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 5.15 SAFETY INSPECTIONS, OBSERVATIONS AND OSH PROGRAM REVIEW

 
 

 Purpose

 

P1. To ensure that students and staff work and live in environmentally healthy surroundings.

P2. To provide a training, living, and working environment that ensures the occupational safety and health of students and staff.

 

 Requirements

 

R1. Imminent Danger

Imminent danger exists when a condition or practice presents a danger that could reasonably be expected to cause death or serious physical harm. If such a situation exists and is observed, the student(s) and staff in danger must be immediately removed from the area and not permitted to return until the problem is corrected. The center Safety Officer must immediately notify the Center Director of the hazard and recommend corrective action.

The Center Director must take appropriate action(s) to correct the hazard. If the hazard cannot be corrected promptly by the center, the Center Director must consult the appropriate Regional Office and/or the Office of Job Corps for advice and assistance in correcting the hazard. The action recommended by the center Safety Officer and the resulting action taken must be documented in writing and maintained on center for a period of three years.

R2. Required Inspections and Observations

a. All occupational safety and health inspections and observations must be:

1. Conducted by appropriate center staff in accordance with 29 CFR 1960.25 and DLMS 4 Chapter 800, paragraph 825

2. Submitted according to Exhibit 5-2, Plan and Report Submission Requirements

3. The responsibility of the center Safety Officer, managers, supervisors, and instructors

4. Documented and maintained on center for a period of five years, then destroyed

b. Observations on a daily basis, and weekly or monthly inspections are required for all center:

1. Buildings

2. Facilities

3. Career Technical Training (CTT) facilities including tool inventory, accountability, and security procedures

4. Career Technical Skills Training (CTST) projects including tool inventory, accountability, and security procedures

5. Academic classrooms

6. Cafeterias

7. Dormitories

8. Health services

9. Administrative offices

10. Recreation areas

11. Gymnasiums

12. Swimming pools

13. Child development center facilities, including playgrounds

14. Equipment

15. Vehicles used to transport students

Identified deficiencies must be corrected promptly. Weekly and monthly inspections, and hazards identified during daily observations, must be documented. Records of inspections and actions taken to correct deficiencies must be maintained by the center Safety Officer for three years, and made available upon request.

c. Daily Observations

1. Food service supervisors must check food preparation and food serving areas of cafeterias.

2. Residential advisors/residential counselors must check dormitories, snack bars, and canteens and document their findings in a log book. 

3. The center Safety Officer, and CTT and academic managers/instructors, must check classrooms/shops (including CTST projects); tool inventory, accountability, and security procedures; motor vehicles; and all equipment to be used by students and staff.

4. Child development supervisors must check the child development center, equipment, toys, and the playground.

5. Recreation supervisors/staff must check the gymnasium, exercise equipment, and other frequently used recreation areas.

d. Weekly Inspections

The center Safety Officer must inspect:

1. All food service facilities, including cafeterias, culinary arts facilities, snack bars, and canteens

2. Gymnasiums, exercise equipment, and swimming pools during times of operation

3. CTT facilities and CTST projects including tool inventory, accountability, and security procedures

e. Monthly Inspections

The center Safety Officer must inspect:

1. Dormitories

2. Child development centers

3. CTT facilities and CTST projects (see PRH Chapter 3, Section 3.2​) including tool inventory, accountability, and security procedures

4. Academic classrooms

5. Health services

6. Administrative offices, warehouses, and other buildings occupied by students and staff

f. Quarterly Inspections

Centers must arrange for quarterly environmental health inspections by qualified non-center personnel in the following areas:

1. Food service facilities

2. Residential facilities

3. Training facilities

4. Educational facilities, including offices, classrooms, recreational facilities, and wellness center

5. Water supply and distribution facilities, when not a part of municipal systems

6. Wastewater treatment facilities, except for septic systems, which must be inspected annually, and municipal sewer systems, which are exempt from this requirement

7. Child development centers, where appropriate

Centers must submit quarterly environmental health reports and necessary corrective action, simultaneously, to the Regional Office and the National Office of Job Corps within seven days of receipt (see Exhibit 5-2, Plan and Report Submission Requirements).

g. CTST and Other Projects

The center Safety Officer and appropriate instructor must inspect all CTST projects daily. The appropriate instructor must ensure full tool inventory, accountability, and security, ensuring that all tools are accounted for before the end of each class, or the end of each day if off-site, and ensuring that all tools that are unaccounted for are found and all tools are secured. The Center Safety Officer must inspect and approve all final CTST projects, on and off center, before site occupancy and project completion.

Inspection checklists, photographs, tool inventory lists, and associated corrective actions must be maintained on center indefinitely and made available upon request.

R3. Annual Occupational Safety and Health (OSH) Program Reviews

a. The annual Occupational Safety and Health (OSH) Program Review is conducted in accordance with Executive Order 12196, 29 CFR Part 1960, Department of Labor Manual Series (DLMS) 4, Chapter 800, and the Job Corps Policy and Requirements Handbook (PRH). The review verifies that each center has implemented the Occupational Safety and Health program outlined in the PRH and identifies any outstanding occupational health and safety deficiencies.

b. The review is conducted using the Job Corps Program Assessment Guide (PAG), PRH Chapter 5, Sections 5.14–5.20. The PAG is a companion to the PRH. It provides a standardized approach and framework for the review and evaluation of contractors’/operators’ delivery of services as specified in the PRH. The review consists of an on-site visit including opening and closing conferences, walk-through of facilities, document verification, and student/staff interviews.

c. The review process is designed to determine the extent to which program operations meet the government’s requirements and expected outcomes. The PRH requirements set benchmarks for the government’s expectations. Job Corps uses an adjectival rating system to assign ratings to each requirement and overall program component. The adjectival rating system uses five adjectives, as recommended by the Office of Federal Procurement Policy, to define the degree to which expectations are met. Adjectival ratings are defined as follows:

Exceptional

Programs, procedures, and systems are well organized, clearly communicated, and administered to ensure quality delivery of all requirements. Innovative approaches result in program enhancements and improved outcomes. Through rigorous self-assessments and quality assurance, the operator safeguards program assets and maintains the integrity of program data.

Very Good

Programs, procedures, and systems are consistently in place to ensure delivery of requirements. Some innovative approaches are employed to promote continuous improvement. A viable quality assurance plan ensures integrity and accountability of program assets and data.

Satisfactory

Requirements are generally evident in applicable program areas with minor exceptions. A quality assurance plan is in place that demonstrates adequate controls to ensure integrity and accountability of program assets and data.

Marginal

Requirements are missing or minimally evident in applicable program areas. Quality assurance is minimal, resulting in inconsistencies in accountability and integrity of program assets and data.

Unsatisfactory

Critical requirements are missing or minimally evident. The program lacks procedures and controls necessary to ensure compliance, quality, and data integrity.

d. For the purpose of the OSH Program Review, the adjectival ratings definitions are designed to assist evaluators in assigning scores for each requirement by describing what is expected for each adjectival level.

The ratings are made against a 10-point scale, as shown below.

0

1

2

3

4

5

6

7

8

9

Unsatisfactory

Marginal

Satisfactory

Very Good

Exceptional


e. At the end of each PAG section, the ratings for each requirement are averaged. The average compliance and quality ratings for all sections 5.14-5.20 are then averaged to produce final ratings. The final compliance and quality ratings constitute the final OSH Program Review score.

f. Documentation Examined During Review

Documentation is critical. Reviewers will assess only the documentation provided to them while they are on center. Should the required documentation not be presented, the center will not be credited with the associated item. The reviewer will give the center Safety Officer (or designee) an opportunity to present any omitted documentation before the end of the review.

Documentation that is created during or after the opening day of the review, however, will not be considered. OSH Program Review rebuttals based upon missing or unaccepted documentation at the time of the review will be rejected and the final score will not be changed.

g. Interviews During the Review

The strategies outlined in the PAG necessitate interviews with the Center Director, staff members, and students to determine knowledge and involvement. In cases where verbal statements and documentation conflict, reviewers will use their professional judgment in deciding whether to award credit. Rebuttals or scoring changes based upon discussions with the reviewer that are not substantiated by the rationale for rating or other documentation will be rejected and the final score will not be changed.

h. Documentation of Deficiencies and Abatement Activities

National Office OSH Program Reviewers are required to document deficiencies in the Abatement Tracking System (ATS) website. Job Corps centers are required to document and post deficiencies manually on the DOL Form DL1-2029​. Blank forms can be obtained from the Job Corps Community website. Center abatement activities must be documented in ATS. The ATS website can be accessed at: http://ats.dol.gov/.

R4. Occupational Safety and Health Facility Survey (Preoccupancy)

a. An Occupational Safety and Health Environmental Facility Survey (Preoccupancy) must be conducted before moving students into

1. a new center, dormitory, or classroom; or

2. a facility that has been renovated so as to change any building structural system or major mechanical, electrical, plumbing, egress, or fire and safety system.

b. Centers must contact the Regional Office (RO) Project Manager to schedule a pre-occupancy survey 30 days prior to project completion.

c. The preoccupancy survey must be coordinated through the RO and conducted by the center Safety Officer and/or the Office of Job Corps. The Office of Job Corps will determine who will conduct the preoccupancy inspection.

d. Major deficiencies must be corrected before occupancy.

e. The survey report will be distributed prior to occupancy, and it will be maintained by the National Office, Regional Office, and the center.

R5. Monitoring of Work-Based Learning Sites

Centers are responsible for ensuring that students are placed in safe and healthful working conditions at work-based learning locations. However, Job Corps’ responsibility will not extend to reviewing or inspecting private employer businesses for compliance with OSHA standards because this authority rests only with OSHA.

To ensure the occupational safety and health of students at private employer work sites, appropriate career development staff and/or the center Safety Officer must:

a. Visually survey the work site for potential hazards and discuss safety and health requirements with the employer.

b. Ensure the employer signs a work-based learning agreement, Exhibit 3-4​, that specifically states the employer will provide students with safety and health protection which shall be at least as effective as that which is required under the Occupational Safety and Health Act of 1970 (29 U.S.C.) and 29 CFR Parts 1910, 1926, and 1960​.

c. Monitor active work sites on a regular basis. If hazards are noted, the employer must be requested to take corrective action. Students should be removed from work sites where hazards exist that could cause personal injury or impairment of the health of students.

d. Document the injuries of students who are injured on work-based learning sites in the Employees’ Compensation Operations and Management Portal (ECOMP), as they are covered by the Federal Employees’ Compensation Act (FECA).

R6. Abatement Plans for Violations Identified in Annual Occupational Safety and Health (OSH) Program Review

a. Abatement Procedures and Time Frames

The following procedures must be followed by centers and Regional Offices (ROs) in responding to safety and health violations cited during annual safety and health reviews:

1. As part of the OSH Program Review, the center will receive a detailed verbal briefing regarding all hazards identified. The center must immediately begin to address those concerns. A log of the corrected item(s) must be maintained, indicating what action was taken, by whom, and the date of action.

2. The center and the RO will receive a formal OSH Program Review report from the National Office of Job Corps within 60 days of a review. Violations must be documented manually on Form DL1-2029, Notice of Unsafe or Unhealthful Condition, which is to be created by the center. The violations documented on the DL1-2029 are the same as those documented in the Abatement Tracking System (ATS), which is the Web-based system designed to facilitate an information exchange between the reviewer, the RO, and the center, and to allow the National Office to monitor case status to ensure prompt and timely hazard abatement.

3. The roles of each ATS user are as follows:

(a) At the national level, the National Office inputs DL1-2029 center violation data into ATS and transmits the data to the RO to initiate tracking.

(b) At the regional level, both the Job Corps Regional Director and the center’s Project Manager are authorized to access ATS to view new cases transmitted from the National Office and centers’ abatement responses. Either individual in the RO can transmit the DL1-2029 in ATS to the Job Corps center. The RO can edit the center response and can close out the case only after all violations have been abated.

(c) At the center level, the Center Director and the center Safety Officer are authorized to access ATS to view new cases transmitted from the RO and can respond to violations. Most violations should be abated within 30 days. If abatement is not completed, an abatement plan is required. Centers can indicate in ATS whether the response is a corrective action or an abatement plan. Funding requests can also be indicated. After the center transmits the response electronically to the RO, the RO will determine whether to accept the abatement response in part or in whole.

ATS is not capable of providing users e-mail notification, so the system should be checked frequently.

b. Posting Requirements

Official response to violations noted during the occupational safety and health review occurs via ATS. A copy of the paper DL1-2029​, which must be created by the center, is to be posted by the center at or near each place where an unsafe or unhealthful condition is referred to in the notice. It must remain posted until all violations cited are abated, or for three training days, whichever is longer.

 

 Exhibits

 
  
Exhibit 3-4 Work-Based Learning Program Agreement Template
Exhibit 5-2 Plan and Report Submission Requirements
 

 Legal/CFR Requirements

 
  
29 CFR 1910
29 CFR 1926
29 CFR 1960
29 CFR 1960.25