverages the resources of all the parties through the systematic anticipation,
identification, evaluation, and control of health and safety hazards at Ford Motor
Company and ACH-LLC locations, thereby continuously reducing worker injury and
illnesses.
Goals/Strategies/Measurements
The primary goal of this partnership is to reduce injuries and illnesses year-over-year
from baseline OSHA log summary data at each Ford Motor Company and ACH-LLC
location through the creation of a pro-active health and safety culture and a cooperative
non-adversarial relationship that optimizes the resources of all parties. Performance
metrics used to monitor and track health and safety process performance shall include
the Total Case Incident Rates (TCIR) and Days Away, Restricted and Job Transfer
(DART) rates. The participants may present information collected and reported using
Safety and Health Assessment Review Process-Safety Operating System (SHARPSOS) tools and on OSHA-MIOSHA Day visits where that information has been
contributory to achieving the goals of the partnership.
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Evaluation
A written annual evaluation will be developed by OSHA and it will address trends noted
in the injury and illness data based on a calendar year. Among the information included
in the evaluation will also be an analysis of the employer’s internal audit results,
protocol-related analysis and the results of the OSHA-MIOSHA Day visits for the
individual participating sites.
Benefits
1. Benefits will include inspection protocols (used to perform focused inspections)
and the diminished probability of wall-to-wall inspections under OSHA targeting
programs. The inspection protocols will result in shorter more focused
inspections. Inspection protocols address top causal factors of injuries and
illnesses previously identified by the partnership.
2. In addition, provided that the Ford or ACH-LLC facility is following the Ford and
ACH-LLC programs and joint processes, OSHA-MIOSHA agrees to maximum
penalty reductions based on the agency's current policies for good-faith
reductions for effective safety and health programs as detailed in the current
version of OSHA’s Field Operations Manual.
Verification
Annually, 33 percent of the participating sites will receive“OSHA-MIOSHA Day Onsite
Non- enforcement Verification Visit”. The date of the OSHA-MIOSHA Day visit will be
determined by the corresponding OSHA Office in conjunction with the site. Sites will
provide a predetermined OSHA Day Information Package, which includes their OSHA
300 log and SHARP-Safety Operating System information for the previous year to the
appropriate OSHA-MIOSHA office at least two weeks prior to the scheduled OSHAMIOSHA Day visit. OSHA-MIOSHA representatives will review this information prior to
the OSHA-MIOSHA Day visit.
The selection process for identifying sites that will receive OSHA-MIOSHA Day visits
will be developed by the Partnership Steering Team during their first meeting after the
signing of this agreement and annually thereafter.
OSHA-MIOSHA Day Meeting
Annually, 33 percent of Ford and ACH-LLC locations covered by this agreement (see
Appendix A) will conduct an annual OSHA- MIOSHA Day visit where the appropriate
local OSHA-MIOSHA representative(s) will be invited to the location and briefed by the
Plant Manager, the Union Chairperson and their leadership team. The briefing will
include a review of the injury and illness experience for the past year and any
developing trends as compiled by OHSIM. The briefing will also include a review of
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results from continuous internal comprehensive inspections conducted by the Plant
Safety Engineer and the Unit Health and Safety Representative and the corrective
actions taken. Additionally, the briefing will include the results of the Safety and Health
Assessment Review Process-Safety Operating System (SHARP-SOS) conducted since
the last OSHA-MIOSHA Day meeting and the corrective actions taken. The written
materials from the OSHA-MIOSHA Day meeting will be given to the appropriate OSHAMIOSHA partnership representative(s) for analysis, including Ford site managers, the
UAW, and OSHA’s National Office.
During the OSHA-MIOSHA Day, OSHA-MIOSHA will conduct an informal walk-through
of the facility. The purpose of the walkthrough is to verify that the information presented
in the OSHA-MIOSHA Day briefing is an accurate portrayal of what is occurring within
the facility. If observable conditions and program implementation are not consistent
with the information provided at the OSHA-MIOSHA Day meeting, a focused inspection
could be initiated and expanded to a traditional inspection with the approval of the
OSHA-MIOSHA representative. During the visit, if OSHA-MIOSHA personnel identify
serious hazards that site management refuses to correct, OSHA-MIOSHA will make a
referral for an enforcement inspection.
OSHA may return at a later date for a monitoring visit as an extension to the OSHAMIOSHA Day visit, to investigate complaints, referrals, and to perform Site Specific
Targeting (SST) inspections at partnership plants. Monitoring visits are considered
enforcement visits, and as such citations may be issued at that time. The OSHA
National Office will be notified when a monitoring visit is scheduled. The OSHAMIOSHA members of the steering committee will coordinate the monitoring visits.
It is understood that items identified as opportunities for improvement by OSHAMIOSHA will be prioritized for action, with timing milestones as determined by good
health and safety practice and by joint agreement of Ford, ACH-LLC, UAW-Ford and
UAW-ACH LLC Health and Safety Professionals. If these tenets are adhered to,
OSHA- MIOSHA will not use this information as justification for Willful violations. In
general, items identified by Ford, ACH-LLC and the UAW or OSHA-MIOSHA will be
abated immediately where practicable, and those will not result in OSHA citations.
Inspection Protocols
Inspection protocols will be based on the annual analysis of U.S. injury and illness
experience from the Occupational Health and Safety Information Management (OHSIM)
System and from similar analyses provided OSHA for the location selected for
inspection. In general, the protocol will include an investigation of hazards or issues
covered under joint programs developed by the National Joint Council on Health and
Safety (NJCHS). See Appendix B for a list. Protocols may be added/removed via
steering committee consensus without making modifications to this agreement.
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Management and Operation of Partnership
A steering committee will be designated consisting of members from Ford, ACH-LLC
the UAW, and OSHA-MIOSHA. OSHA-MIOSHA steering committee representatives
will consist of representatives from OSHA’s Directorate of Cooperative and State
Programs (DCSP), OSHA Region V, Michigan OSHA, and from any State Plan states
who sign similar agreements with the partners. The purpose of the steering committee
will be to develop an implementation plan, review data and reports, and to meet as
appropriate to resolve any issues that arise during the course of this partnership. The
steering committee will also be involved in the coordination of site visits and monitoring
inspections.
Ford/UAW and ACH-LLC/UAW
1. Ford and ACH-LLC will provide a complete OSHA Day information packet to the
appropriate OSHA-MIOSHA Office 2 weeks prior to the scheduled OSHAMIOSHA Day.
2. Ford and ACH-LLC agree to facilitate the inspection process by providing OSHAMIOSHA compliance officers access to the plant injury and illness reports related
to the protocols.
3. A corporate annual report for Ford and ACH-LLC will be developed and
presented at an annual national meeting between the parties. The report will
address trends noted through data analysis. Among the information included in
the annual review will be an analysis of the internal audit results, and information
from each site’s verification report. This report should additionally discuss
progress towards meeting the partnership goals.
OSHA-MIOSHA:
1. OSHA-MIOSHA will continue to make maximum use of inquiry letters, phone and
fax procedures for minor investigations.
2. OSHA MIOSHA inspections to investigate employee complaints, serious injuries
or fatalities, and National or Local emphasis programs are not precluded by this
agreement.
3. Ford and ACH-LLC plants selected for General Schedule inspections from the
OSHA Site-Specific Targeting (SST) list will receive a focused inspection. The
focused inspection will include an evaluation of the inspection protocols listed in
the agreement.
4. The OSHA-MIOSHA compliance officer will review the required recordkeeping
information; conduct a walk through inspection, and interview workers in
accordance with OSHA inspection procedures.
5. OSHA-MIOSHA will complete and submit an OSHA-MIOSHA Day Report within
30 days of the annual OSHA-MIOSHA Day for each site participating in the
partnership. Reports shall be forwarded to OSHA’s National Office, Ford and
ACH LLC Corporate Safety personnel, and UAW-Ford Joint Health and Safety
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Leadership. The OSHA-MIOSHA Day report template can be found in Appendix
C of this document.
Employee and Employer Rights
This partnership does not preclude employees and/or employers from exercising any
right provided under the OSH Act (or, for federal employees, 29 CFR 1960), nor does it
abrogate any responsibility to comply with rules and regulations adopted pursuant to the
Act. For MIOSHA, the provisions of this agreement identified herein, shall not modify
any legal or contractual rights and remedies.
Employee awareness and involvement will be facilitated through the contractual
processes developed by Ford, ACH-LLC and the UAW.
Term of Partnership
This agreement will terminate on December 31, 2013. The partnership will end with
respect to an ACH-LLC facility upon the sale, closure, or transfer of operations to a third
party at the facility. If any signatory to this agreement wishes to modify, amend or
terminate their participation prior to the established termination date, written notice
within 30 days shall be provided of the intent to withdraw to all other signatories and this
agreement will terminate as to the party withdrawing on that date.
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2011 PARTNERSHIP RENEWAL AGREEMENT
Signature Page
OSHA, MIOSHA, UAW INTERNATIONAL UNION,
THE FORD MOTOR COMPANY, and ACH-LLC
June, 2011
FOR FORD MOTOR COMPANY
FOR U.S. DEPARTMENT OF LABOR
(OSHA)
__________________________________
Jim Tetreault
Vice President
North American Manufacturing Operations
_________________________________
David Michaels, PhD, MPH
Assistant Secretary of Labor for
Occupational Health and Safety
FOR MICHIGAN OSHA
__________________________________
Greg Stone
Director, Occupational Health and Safety
__________________________________
Steve Arwood, Deputy Director,
Department of Licensing and Regulatory Affairs
__________________________________
Mark Jones, Company Co-Chair
National Joint Committee on Health and
__________________________________
Douglas J. Kalinowski, Director
Michigan Occupational Safety and Health
Administration
FOR ACH-LLC
FOR UNITED AUTOMOBILE WORKERS
__________________________________
Mark Blair,
President and Chief Executive Officer
__________________________________
Donald R. Hunter, Assistant Director
National Ford Department Health and Safety
__________________________________
Floyd Ford, UAW Co-Chair, National Joint
Committee on Health and Safety
___________________________________
John Rupp, Assistant Director of Health and Safety
Department, International UAW
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
Appendix A
Participating Sites within Federal OSHA Jurisdiction
FORD LOCATIONS
Chicago Assembly Plant
Chicago, Illinois
Chicago Stamping Plant
Chicago, Illinois
Kansas City Assembly Plant
Kansas City, Missouri
Buffalo Stamping Plant
Ohio
Hamburg, New York
Cleveland Engine Plant 2
Brook Park, Ohio
Lima Engine Plant
Lima, Ohio
Ohio Assembly Plant
Avon lake, Ohio
Sharonville Transmission Plant
Sharonville, Ohio
Walton Hills Stamping Plant
Walton Hills, Ohio
* ACH-LLC LOCATIONS
Sandusky Plastics Plant
Cleveland Engine Plant 1
Sandusky, Ohio
Brook
Park,
*Note: OSHA and ACH-LLC recognize and agree that the
terms, conditions, and obligations associated with this
partnership agreement shall expire in the event of and
immediately upon divestiture of the Sandusky Plastics
Plants from ACH-LLC.
TBD: Louisville and Kentucky Truck Currently not included
in partnership.
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
Participating Sites in Michigan (State Plan OSHA Jurisdiction)
Dearborn Tool and Die Plant
Dearborn/Rouge Site, 3001 Miller Rd., Dearborn, MI 48120
Dearborn Truck Plant
Dearborn/Rouge Site, 3001 Miller Rd., Dearborn, MI 48120
Dearborn Diversified Manufacturing Plant Dearborn/Rouge Site, 3001 Miller Rd., Dearborn, MI 48120
Dearborn Stamping Plant
Dearborn/Rouge Site, 3001 Miller Rd., Dearborn, MI 48120
Dearborn Engine and Fuel Tank Plant
Dearborn/Rouge Site, 3001 Miller Rd., Dearborn, MI 48120
Michigan Assembly Plant
Wayne, 38303 Michigan Avenue, Wayne, MI 48184
Woodhaven Stamping Plant
Woodhaven, 20900 West Rd., Woodhaven, MI 48183
Livonia Transmission Plant
Livonia, 36200 Plymouth Rd., Livonia, MI 48150
Van Dyke Transmission Plant
41111 Van Dyke, Sterling Heights, MI 48310
Romeo Engine Plant
701 East 32 Mile Road, Romeo, MI 48065
Sterling Transaxle Plant
39000 Mound Road, Sterling Heights, MI 48310-2799
Rawsonville Parts Plant
Textile and McKean, Rawsonville, MI 48197
Brownstown Parts Redistribution Center
25555 Pennsylvania Road, Romulus, MI 48174
National PDC (Livonia)
11871 Middlebelt Road, Livonia, MI 48150
Woodhaven Forge Plant
24189 Allen Road, Woodhaven, MI 48183
*
ACH-LLC LOCATIONS (Michigan)
Saline Instrument and Plastics Plant
7700 Michigan Ave., Saline MI 48176
Sheldon Road Plant
14425 Sheldon Road., Plymouth Twp., MI 48170
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
Appendix B
Inspection Protocols
1. Ergonomics
2. Energy Control and Power Lock Out (ECPL)
3. Confined Space Entry
4. Hearing Conservation and Noise Control
5. Lifting and Rigging
6. Machine/Equipment Guarding
7. Heat Stress
8. Personal Protective Equipment (PPE)
9. Chemical Safety Training (Hazard Communication)
10. Powered Material Handling Vehicles (PMHV)
11. Maintenance Vehicles
12. Working at Heights
13. Electrical Safety
14. Emergency Preparedness
15. Walking and Working Surfaces
Note: Protocols may be added/removed via steering committee consensus without making
modifications to this agreement.
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
Appendix C
OSHA-MIOSHA DAY REPORT TEMPLATE
1. Date:
2. Plant Name/Location:
3. Key Participants:
Ford/ACH:
UAW:
OSHA:
MISOHA:
4. Observations from Walk-Around:
5. Top 3 Opportunities for Improvement (Please include a follow-up date for each
“Opportunity” to check on progress/resolution):
6. Best Practices Observed:
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
7. Injury and Illness Trends
Recordable Rates [Last Three Years]
(NOTE: See discussion of injury & illness statistics in section 8 of this report.)
YEAR
Total
Cases
Total
Current YTD
with
Recordable
and prior two
Hours
TCIR
Days
Injuries and
full years
Away
Illnesses
from
Work
*Current
Year 2
Year 3
*Year to date
19
LTC
R
Total Cases
with Days
Away from
Work or
Restricted
Activity
DART
MIOSHA-GEN-04-1R2
May 22, 2012
UAW/Ford/ACH/MIOSHA Partnership (Revised)
8.
Discussion of Injury and Illness Trends:
9.
Outstanding/Overdue Items from Previous SHARP-SOS SELF ASSESSMENTS:
10. Noted Issues of Non-Compliance (if any)
11. Discussion of SHARP-SOS Results Trends:
Yes
No
Reasons:
-keeping issue: ______________________________________________
_____________________________
13. Other Comments:
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
APPENDIX B
UAW/MIOSHA PARTNERSHIP FLOW CHART
Unprogrammed Inspection:
Programmed Inspection:
-Complaint
- Fatality/Catastrophe
-Referral
-Accident
Meet and Greet
-SST (Site Specific Targeting)
-Emphasis Programs
Site Afforded
Opportunity for
Abbreviated
MIOSHA Day
MIOSHA Day
Team
MIOSHA Day
Focused
Inspection
MIOSHA Day
Team
Completed
One or Two Day
Monitoring
(Compliance and
CET Involvement)
Monitoring Team
Review
Deputy Director
Wall to Wall
Inspection
Site Completed
Project Team
Review
5/9/08
21
Project Team
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May 22, 2012
UAW/Ford/ACH/MIOSHA Partnership (Revised)
APPENDIX C
MIOSHA Day Agenda
Morning Session (120 – 180 minutes):

Welcome and participant introductions

Review previous MIOSHA Day Report

Review injury and illnesses statistics

Discuss MIOSHA visits

Identify high priority protocols with respect to specific areas of plant

Discuss action plans/needs
-MIOSHA assistance
-Corporate assistance
-NJCHS assistance

Begin Shop Floor Tour w/emphasis on opportunities, best practices, other process
challenges.
Afternoon Session (120 – 180 minutes):

Continue Shop Floor Tour w/emphasis on opportunities, best practices, and other process
challenges.

Actions taken or being taken by the plant to address the high priority issues

Close with responsibilities identified
The final agenda will be mutually agreed upon. The Team Leader will request a finalized
agenda from the host site.
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
APPENDIX D
2011 UAW-Ford MIOSHA Partnership Site Documentation Requirements
Plant Site H&S Data and Process Performance Material: The following information will be
prepared by the plant health and safety function and submitted to MIOSHA by the plant safety
function preferably two weeks prior to the actual visit. Information should be submitted to the
MIOSHA representative identified during the Meet and Greet conference call.






Status Report for those items identified during the last MIOSHA Day Visit.
MIOSHA Recordkeeping Summary (i.e. 300A) for previous 3 years.
Most recent Industrial Hygiene Visit Assessment (i.e. monitoring, sampling, other) and
actions taken to address recommendations (if applicable).
Top three opportunities for improvement (*should align with department injury-illness rate
data provided to the plant by staff OHS below).
Top three best practices (unique and noteworthy for sharing).
Latest SHARP Self Assessment Score.
Staff OHS H&S Data and Process Performance Material: The following information will be
prepared by staff OHS and submitted to the Plant Safety function. This information should be
consolidated with the plant information reflected above and submitted to MIOSHA by the plant
safety function preferably two weeks prior to the actual visit.



Top 5 departments with the highest TCIR and DART "injury rates."
 Top five injuries in each department with a brief description of each case.
Top 5 departments with the highest TCIR and DART "illness rates."
 Top five illnesses (incl ergo cases) in each department with a brief description of each
case.
List of all traumatic injuries including fractures, amputations, avulsions, eye and crushing
injuries.
 Brief case description of each.
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
APPENDIX E
Safety and Health Assessment Review Process-Safety Operating System (SHARP-SOS)
Elements/Protocols
1. Ergonomics
2. Energy Control and Power Lock Out (ECPL)
3. Confined Space Entry
4. Hearing Conservation and Noise Control
5. Lifting and Rigging
6. Machine/Equipment Guarding
7. Heat Stress
8. Personal Protective Equipment (PPE)
9. Chemical Safety Training (Hazard Communication)
10. Powered Material Handling Vehicles (PMHV)
11. Maintenance Vehicles
12. Working at Heights
13. Electrical Safety
14. Emergency Preparedness
15. Walking and Working Surfaces
Note: Protocols may be added/removed via steering committee consensus without making
modifications to this agreement.
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
APPENDIX F
MIOSHA Day Report Outline
1.
Worksite Name and Location:
2.
Ford/Visteon/UAW/MIOSHA Participants:
3.
Date:
4.
Injury and Illness Trends: Recordable Rates [Last Three Years]
(NOTE: See discussion of injury & illness statistics in section 5 of this report.)
YEAR
Current YTD
and prior two
full years
Hours
Total
Recordable
Injuries and
Illnesses
TCIR
Total Cases
with Days
Away from
Work
LTCR
*Current
Year 2
Year 3
*Year to date
5.
Discussion of Injury and Illness Trends:
6.
Top Three Opportunities for Improvement:
7.
Observations from Walkaround:
8.
Outstanding Items from Previous MIOSHA Inspection:
9.
Best Practices Observed:
10.
Outstanding/Overdue Items from Previous Sharp-SOS Self Assessment:
25
Total Cases
with Days
Away from
Work or
Restricted
Activity
DART
MIOSHA-GEN-04-1R2
May 22, 2012
UAW/Ford/ACH/MIOSHA Partnership (Revised)
11.
Discussion of SHARP-SOS Results Trends:
12.
Monitoring Visit Recommended? If yes, give justification(s):
13.
Other Comments:
14.
Future Actions:
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
APPENDIX G
(SAMPLE COVER LETTER FOR FOCUSED INSPECTION)
Insp #:
Reply to:
MIOSHA – (Division)
7150 Harris Drive, P.O. Box 30644,
Lansing, MI 48909-8144
------ (Date) ------Mr./Ms. ------ (Name) ------------- Plant Manager
Mr./Ms. ------- (Name) ------------ UAW Plant Chairman
Ford Motor Company
-------- (Full Company Address) ----------
Dear Mr./Ms. --------------------------- and Mr./Ms. ----------------------------:
(Plant Manager)
(UAW Plant Chairperson)
On --- (Date) ------, representatives of MIOSHA enforcement division initiated a focused safety and
health inspection of your plant operations. The inspection was jointly conducted by ----- (Name) ---, Industrial Hygienist, ----- (Name) ----, General Industry Safety Officer, and ----- (Name) ----,
Construction Safety Officer under the premise and provisions of the Ford/ACH/UAW/MIOSHA
Partnership Agreement.
We held an opening conference with both of you during which we discussed the purpose and scope
of the inspection. Also present at the conference were -- (Names of other people present during
opening conference).
The primary scope of this inspection was to review your plant’s compliance status with respect to
applicable MIOSHA standards and regulatory requirements, including injury and illness record
keeping, and workplace MIOSHA posting requirements. Other potential safety or health hazards
that we observed, or that were brought to our attention by employees during the inspection, were
also addressed.
In accordance with the provisions of the Ford/ACH/UAW/MIOSHA partnership agreement, the
focused inspection involved detailed review and evaluation of your facility’s safety and health
programs, as well as review of your facility’s implementation of the SHARP elements/protocols,
including written programs, employee medical/exposure records, employee training records, and
safety & health audit records. We conducted a walk-through inspection of the ------ (indicate area
of plant covered) ------ area of the facility, and held interviews with some of your employees on
duty.
Inspection Findings
During this inspection, we determined the following serious violations in your facility:
(List serious violations that are being cited in this inspection)
In accordance with the provisions of the partnership agreement, the enclosed citations have been
issued accordingly (with maximum penalty reduction) for the above listed violations. The
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
inspection also uncovered various non-serious safety/health violation conditions. No citation is
issued on the non-serious violations, since the items were abated during the course of the inspection.
Our findings on the review of your facility’s SHARP program elements/protocols are explained in
this report. Also, other general safety and health recommendations are outlined in this report.
We thank you for opportunity to work with the management officials, union representatives, and
other plant personnel at the Wayne Assembly and Stamping Plant. We hope the focused inspection
was beneficial to your plant operations.
Sincerely,
(Name)
Division Director
Enclosures:
cc:
Citations
- SHARP Protocols Review Findings
- List of Non-serious safety/health potential violation conditions determined
- General Recommendations
Martha B. Yoder
Bart Pickelman
Harry Tarrant, Safety-Security Manager
North American Manufacturing Operations 6100 Mercury Drive Fairlane North Bldg. 2 Mail Drop 270
Dearborn, Michigan 48126-2746
(313) 313-805-8072
htarrant@ford.com
Mark Jones, Company Co chair NJCHS
UAW-Ford National Programs Center
151 West Jefferson
Detroit, Michigan P.O. Box 33009
313-392-7019
markjones@ford.com
Floyd Ford; UAW Co Chair NJCHS
UAW-Ford National Programs Center
151 West Jefferson
Detroit, Michigan P.O. Box 33009
(313) 594-6961
floydford@ford.com
John Lawson, Regional Safety & Security ManagerVehicle Operations, N.A. Manufacturing
One American Road
Dearborn, Michigan 48126-2701
Section 530 - Office A-3
(313) 323-0307
jlawson5@ford.com
John Rupp, Jr.
UAW Health & Safety
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UAW/Ford/ACH/MIOSHA Partnership (Revised)
Dave Miller Building
8731 E. Jefferson Avenue
Detroit, MI 48214
(313) 926-5563
(313) 926-5755
jrupp@uaw.net
29