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Recognition & Exemption Programs

Program Eligibility

In order to be considered for participation in SHARP, an employer must:

  1. Employ not more than 250 employees at the site and not more than 500 at all sites nationwide. (Establishments that are too large to qualify for SHARP but demonstrate commitment to workplace safety and health may be eligible for OSHA's Voluntary Protection Program, described in OSHA Instruction TED 8.la at www.osha.gov/oshprogs/vpp/.)
  2. Be in an industry that is on OSHA's high-hazard list or a supplemental high-hazard list approved by the Director of Federal-State Operations, or be on any national, state, or locally approved special emphasis program list.
  3. Be a single, fixed worksite. (Multiple worksites under common control must be evaluated and approved separately. Employers at mobile worksites such as logging, longshoring, construction, etc., are not eligible for SHARP.)
  4. Have at least one year of operating history, in order to have established Lost Work Day Injury and Illness (LWDII) rate and Total Recordable Case Rate (TRCR).
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Program Requirements

Employers requesting consideration for SHARP must:

  1. Agree to a full service consultation survey of all conditions and operations at the establishment, including a complete safety and health systems review.
  2. Involve employees in the development, operation, and improvement of all elements of the written workplace safety and health program as well as in the decisions that affect their safety and health. At unionized sites, if the union representatives object to the site's involvement in SHARP, the Consultation Project Manager must advise the employer that the application cannot go forward until labor and management agree on the issue.
  3. Work with a Consultant to accomplish all of the following:
    1. Correct all identified safety and health hazards or potential hazards and provide the Consultation Project Manager with written confirmation that each identified hazard has been corrected within the agreed upon time frame.
    2. Develop, implement, or improve all elements of the effective safety and health management system at the site.
    3. Lower the LWDII rate at the site to a level below the national average for that industry, based on at least one full year of operation. In addition, the Total Recordable Case Rate (TRCR) for the site must be at or below the national average for that industry.
  4. Develop and maintain a written safety and health management system addressing, at a minimum, the major elements of the 1989 Guidelines.
  5. As a condition of receiving a two-year exemption period, conduct interim year self-evaluations based on the elements of the written safety and health management system. The self-evaluation must be reported in a written report to the Consultation Project Manager. The report must include OSHA 300 log data.
  6. Satisfy the requirement that they score at least 2 on all required attributes of the Safety and Health Program Assessment Worksheet (Revised OSHA Form 33).
  7. Inform the Consultation Project Manager prior to making any changes in working conditions or work processes that might introduce new hazards into the workplace.
  8. Notify the Consultation Project Manager when all elements of a SHARP have been implemented so that a Consultant can make a follow-up visit.
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Pre-SHARP Inspection Deferral

An employer who corrects all hazards identified during the consultation visit and shows reasonable promise of achieving milestones and time frames agreed upon with the consultant will be granted inspection deferral. The deferral time frame recommended by the Consultation Project Manager must not exceed 18 months from the expiration of the correction due date. All of the following criteria must be met in order for deferral to be granted.

The employer must:

    1. Post the list of hazards identified by the consultant.
    2. Provide information on all identified hazards identified by the consultant to employees and inform employees when hazards are corrected.
    3. Correct all hazards (serious and other) identified by consultants.
    4. Show evidence of having the foundation of a safety and health management system by scoring a minimum of 75 on the Safety and Health Program Assessment Worksheet (Revised OSHA Form 33).
    5. Implement an action plan agreed upon with the consultant to address those elements of a safety and health management system identified by the consultant as essential.
    6. Provide progress reports to the Consultation Project Manager and meet other state- or project-specific requirements.
    7. Agree to full service visit by consultants at the end of the deferral period.
    8. Notify the Consultation Project Manager in case of changes in conditions (e.g. process, equipment etc.).
    9. Involve employees in the safety and health management system, including the implementation of the action plan.
    10. Be capable of reducing the site's Lost Workday Injury and Illness (LWDII) Rate and Total Recordable Case Rate (TRCR) to below the industry national average within the deferral period.
    11. Post the action plan and a notice of intention to participate in SHARP (provided by the consultant).
    12. At unionized sites:
      • Notify the employee representative(s) of the employer's intention to participate in SHARP.
      • Involve the union in the process.
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Inspections at SHARP Sites

The following types of incidents trigger inspections at SHARP sites:

    1. Imminent Danger
    2. Fatality/Catastrophe
    3. Formal Complaints
    4. Referral from a safety compliance officer to a health compliance officer, or from a health compliance officer to a safety compliance officer
    5. Follow-up of previously cited violations
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Exemption

The initial exemption from Programmed Inspections is for a period of one year. If participation is renewed, a two-year exemption period may be awarded to the SHARP participant. An employer receiving a two-year exemption must conduct interim year self-evaluations based on the elements of the written safety and health management system. The self-evaluation must be reported in a written report to the Consultation Project Manager. The report must include OSHA 300 log data.

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Changes that May Affect a SHARP Employer’s Eligibility

  1. Relocation. Employers planning to relocate their facilities must notify the Consultation Project Manager sixty days in advance of the move. A consultant must visit the new site within sixty days of the move to verify that all elements of the safety and health management system are in place. If this is not the case, the Consultation Project Manager must ask the employer to withdraw from the program.
  2. Change in Ownership. Whenever ownership or major organizational changes occur that may impact the safety and health management system, the Consultation Project Manager must discuss the changes with the employer and schedule an onsite visit, if necessary.
  3. Fatalities or Catastrophes. In the case of a fatality or catastrophe at a SHARP site, the employer must notify the OSHA Area Office within eight hours of the incident. The Area Director must then notify the Consultation Project Manager as soon as possible after receiving notification of the incident. Until enforcement has issued a final order, Consultation personnel should not visit the worksite.
    1. If an inspection is conducted and a serious or repeat citation is issued, a consultant must conduct an onsite visit to ensure that the safety and health management system is operating effectively.
      • If the consultant believes there is a connection between a serious citation and reduced effectiveness of the safety and health management system, the Project Manager must recommend that the SHARP employer withdraw from the program.
      • If there is no connection the employer will be counseled on how to prevent a recurrence.
    2. If an inspection is conducted and a willful citation is issued, the SHARP employer must be asked to withdraw from the program. The employer may reapply 12 months after withdrawing from the program. If the enforcement action uncovered evidence that the site's application or annual self-evaluations was falsified, participation in SHARP will be terminated.
    3. If no citation is issued, an on-site visit will be conducted to assure that all elements of the safety and health program are still effective.
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Renewal Requirements

Employers of SHARP sites may apply for renewal during the last quarter of the initial year in the program. At the time of the renewal, the Consultation Project Manager must conduct a full service visit to ensure that the safety and health management system has been effectively maintained or improved. If the employer meets all of the program requirements, the Consultation Project Manager may authorize the employer to submit a written request for SHARP renewal.

SHARP renewals are for a period of two years. During the two-year exemption period, the employer must conduct an interim year self-evaluation based on the elements of the written safety and health management system. The self-evaluation must be reported in a written report to the Consultation Project Manager. The report must include OSHA 300 log data.

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Failure to Maintain Program Requirements

An employer who fails to maintain the program requirements outlined in this chapter will be withdrawn from the program. However, before proceeding with termination, the Consultation Project Manager should give the employer the opportunity to withdraw from the program voluntarily.

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Voluntary Withdrawal from the Program

Any approved SHARP participant may withdraw at any time after approval. Withdrawal may occur as a result of plant closing, economic difficulty, or change in management. To withdraw, the employer must send a letter explaining the withdrawal, as well as the SHARP certificate, to the Consultation Project Manager. The withdrawal is effective immediately upon receipt of the letter.

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Termination

The employer must be notified in writing when a SHARP certificate is revoked. The written notice must contain the reason(s) that the certificate is being revoked and the requirements for re-entry in the program.

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Last Updated: February 04, 2014


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