NO CLIENT LEFT BEHIND: T&T STAFF MANAGEMENT AND THE OSHA ALLIANCE PROGRAM

Think back to the mid to late 90’s, even some of the early 2000’s and you might recall our industry facing a very difficult workers’ compensation market. While some PEOs struggled with increased workers’ compensation premiums, others faced the life-threatening issue of securing workers’ compensation coverage. Some carriers began to believe that PEOs were too much liability or simply put, a “ticking time bomb” and therefore, exited the PEO market all together.

As for T&T, our founder and CEO Thad Steele determined these difficult times were an opportunity to enhance and strengthen what is known today as our blue ocean: T&T’s Safety and Risk Management Team. Mr. Steele led our mission to prioritize safety while making sure we followed his “No Client Left Behind” directive. Almost 30 years later, our safety team continues to work together with our client companies by encouraging and practicing our pro-active vs reactive safety approach. This approach demonstrates our safety commitment to our workers’ compensation carrier and has been instrumental to the overall success of our PEO.

THE OSHA ALLIANCE

After implementing “No Client Left Behind” in 2004, T&T entered into an Alliance Agreement with OSHA. The Alliance has been effective in meeting its objectives over the past 20 years and has continuously worked to meet OSHA’s mission to ensure America’s workers have safe and healthy working conditions. Thousands of employees have received OSHA-based safety and health training in English and Spanish as a result of this Alliance. The Alliance attempts to prevent exposure to falls, electrocutions, struck-by hazards, caught-in or between hazards and addresses construction and general industry safety and health issues. We are now in our twenty-first year of the Alliance Program and because of the continued success of this agreement, in December of 2024 we signed another 3-year extension.

In late 2005, Thad Steele and his leadership team chose to adopt and follow OSHA’s Voluntary Protection Program Safety and Health Management System (SHMS) elements. The VPP SHMS consists of four critical interrelated elements: 1.) management, leadership and employee involvement, 2.) worksite analysis, 3.) hazard prevention and control, and 4.) safety and health training. Another critically important change implemented during this time within our internal risk management and safety systems was the decision to have our safety specialists investigate 100% of all work-related injuries reported by our clients.

Diego Alvarado, OSHA Area Director (pictured left) and Thad Steele, T&T CEO & Founder (pictured right), sign a 3-year Osha Alliance extension. T&T was the first PEO in the nation to sign an Alliance with OSHA. The Alliance has been in existence since January of 2004.

Because of our working relationship with OSHA, when OSHA launched its Temporary Worker Initiative (TWI) on April 29, 2013, which helps prevent work-related injuries and illnesses among temporary workers, we were able to hold roundtable discussions with our local OSHA office. During these roundtable discussions T&T was able to explain to OSHA the difference between a PEO and a temporary staffing company.

Our primary responsibilities are to inform and educate clients of their safety and health responsibilities. Our secondary responsibility is to assist clients, with their full knowledge and cooperation, in the initiation and implementation of their safety and health programs. This also includes participating in OSHA inspections when requested by our clients and helping our clients navigate through OSHA post inspections activities. When participating in an OSHA inspection, we generally take the same pictures the OSHA inspectors take and note their inspection findings. We also encourage our clients to immediately fix and abate any hazards identified by the OSHA inspectors. If they do receive citations, we encourage our clients to call and set up an informal conference with the local OSHA Area Director and we help them prepare for their informal conference. In some instances, we will accompany our clients to their informal conferences. Contractually, 100% of our clients are made aware of their responsibility and requirement to always follow OSHA rules and regulations. All are made aware of our Alliance with OSHA and are also made aware of the no cost safety services available to them upon request.

As part of underwriting new business, the safety team evaluates all prospects in a few critical items. For example, what type of industry or types of work are the clients involved in? Is it a high risk (blue collar) or lower risk (white collar) industry? What do their Total Injury and Illness Rates (TIIR), Days Away, Restricted and Transfer rates (DART), and Experience Modifier Rate (EMR) look like? We also want to know how many employees they have at any given time during the year and whether they have full-time safety personnel on staff.

The old adage one size does not fit all is truly what we and you will be faced with when dealing with your individual client’s safety and health needs. Establishing early and often to all our clients that we are not their full-time safety professionals and that we do not have “control” of their operations at any time is important. Fully explaining their responsibilities under the OSHA Act and gaining their trust is paramount in developing a strong working relationship with them.

We deal of course at any time with client owners that maintain a strong safety culture in their operations and have safety personnel on their staff, making every effort to not only comply but exceed minimal OSHA requirements. Those types of clients will also utilize our safety services often by requesting toolbox safety meetings and or worksite safety inspections. We also have client owners that want to be safe and want to comply with OSHA’s minimum requirements. These types of clients will utilize our safety services as needed. Then there are those client owners which claim they want to be safe but still tend to place production above safety. These types of clients will rarely utilize our safety services but are immediately placed on our safety radar to ensure we manage the “risks” associated with their on-going operations.

Even if clients do not want any of the typical safety services we offer, we still want to ensure they are receiving current safety and health information pertinent to their industry.

We create personalized OSHA data reports based on their NAICS, which can provide them with current OSHA inspection activity specifically related to their NAICS and most frequently cited OSHA standards again, specific to their industry. We send them newsletters, safety articles, and we contact them no less than once a month offering safety services. Finally, we can do a “safety drive-by” of their on-going operation and if we can identify a hazardous condition in plain view, we notify the client concerning our observations.

COMMUNITY SAFETY LEADERS

Here are some things we continue to do or have done throughout the years locally to stay relevant within the realm of safety and health.

• Develop bilingual toolbox safety talks
• Become members of the National Safety Council
• Participation in OSHA’s Annual National Safety Stand-Downs
• Build or dedicate a training facility to provide safety and health training
• Invite the local OSHA office to utilize your training facilities.
• Provided First Aid/CPR/AED training for your local OSHA personnel
• Partner with and invite your local institutions of higher learning (universities and community colleges) to utilize your training facilities to provide safety and health training
• Participate in local marketing campaigns aimed at promoting safety and health in the workplace in your local area
• Have available new hire safety orientations (in person and/or on-line) for every employee who registers with your organization
• Continually run work-related safety messages on company electronic billboards
• Distribute various OSHA educational materials and publications to your local business community and have these materials available to distribute at your offices
• Sponsor events hosted by your local OSHA office
• Establish web links on your website to OSHA and NSC websites.
• Partner with and hold safety events/trainings/demonstrations with safety equipment manufacturers or distributors
• Partner with, participate in and or sponsor local safety and health related events being put on by your local institutions of higher learning or industry trade groups.

Being involved in and being a safety leader locally within the business community helps give relevancy to your safety team and your organizations commitment to safety and health. It is always beneficial and makes safety an easier sell, when your clients can plainly see that you “walk the talk”.

HOW YOUR PEO CAN PARTICIPATE

Concerning OSHA’s Alliance Program, PEOs can get information about OSHA’s Cooperative Programs here. We recommend calling your local OSHA office and asking to speak to the Compliance Assistance Specialist (CAS) assigned to your area. Set up in-person meetings to get to know the CAS and invite them to visit with you at your facility. The CAS should be able to meet with the PEO and see if they meet the criteria and fundamental requirements needed to participate in an alliance. From our experience the CAS will evaluate the organization seeking to enter into the Alliance agreement and will generally be looking at what the PEO is currently doing in regard to safety and health and again see if they meet OSHA’s criteria for participating in an Alliance. Below are some additional resources that will help any PEO get information concerning OSHA’s cooperative programs.

Our overall experience has been a positive one while being involved in the Alliance program. We have invested hundreds of hours of our safety professionals time in participating in local safety and health events and we have sponsored numerous safety trainings, conferences and events over the years, but we feel that the return of our investment in participating in the Alliance Program has been worth every penny.

Our safety and risk management team plays a vital role in the overall success of our organization. Our office training rooms are frequently booked during weekdays and sometimes weekends, as we continue providing safety and health training to our clients, supervisors, employees, the community and even OSHA themselves. It is true that prioritizing safety pays and “No Client Left Behind” has and will continue to be one of our main priorities. Stay Safe!

Resources:

1. https://www.osha.gov/sites/default/files/publications/factsheet-alliance.pdf
2. https://www.osha.gov/sites/default/files/enforcement/directives/CSP_04-01-003_0.pdf
3. https://www.osha.gov/alliances/faq-2020
4. https://www.osha.gov/alliances/templates
5. https://www.osha.gov/alliances/alliance-products-guide