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Does your company have what it takes to be SHARP?

In this article, I will provide you with specific SHARP information exclusively for the maritime and general industries. We will discuss the advantages of being a SHARP company, the process to get the ball rolling, and the program requirements. For those in the Construction industry, do not despair. I’ve got you covered in next month’s e-Letter.

The Occupational Safety and Health Agency (OSHA) encourages employers to operate exemplary safety and health management systems. To reward such employers, OSHA allows those who meet the qualifications for SHARP to be removed from OSHA's programmed inspections scheduled for up to two (2) years upon initial approval or for three (3) years for subsequent renewal periods.

The SHARP program is an OSHA funded program designed to recognize small business employers who have used the University of South Florida SafetyFlorida Consultation Program’s 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.

To begin this SHARP process, companies must:
1. Request a consultation visit that involves a Full-service both visit that provides a complete safety and health hazard survey of all working conditions, equipment, processes and OSHA-mandated safety and health programs at the worksite, including a comprehensive assessment of the worksite's safety and health management system; and
2. Have at least one (1) year of operating history at the particular worksite for which the employer is seeking SHARP participation.
3. The size requirements for employer participation in SHARP are 250 or fewer on-site employees and fewer than 500 corporate-wide employees. The upper corporate size limit does not apply to individual franchisees. There may be sites that are a part of holding companies where one would not expect the parent company to provide safety and health resources to the site. This particular situation would be addressed on a case-by-case basis.

Program requirements:
1. Receive a Full-service both safety and health consultation visit and a comprehensive review of their safety and health management system with all hazards found by the consultant(s) corrected;
2. Receive a score of at least "2" on all 50 basic attributes of the Form 33. Additionally, all "stretch items" of the Form 33 must be scored. "Stretch items" are the safety and health attributes above the basic attributes of a foundational safety and health management system, such as employee participation in hazard prevention and control activities within the worksite;
3. Agree to notify the Consultation Program Director and request a subsequent on-site consultation visit when changes in working conditions or work processes occur that may introduce new hazards into the workplace;
4. Employers DART and TRC rates for the preceding year must be below the Bureau of Labor Statistics rates for the specific industry’s NAICS code.
5. Not have rate-based incentive programs that discourage employee reporting of work-related injuries and illnesses or safety and health hazards; and
6. Submit a request for SHARP participation to Consultation Program Manager after receiving their full service visit and correcting all the identified hazards.

If you have satisfied all SHARP participation guidelines, USF Safety Consultation Program may recommend your site for final approval. Employers who meet all the requirements for recognition and exemption will have the names of their establishments removed from OSHA's Programmed Inspection Schedule for a period of not less than one year. The exemption period will extend from the date of issuance by the Regional Office of the certificate of recognition

The renewal exemption period will be based on OSHA approval. You must apply for renewal during the last quarter of the initial exemption period. Of course, a fatality, a formal complaint, or a catastrophe involving the hospitalization of one or more employees will trigger an inspection of your site by Federal OSHA at any time during the initial or renewal periods

If you have otherwise met the eligibility requirements but need some time to implement an effective safety and health management system you may request an OSHA inspection deferral (Pre-SHARP) of up to 18 months. During this time you will not be inspected by OSHA, but your consultant will provide you with an action plan and will visit you on an interim basis to help you qualify for the SHARP.

The USF SafetyFlorida Consultation Program has exciting news for those who work in the construction industry. We have released a new SHARP award program just for you! Stay tuned next month for Part 2, in which I will cover the advantages of the program, the initiation process and the program requirements.