• Prevent and reduce worker injuries and illnesses

• Develop baseline data on existing INVISTA systems: Compliance Assurance Management System (CAMS) and Contractor Safety (CSO) processes
• Review injury and illness information, identify causal factors, develop SHMS to address
• Implement VPP principles at participating facilities
• Use culture/survey from Texas A&M University
• Expand awareness of the value of safety and health management systems
• Continue to Enhance Contractor safety and Prequalification process
• Continue to enhance Process Safety Management programs at covered facilities

• Self assessments results
• Total Case Incident Rate (TCIR) and percentage change versus baseline
• Days Away, Restricted or Transferred (DART) rate and percentage change versus baseline
• Percentage of change(s) in costs (e.g. worker’s comp costs)
• Contractor TCIR rates
• Number and % of INVISTA contract companies and workers participating in training or sharing best practices in safety and management systems
• PSM compliance audit results
• Survey results

• Prevent and reduce worker ergonomic injuries and illnesses at applicable facilities

• Develop baseline data on existing INVISTA systems (CAMS and CSO processes)
• Review injury and illness information, identify causal factors
• Enhance ergonomic program management
• Establish systems that identify ergonomic risk factors, evaluate and control ergonomic risk, and share best practices in ergonomic program management

• Ergonomic risk factors identified and percent controlled
• Ergonomic-related TCIR and DART rates

• Improve communication and knowledge sharing between OSHA and INVISTA

• Enhance local relations between OSHA and INVISTA
• Share best practices and lessons learned
• Identify case studies or other joint projects that advance the knowledge of the practical implementation of safety and health management systems
• Attend and network at conferences
• Improve safety and health knowledge sharing process between INVISTA facilities

• Facility feedback from annual evaluation
• Number of best practices, success stories, lessons learned, and case studies shared

• Increase Voluntary Protection Programs participation

• Identify potential VPP facilities
• Seek mentors for facilitation of VPP application
• Use tools such as OSHA Challenge to track facilities’ progresses to VPP qualification
• Increase participation in SGE program

• Environmental, Health and Safety (EHS) management system baseline assessment score
• Number of facilities in VPP
• Number of INVISTA company Special Government Employees (SGE); Number of SGEs trained and number of onsite evaluations performed
• Scorecard measuring improvement such as OSHA Challenge modified to reflect INVISTA terminology

Construction

Amputations in Manufacturing

General Industry

X

Amputations in Construction

Oil and Gas Field Services

Blast Furnaces and Basic Steel Products

Preserve Fruits and Vegetables

Blood Lead Levels

Public Warehousing and Storage

Concrete, Gypsum and Plaster Products

Ship/Boat Building and Repair

Ergo/Musculoskeletal

X

Silica-Related Disease

Landscaping/Horticultural Services

1/18/2009

End Date

12/31/2009

Christian Wojnar

Directorate of Cooperative and State Programs (DCSP), Office of Partnerships and Recognition (OPR), Washington, DC

# Active Employers

7

# Active Employees

3000

Participating Facility

SIC

NAICS

Description

INVISTA Applied Research Center, Newark, DE

8731

541380

Testing laboratories

INVISTA Athens, Athens, GA

2281

313112

Fiber, yarn, and thread mills

INVISTA Dalton, Dalton, GA

8731

541380

Testing laboratories

INVISTA La Porte, La Porte, TX

2869

325199

Chemical manufacturing

INVISTA Orange, Orange, TX

2869

325199

Chemical manufacturing

INVISTA Seaford, Seaford, DE

2281

313112

Fiber, yarn, and thread mills

INVISTA Victoria, Victoria, TX

2869

325199

Chemical manufacturing

Required

Performed

a. Training

X

X

b. Consultation Visits

c. Safety and Health Management Systems Reviewed/Developed

X

X

d. Technical Assistance

e. VPP-Focused Activities

X

X

f. OSHA Enforcement Inspection

g. Offsite Verifications

X

No

h. Onsite Non-Enforcement Interactions

X

No

i. Participant Self-Inspections

X

X

j. Other Activities

SHMS implemented or improved using the 1989 OSHA Safety and Health Program Management Guidelines

7

During the evaluation period some progress was made by the OSP in the development of SHMS for the participating facilities. However, INVISTA’s available resources for this effort were limited due to a number of factors including two of the OSP participating facilities were not active for part of the year due to downturn in economy; many resources being diverted to support Hurricane Ike recovery efforts, and changes in key staff positions at the company. INVISTA’s efforts and corresponding improvements are described below.

Compliance Assurance Management System (CAMS) (Employer Designed Assessment Tool)
During this evaluation period, the OSP participating INVISTA facilities continued conducting annual self-assessments and the information learned during the assessments serves as the baseline data for this OSP. In 2008, INVISTA used only its Compliance Assurance Management System (CAMS) to assess its performance. In 2009, INVISTA developed a set of metrics to be used by all of its facilities worldwide in addition to CAMS.

Each year the participating INVISTA facilities evaluate their CAMS which has 7 major elements. These elements, which are similar to OSHA’s VPP elements, are listed below:

1. Leadership and Management Commitment
2. Employee Ownership-compliance System Owner
3. Compliance and Risk Assessment
4. Hazard and Operability Study (the main methodology used for process hazard analysis)
5. Training and Education
6. Change Management
7. Continuous Improvement

Examples of the subject areas covered by the measures as listed in the goals, strategies, and measures matrix of the OSP agreement and CAMS include: job safety analysis, safe work permits, safety training, and incident investigations.

During the annual CAMS review, unit operators at all facilities address any observed safety and health issues which are documented. If necessary, action items will be developed and tracked until completion. In addition to the annual evaluation of CAMS, INVISTA takes additional steps to protect its workers: safe work practices are stressed as work permits are audited regularly, and work activities are reviewed by the shift supervisor prior to the start of each shift. Also, work behavior is observed and the results of these internal observations are distributed monthly. Tool box meetings are held at the beginning of each shift and job hazards analyses are conducted when needed.

Each facility’s compliance plan uses 20 questions on a checklist for evaluating the safety management system and also uses third party oversight through LYNX. The LYNX database is used to track, monitor, analyze, and report environmental, health and safety, transportation, security, distribution, audit and assessment, investigations, action items and other corporate data. It manages information in three sections, Track (for events), Prevent (for inspections and audits), and Prove (for review of data).

Contractor Safety
Contractor safety is an important element of each INVISTA facility’s SHMS. Prior to any hire, a contractor management team in Wichita, KS reviews contractor qualifications. The evaluation criteria include having an Experience Modification Rate (EMR) of below 1 and adequate insurance as well as reviewing injury/illness logs. All contractor workers go through 8 hour “Basic Plus” training and receive facility specific training via the Safe Work Permit program administered by the Site Supervisor when they come to the facility. In addition, they undergo training on an annual basis while they are at the facility INVISTA tracks the number of hours worked by contractor’s employees and reviews the Material Safety Data Sheets for chemicals used by the contractors. Also, contractors are required to conduct a job hazard analysis before each job starts with weekly audits and issuance of safe work permits when needed for every job.

Culture Survey Results
During the time when the OSP was being developed (2007), a web-based culture survey with 100 questions developed by Texas A&M University was sent to all 18,000 INVISTA workers. Over 50% of employees responded to the survey. However, several facilities in the OSP (Applied Research Center, Newark, Delaware; and Dalton, Georgia) did not have the required minimum number (25) of respondents to guarantee anonymity and these facilities’ data was not included in the survey results. Results of the survey show a need to improve communications between the facilities’ leadership and workers and that the facilities need to improve perceptions in the area of safety values and training. The survey allowed the facilities to address the issues and identify gaps in their safety programs and the results serve as the bases for all of SHMS improvements made. Also, shift supervisors discussed the results with their workers. A follow up survey is planned for either 2011 or 2012, prior to the conclusion of the OSP.

The results of the survey are discussed here as the OSP continues to use the results of this survey in their efforts to develop their OSP strategies and measures.

Ergonomics
The assessment and control of Ergonomic risk factors is applicable for the facilities in Athens, GA and Seaford, DE where spinning fibers and filaments are manufactured, requiring repetitive work. For these facilities, INVISTA has taken appropriate steps to control ergonomic concerns. The facilities’ focus in this area includes collecting reports of discomfort, performing ergonomic stretches, as well as incorporating ergonomic safety into the facility’s overall safety and health management system. Additionally, ergonomic concerns are address through the facilities’ Management of Change (MOC) Program and workers have been provided with ergonomic training. The facility physician is consulted as needed. A Physical Ability Test is utilized during the new hire process to assist in proper placement. Additionally, annual self assessment incorporating ergonomic surveys are performed.

INVISTA uses a Discomfort Complaint Evaluation Protocol which is implemented when a complaint is received and triggers a hazard evaluation. The evaluation records ergonomic risk factors and relevant medical information along with trends, and improvements when required. The self assessment program has been vetted to include industry best practices for correct ergonomic workstations.

For facilities with minimal ergonomic risk factors, workers are provided with awareness training about ergonomic safety programs during annual safety meetings and monthly reminders are distributed with information on ergonomics.

PSM
The OSP has three facilities covered by OSHA’s PSM Standard: La Porte, TX; Orange, TX; and Victoria, TX.

La Porte, TX facility reported the following related to its PSM program:

• A facility siting study was initiated in 2007. During 2009, a risk assessment was completed using the American Petroleum Instititute (API) Recommended Practice (RP) 752 “Management of Hazards Associated with Location of Process Plant Permanent Buildings” and API RP 753 “Management of Hazards Associated with Location of Process Plant Portable Buildings”. Different phases of the proposed plan will be completed in the summer of 2010.
• Used Baker Engineering and Risk Consultants, Inc., a third-party consultant, to prepare models for toxic, fire and explosion hazards. Models were redone using current API RP 752 and API RP 753 guidelines.
• One Process Hazard Analysis (PHA) was conducted in 2009. PHAs are staggered on 5 year cycles with three PHAs planned for 2010.
• The facility uses a Hazard and Operability Study as the main methodology for the assessments and uses cross functional teams and three scenario models for small, medium, and large-2 to 6 inches process lines.

Provided by OSHA Staff

Provided by Partners

Provided by Other Party

Conference/Seminar Participation

X

X

Interpretation/Explanation of Standards or OSHA Policy

X

X

X

Abatement Assistance

X

X

Speeches

X

Other (specify)

INVISTA shares knowledge and best practices on programs and processes with other facilities through the use of an online intranet system. Also, the Environmental, Health, and Safety (EHS) department holds a teleconference on a quarterly basis with all facilities in North and South America to discuss safety issues and corrective action plans. In those meetings, best practices are identified and shared. INVISTA also has a web driven program on emerging issues. Several facilities have sent representatives to a variety of conferences including Koch Industries/INVISTA (EHS) conferences (2008) and Regional (IV and VI) and National VPP Participants’ Association conferences.

OSP participating facilities are utilizing the VPP mentoring model in preparing their facilities for VPP approval. During this evaluation period:

• Representatives from INVISTA Athens, GA visited Noramco, a VPP facility, to learn more about the VPP.
• INVISTA La Porte, TX uses a mentor from the Chevron-Phillips to assist the facility with its VPP efforts.

Offsite verifications performed

1

As the PMT did not have specific and detailed procedures in place to carry out such verifications on a consistent basis, a verification template was developed during the latter part of 2009 and approved in early 2010. As a result, no offsite verifications were performed for any of the non-VPP facilities during 2009.

The Victoria, TX facility is a VPP Star facility and as such, is required to submit an annual self evaluation to OSHA that provides updated OSHA 300 Log data in addition to other safety and health information. OSHA reviewed the site’s 2008 annual VPP self evaluation.

Self-inspections performed

**

Hazards and/or violations identified and corrected/abated

**

Every year, per the OSP, each facility is required to perform ergonomic assessment at all of its workstations and material handling activities.

The assessment program has been vetted to include industry best practices with respect to correct ergonomic workstations. Enhancements to the assessment process came from Corporate Industrial Hygienist and were vetted by the employer’s EHS management. Also, management provided the monthly housekeeping inspections team with an ergonomic assessment checklist and the enhanced housekeeping inspection process was shared as a best practice throughout INVISTA.

** INVISTA did not report the numbers of self-inspections performed as well as hazards identified and corrected in 2009. The PMT will consider the need to either develop a tracking procedure to document all ergonomic assessments and the hazards identified/corrected or to enhance its data reporting procedures to include such totals.

Baseline Data
The OSP agreement specifies that 2008 data will be used as the baseline data to provide reference points to measure the performance of the participating facilities in the OSP. Therefore, the baseline data points are:

• Total Case Incidence Rate: 0.2
• 4 out of 7 facilities had a TCIR of 0.0
• The average facility was 87% below the industry average
• Days Away, Restricted or Transferred Rate: 0.0
• All 7 facilities had a DART of 0.0
• The average facility was 100% below the industry average

CY 2009 OSP Performance

• Total Case Incidence Rate: 0.3
• Represents an increase of 60% from 2008’s rate of 0.2 (numbers were rounded off)
• 3 facilities saw TCIR increases in 2009 and 2 were able to reduce theirs, and the remaining two maintained their TCIR at the 2008 level
• 1 out of 7 facilities had a TCIR of 0.0
• The average facility was 40% below the industry average
• Days Away, Restricted or Transferred Rate: 0.1
• The percentage increase could not be computed as zero may not be divided by an integer
• 2 facilities saw DART increases in 2009 and 5 maintained theirs at 0.0
• 5 out of 7 facilities had a DART of 0.0
• The average facility was 80% below the industry average

Changes

Challenges

Management Structure

Participants

Data Collection

X

Employee Involvement

Verifications

X

X

OSP Outreach

Training

Other (Specify)

Data Collection: A review of the reports and data submitted for the CY2009 evaluation period indicated that the data is incomplete as not all of the measures listed in the OSP Agreement have been addressed. However, in 2009, the OSP worked on a dashboard which will provide the reader with a snapshot of safety and health activity at the OSP participating facilities. It is scheduled to be finalized in early 2010 and will be updated on a quarterly basis and provided to the PMT at each quarterly meeting. The PMT will work to ensure that all measures listed in the OSP Agreement are addressed with relevant data. This improvement will ensure that the appropriate information is collected and reported for the OSP evaluation in 2010.

Verifications:
As described in Sections 2g and 2h of this report, the verification template was developed during this evaluation period. Therefore, except for the offsite documentation review of Victoria, TX’s facility’s VPP annual self evaluation for 2008, no verifications were performed during this evaluation period.

Improvements

N/A

Meet more often

Improve data collection

X

Conduct more training

Change goals

Data Collection: A review of the reports and data submitted for the CY2009 evaluation period indicated that the data is incomplete as not all of the measures listed in the OSP Agreement have been addressed. However, in 2009, the OSP worked on a dashboard which will provide the reader with a snapshot of safety and health activity at the OSP participating facilities. It is scheduled to be finalized in early 2010 and will be updated on a quarterly basis and provided to the PMT at each quarterly meeting. The PMT will work to ensure that all measures listed in the OSP Agreement are addressed with relevant data. This improvement will ensure that the appropriate information is collected and reported for the OSP evaluation in 2010.

Increased safety and health awareness

X

Improved relationship with OSHA

X

Improved relationship with employers

Improved relationship with employees or unions

Increased number of participants

Other (specify)

INVISTA reported it continued its efforts to pursue VPP at OSP participating facilities in 2009. These efforts contributed to increasing safety and health awareness among workers at the participating facilities.

Partnership Completed

Continue/Renew

Continue

Continue with the following provisions:

Improve data collection to ensure all measures as listed in the OSP agreement are documented and submitted for inclusion in the CY 2010 evaluation.

Terminate (provide explanation)