An Overview of SHARP Safety & Health Achievement Recognition Program

Recognizes small business employers who have used OSHA's On-site Consultation Program services and operate an exemplary injury and illness prevention program. Acceptance of your worksite into SHARP from OSHA is an achievement of status that singles you out among your business peers as a model for worksite safety and health.On-site Consultation Program

Who is eligible for SHARP? Businesses already participating in OSHA’s On- site Consultation Program. New businesses who want to participate. – The size requirements for employer participation in SHARP are 250 or fewer onsite employees and fewer than 500 corporate-wide employees.* * The upper corporate size limit does not apply to individual franchises.

What are the benefits of SHARP? Provide Protection Create a Culture Build a Reputation Save Money Avoid Reduce the Likelihood of an OSHA Inspection* * Participation in SHARP does not eliminate the responsibilities of owners or rights of workers under the Occupational Safety and Health Act. Under OSHA, the following types of incidents can trigger an OSHA enforcement inspection at SHARP sites: formal complaints, fatality, imminent danger situations and any significant events as directed by the Assistant Secretary of OSHA.

SHARP: Provide Protection Protect workers from all safety and health hazards that may exist at your workplace; Work with OSHA to identify and implement best practices to protect your workers; Develop and innovative injury and illness prevention program for your business that protect your workers.

SHARP: Create a Culture Create a better working environment free of safety and health hazards; Boost worker morale by involving workers in creating a culture that emphasizes a safe and healthful workforce; Improve communication among workers and management; Encourage safety in the community as workers may transfer safe and healthy work practices outside of workplace.

SHARP: Build a Reputation Receive official recognition from OSHA for your achievement of SHARP status and for maintaining an exemplary injury and illness prevention program; Become a leader in your industry by providing a safe and healthy workplace for workers; Attract skillful workers looking to join a business that is at the forefront of its industry in providing a safe and healthy workplace for its workers.

SHARP: Save Money Lower worker compensation insurance premiums; Improve your worker retention and reduce costly turnover; Reduce worker days away from work to keep operations and production running smoothly.

How can my small business participate in SHARP? Request a comprehensive On-Site Consultation visit; Involve employees in the consultation process; Correct all hazards identified by the consultant; Implement and maintain an injury and illness prevention program than, at a minimum, addresses OSHA’s Safety and Health Program Management Guidelines; Maintain your company’s Days Away, Restricted, or Transferred (DART) rate and Total Recordable Case (TRC) rate below the national average for your industry; and Agree to notify the On-site Consultation office prior to making any changes in the working conditions or introducing new hazards into the workplace.

What happens after my small business achieves SHARP? Recognition with a certificate and flag; Exemption from OSHA programmed inspections for up to 2 years. After initial certification, you may request SHARP for up to 3 years. – Apply for renewal during the last quarter of exemption period; – Allow a full service comprehensive visit to ensure injury and illness prevention program has been effectively maintained or improved; – Continue to meet all SHARP eligibility criteria; and – Submit an Interim Year SHARP Site Self-Evaluation.

Active OSHA SHARP Sites: FYs Source: Consultation Recognition & Exemption Activity Report for FY 2015 Q2 generated on April 9, Totals include 21(d) and 23(g) On-site Consultation Project data.

Active OSHA SHARP Sites in Federal and State Plan States by Region: FY 2015

SHARP Sites by State * Incomplete List

Future of OSHA’s SHARP Company size limitations Incentive programs restrictions Process Safety Management (PSM) company considerations

“OSHA is always looking for ways to ensure that compliance assistance resources are used effectively as possible to help small businesses. When it came to OSHA's attention that subsidiaries of large, multi-national corporations, some with tens or hundreds of thousands of employees, were participating in SHARP, OSHA concluded that additional requirements were needed to ensure that SHARP resources would be more effectively targeted to the small employers that really needed them. The subsidiaries of larger employers likely had the economic means to provide safety and health assistance for their subsidiaries without Federal Assistance and therefore would be better served by participating in the Voluntary Protection Program (VPP), which is designed to recognize larger companies.” Why did OSHA change the SHARP size policy?

SHARP Size Policy 2014 Memo OSHA's November 24, 2014 memorandum sought to refocus On-site Consultation resources on the needs of the five million small employers in the nation by requiring companies that exceed the size limit to transition from SHARP to the Voluntary Protection Program (VPP). These companies were allowed to remain in SHARP until their VPP evaluation was completed.Voluntary Protection Program (VPP) 2015 Memo On March 20, 2015, OSHA rescinded the November 2014 policy memorandum and issued a revised memorandum that : Allows all worksites of any size that are currently participants in SHARP to remain in SHARP and continue to reapply for SHARP. Allows worksites that chose to leave SHARP because of the 2014 memorandum to automatically rejoin SHARP. Reminds states that if they want to allow new subsidiaries of large firms to become participants in SHARP, they can use 100% of state funds instead of OSHA grant funds. Permits current SHARP sites that grow in size beyond the size limits identified in the policy to remain in the program.

“Companies with incentive programs that have the potential to discourage reporting of workplace injuries and hazards do not meet the injury and illness prevention program requirements to qualify as a SHARP participant. An incentive program that focuses on injury and illness numbers often has the effect of discouraging workers from reporting an injury or illness. When an incentive program discourages workers reporting injuries or hazards or (in particularly extreme cases) disciplines workers for reporting injuries or hazards, problems remain concealed, investigations do not take place, nothing is learned or corrected, and workers remain exposed to harm.” Why did OSHA restrict incentive programs?

“Incentive Programs” Restrictions Applicant for SHARP Participation “The CPM (Consultation Program Manager (or designee)) must ensure that a SHARP applicant's incentive program does not contain provisions that could discourage injury and illness reporting, worker participation, or both. The CPM must advise the applicant of OSHA's position and SHARP policy. The applicant may choose to make an immediate change to its incentive program that will bring the program in line with SHARP policy. If the applicant needs 90 days or less to eliminate the disincentive, to revise its program, or both, the CPM should reappraise the site once the change to the applicant's incentive program takes place. If an applicant for SHARP status refuses to make the needed change, the CPM will inform the site that they are not currently eligible for SHARP participation.” Current SHARP Participant “If a site has already been awarded SHARP status, the CPM must advise the participant of OSHA's position and SHARP policy and confirm that the existing incentive program complies with Agency policy. To confirm that an incentive program does not contain provisions that could discourage injury and illness reporting, incorporate this element into the review criterion when participants submit interim year self-evaluations, enter the reapplication processes, and provide other reports. If disincentives are found, the CPM will assist the SHARP participant in reaching compliance with OSHA's position and SHARP policy.”

“…some On-site Consultation Projects do not have qualified Process Safety Management personnel on staff.” OPTIONS: Assistance with onsite evaluations from Compliance Assistance Specialists. Assistance with onsite evaluations from OSHA’s Health Response Team. Why does OSHA consider PSM with SHARP ?

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