In article “Handbook EL-802 Revision: Executives’ and Managers’ Safety and Health Program and Compliance Guide,” published in the September 8, 2022, Postal Bulletin (22606), the Postal Service™ announced that Handbook EL–802, Executives’ and Managers’ Safety and Health Program and Compliance Guide, would be revised and published in late 2022. However, this did not occur due to a delay.
Effective later this year, the Postal Service will revise Handbook EL-802, in its entirety, to reflect changes and updates in Occupational Safety and Health Administration (OSHA) and Postal Service Occupational Safety and Health programs.
Although the Postal Service will not publish the revisions in Handbook EL-802 until later this year, these standards are effective immediately.
Handbook EL-802, Executives’ and Managers’ Safety and Health Program and Compliance Guide
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1 Introduction
1-1 Purpose
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The Postal Service™ focuses on engaging in innovative safety efforts to reduce the number of, and prevent, employee workplace accidents and injuries. The purpose of this handbook is to help Postal Service nonbargaining employees:
n Understand their roles in the Postal Service commitment to safety as a smart business practice.
n Get involved in promoting safety programs, and to recognize and correct unsafe acts, working conditions and practices.
n Ensure accountability for effective programs in all Postal Service facilities.
The handbook also includes information on management responsibilities under the Occupational Safety and Health (OSH) Act, and regarding Occupational Safety and Health Administration (OSHA®) inspections and citations.
1-2 Content Summary
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Chapter 1 — Includes the purpose of this handbook, a summary of the handbook’s content, and a list of references.
Chapter 2 — Provides an overview of Postal Service obligations under the OSH Act so that managers understand their legal and Postal Service responsibilities under the OSH Act.
Chapter 3 — Includes an overview of the Postal Service Safety and Health Program, including information on using the safety, environmental, and ergonomic resources in the Safety and Health Management Tool (SHMT) to manage Safety and Health programs.
Chapter 4 — Provides information on working with OSHA, including responding to employee complaints, handling OSHA inspections and citations, and managing citations.
Appendix — Postal Service Executives’ Safety and Health Planner.
1-3 References
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Key references used throughout this handbook include:
n Employee and Labor Relations Manual (ELM), Chapter 8, “Safety, Health and Environment” (blue.usps.gov/cpim/manuals.htm).
n Safety and Health Management Tool (SHMT).
n Postal Employees Safety Enhancement Act (Pub L. 105–241) (govinfo.gov/app/details/PLAW-105publ241).
n Occupational Safety and Health Administration (OSHA) (osha.gov).
Information on OSHA inspections and compliance activity, and employer rights and responsibilities following an OSHA inspection is available on the “OSHA® FactSheet: Occupational Safety and Health Administration (OSHA) Inspections” at osha.gov/sites/default/files/publications/factsheet-inspections.pdf.
2 Regulatory Requirements and Postal Service Policy
2-1 Postal Employees Safety Enhancement Act
2-1.1 Change in Postal Service Status as Employer Under OSHA
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***Previously, the Postal Service, as a federal agency, had been exempt from the private-sector provisions of the OSH Act.1
2-1.2 PESEA Requirements and the OSH Act
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When PESEA became effective, the Postal Service, like most private-sector employers in the United States, became fully subject to the OSH Act. This means that OSHA has jurisdiction over the Postal Service in matters relating to employee safety and health. The Postal Service must comply with the OSH Act and OSHA standards and regulations. If violations occur, the Postal Service may be cited, fined, and, in extreme cases, referred for criminal prosecution by OSHA.
PESEA also does the following:
n Amends federal law to prohibit the Postal Service from:
n Considering compliance with OSHA in determining whether to close or consolidate a Post Office®; or
n Restricting, eliminating, or adversely affecting any service it provides because of a paid penalty imposed under OSHA.
n Prohibits the Postal Regulatory Commission from considering compliance with OSHA in determining whether to increase rates and provides that OSHA compliance must not otherwise affect the service of the Postal Service.
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2-2 Postal Service Policy
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The Postal Service complies with OSHA requirements described in 2-1. The Postal Service is committed to:
n Developing and promoting safety programs.
n Recognizing and correcting unsafe acts, working conditions and practices.
n Ensuring accountability for effective programs in all Postal Service facilities.
n Promoting safety as part of smart business practices.
See the Employee and Labor Relations Manual (ELM).
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3 Postal Service Safety and Health Program
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3-1 Guidelines
The Postal Service has a Safety and Health program, which includes the following guidelines:
A. Management leadership and employee participation:
n Management commitment and employee involvement are complementary.
n Management commitment provides the motivating force and the resources for organizing and controlling activities within an organization.
n Employee involvement provides the means through which workers develop and express their commitment to safety and health protection.
B. Workplace analysis (surveys and job hazard analysis, inspections and hazard controls, and employee hazard reporting):
n Workplace analysis involves a variety of worksite examinations to identify not only existing hazards, but also the conditions and operations where changes may occur to create hazards.
n Effective management actively analyzes the work and the workplace to anticipate and prevent harmful occurrences.
C. Accident reporting, investigation, and analysis:
n Reporting and investigating accidents and near-miss incidents and analyzing their causes helps determine a means for preventing them.
n Analyzing injury and illness trends over time helps identify common causes and develop preventive measures.
D. Hazard prevention and control:
n This activity is triggered by a determination that a hazard or potential hazard exists.
n Where elimination is feasible, hazards are prevented by effectively designing job tasks and/or the job site.
n Where elimination is not feasible, hazards are controlled to prevent unsafe conditions and unhealthful exposure.
n Elimination or control is accomplished in a timely manner.
E. Emergency response:
Effective emergency response includes written emergency action plans, training, fire inspections, and first aid.
F. Safety and health training:
n Effective safety and health training addresses the safety and health responsibilities of all personnel, whether salaried or hourly.
n Safety and health training is most effective when incorporated into other training about performance requirements and job practices.
n The complexity of training depends on the size and complexity of the workplace and nature of hazards.
n Effective safety and health training ensures that all employees understand the hazards to which they may be exposed and how to prevent harm to themselves and others from exposure to these hazards.
n Such training ensures that supervisors carry out their safety and health responsibilities, including:
n Analyzing the work under their supervision to identify unrecognized potential hazards;
n Maintaining physical protection in work areas;
n Reinforcing employee training through continual performance feedback; and
n Enforcing safe work practices.
G. Motor vehicle safety and driver training:
n Effective motor vehicle safety and driver training ensures proper driver selection, training, and supervision, in accordance with Handbook ELH804, Safe Driver Program.
n Such training ensures compliance with U.S. Department of Transportation regulations.
3-2 Postal Service Program
3-2.1 Requirements
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Managers must:
n Demonstrate a commitment to providing safe and healthful working conditions in all Postal Service owned and leased installations, along with being involved in day-to-day safety performance.
n Be held accountable for safety performance and compliance with OSHA standards and regulations.
Installation heads in facilities that do not have a full-time safety professional assigned, must designate an Executive and Administrative Schedule (EAS) employee as facility safety coordinator (FSC).
3-2.2 Program Elements
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The Postal Service program elements include management commitment, involvement, and accountability.
3-3 Management Commitment, Involvement, and Accountability
3-3.1 How to Demonstrate Commitment
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Key steps for demonstrating commitment include the following:
n Develop a written policy statement.
Executives and managers at all levels should ensure that a current written safety policy statement is in effect. This policy should stress that safety is a line-management responsibility supported by Postal Service Safety and Health Program professionals and senior management officials.
n Establish personal communications.
Executives and managers should:
n Periodically send to targeted audiences memorandums, articles, and other communications highlighting major safety initiatives, success stories, exceptional safety performance, and other safety-related activities.
n Stress commitment, involvement, and accountability to their managers and supervisors.
n Publicize information on OSHA compliance activities and the Postal Service Safety and Health Program.
n Consider funding needs.
During annual budget reviews, managers must give consideration to adequately funding locally the Postal Service Safety and Health Program, as noted in ELM section 818, “Safety and Health Program Budgeting.”
n Establish Executive Safety and Health committees.
ELM section 815, “Executive and Management Safety and Health Committees,” requires executives and managers to establish these committees at all levels. Executives must ensure that the committees meet at least quarterly to address safety program issues, as required by standards in the ELM.
n Attend Joint Labor-Management Safety and Health Committee meetings.
Executives and managers should attend meetings of the Joint Labor-Management Safety and Health Committee, and do the following:
n Discuss the Postal Service Safety and Health Program and their personal commitment to safety in the workplace and to the program.
n Discuss the committee’s function and responsibility, and their expectations of and support for the committee.
n Review local initiatives.
n Review successes and failures.
n Ask about the agenda, minutes, and recurring items.
n Review employee complaints and PS Forms 1767, Report of Hazard, Unsafe Condition or Practice, submitted by employees, and entered into SHMT.
n Review accident data and accident-reduction plan performance as compared to established accident-reduction targets in SHMT and on the Safety Dashboard.
n Ensure that committee members receive appropriate training.
n Encourage employee participation.
Executives and managers should encourage and be involved in national and local employee participation programs. Refer to SHMT for the latest information on facility efforts.
3-3.2 How to Demonstrate Involvement
3-3.2.1 Conduct Safety-Specific Executive and Management Field Visits
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Field visits present excellent opportunities for executives and managers to demonstrate their commitment and direct support for doing business safely. Executives and managers should focus visits solely on demonstrating commitment and involvement in the safety process. Suggested activities for these visits include:
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n Meet with safety professionals and other supporting employees.
n Discuss support for safety and solicit comments on the local program’s effectiveness.
n Review interaction between Postal Service Safety and Health Program and Occupational Health Claims (OHC) functions.
n Attend safety and health-related awards ceremonies.
Opportunities include:
n National Safety Council’s Safe Driver annual pin recognition, and Kaplan and Million Mile awards.
n Safety Leadership and Vision Award.
n Local ceremonies that acknowledge excellent safety performance.
n Visit employee orientation, craft safety training, and initial-level supervisor, associate, or supervisor refresher training.
These activities provide excellent opportunities to discuss:
n How safety is smart business.
n The Postal Service Safety and Health Program and processes.
n Line-management responsibility and accountability.
n Employee rights and responsibilities.
3-3.2.2 Inspect and Observe
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Managers at all levels must periodically check for unsafe acts, conditions, and work practices.
3-3.3 How to Demonstrate Accountability
3-3.3.1 National Performance Assessment
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The National Performance Assessment (NPA) provides scorecards that may be used to monitor performance of the entire enterprise across the nation. The scorecards include safety-performance criteria, such as OSHA Injury and Illness rates, the Total Accident Rate, and OHC initiatives.
3-3.3.2 Pay for Performance
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The Pay for Performance (PFP) program emphasizes the organization’s success through objective measurable performance indicators that are aligned at the corporate level, and include Safety and OHC indicators. Headquarters establishes Postal Service Safety and Health Program and OHC indicators and targets. By implementing effective program management and accident-reduction programs, executives and managers can achieve these targets.
Note: Executives’ and managers’ performance in this program is measured based on Postal Service Safety and Health Program performance.
3-3.4 Resources
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See SHMT and the OSH Scorecard.
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3-4 Accident-Reduction Plans
Accident-reduction plans target specific Postal Service Safety and Health Program indicators (such as slips, trips, and falls) with specific actions and tasks to reduce the number of accidents. Each year accident-reduction plans that target specific Safety and Health Program indicators must be implemented and tracked in SHMT.
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3-5 Inspections, Improvement Plans, and Written OSHA Compliance Programs
The following includes benefits of safety inspections, safety-improvement plans, and OSHA safety-compliance programs, and information on templates available for OSHA safety programs:
n Inspections identify hazards.
n Improvement plans identify procedures to abate hazards.
n Templates for OSHA-required written programs ensure compliance with specific OSHA standards. Templates are available for programs, such as hazard communication, personal protective equipment, and confined-space safety. Templates are also available on the following safety topics:
n Asbestos.
n Bloodborne pathogens.
n Electrical work plan
n Hazardous material.
n Hearing conservation.
n Lead.
n Respiratory protection.
3-6 Engagement of Postal Service Unions and Employees
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Effective engagement promotes employee involvement and includes agreements with unions on specific Postal Service Safety and Health Program initiatives. (See Article 14 of labor-contract agreements between the Postal Service and national unions.) Examples of effective engagement:
n Promoting active participation in practicing safety and ergonomics in the workplace.
n Providing methods for employee feedback on ideas to improve safety.
n Showing to employees the Postal Service Safety and Health Program video series, “Safety Depends on Me,” which enables communication with employees on safety and fosters motivation for using safe practices.
3-7 Safe Driver Program
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***The program also provides guidance on refresher training for Postal Service drivers.***
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3-8 Safety and Health Management Tool (SHMT)
3-8.1 Purpose
The Safety and Health Management Tool (SHMT) is designed to be used by all levels of the organization, providing managers and employees with access to information about Postal Service Safety and Health Program inspections, accident and hazard reporting, and tools to track safety-program progress.
3-8.2 Content
SHMT provides Postal Service employees with a wealth of safety, health, environmental, and ergonomics information.
The SHMT library contains accident-reduction information. This site also provides the following resources, including but not limited to:
n Guidance and tools for managing accident-reduction plans and goals.
n Best practices and countermeasures.
n Tools for data management and accident analysis.
n National Job Safety Analyses (JSAs) for many tasks for local adaptation.
n Safety inspection checklists.
n Written program guides and templates for 10 OSHA standards.
n Guidance and references for safety and health topics, such as:
n Developing Emergency Action Plans (EAPs).
n Reporting on motor vehicle and industrial accidents.
n Giving safety talks (including sample safety talks on many topics).
n Links to Postal Service safety references (manuals, handbooks, management instructions, etc.).
3-8.3 Access
To access SHMT:
n Go to Blue at blue.usps.gov.
n Click on MyHR on the bar at the top of the page or Featured Topics at left on the page.
n Under MyHR click on Safety & Labor and then Safety Tools for Managers.
n Under Featured Topics, click on Front Line Supervisor’s Toolkit, and then the tab “Apps/Tools.” Under Apps/Tools click on SHMT.
Contact the local Safety office or OHC for additional assistance.
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4 Working With OSHA
4-1 Investigating Employee Safety and Health Complaints
4-1.1 Complaints and Inspections
4-1.1.1 Employee Complaints to OSHA
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Many investigations and inspections result from employee complaints. The most effective method to reduce the number of employee complaints to OSHA is to ensure that:
n PS Forms 1767, Report of Hazard, Unsafe Condition or Practice, submitted by employees, or entered into SHMT, are handled expeditiously.
n Hazards are abated in accordance with Postal Service policy and documented in accordance with requirements in the ELM.
4-1.1.2 Handling Complaints Internally
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n OSHA procedures allow for contacting the employer to:
n Advise management of the complaint; and
n Request an investigation and correction of hazards by the employer.
n Managers may avoid an unnecessary inspection by:
n Responding within 5 working days and correcting any hazards;
n Posting the information that the complaint has been addressed and any hazard corrected; and
n Notifying employees of any hazard and that it has been corrected.
n Managers may also request additional time and dispute complaints with detailed evidence of the conditions. OSHA shares the information obtained from management with the complainants.
n OSHA has wide discretion to forego an inspection if OSHA personnel believe the hazard:
n Does not exist; or
n Has been abated.
4-1.1.3 NIOSH Health Hazard Evaluations
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Based on employee complaints, the National Institute for Occupational Safety and Health (NIOSH) may indicate the intent to conduct a Health Hazard Evaluation (HHE). A manager who receives a written or telephone notification that NIOSH intends to conduct an HHE must immediately contact area Senior Field Safety and Health specialists. Managers must not refuse an investigation or deny NIOSH entry onto the premises. However, they may request time to coordinate with Senior Field Safety and Health. A manager must not initiate a request to NIOSH for an HHE without consulting Senior Field Safety and Health.
4-1.2 Steps to Take
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Managers should take the following steps to ensure that employee safety complaints are handled expeditiously:
n Ensure that PS Forms 1767 submitted or entered into SHMT by employees are properly tracked and responded to in accordance with ELM section 824.6, “Investigating Employee Reports of Hazard, Unsafe Condition, or Practice.”
n Hold supervisors responsible for responding timely to submitted PS Forms 1767.
n Place the highest priority on responding to requests by OSHA for investigation of employee complaints, as follows:
n Upon receipt of such a request, notify the installation head and the supporting Safety office.
n Make sure the response to OSHA is signed by the installation head and transmitted on time (within 5 working days).
n Notify Senior Field Safety and Health if NIOSH communicates the intent to conduct an HHE.
4-2 OSHA Inspections and Citation Management — Postal Service Responsibilities
4-2.1 Executives and Managers
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n Review and be familiar with ELM section 825, “OSHA Inspections.” (The ELM is available at blue.usps.gov/cpim/manuals.htm.)
n Review OSHA guidance on conducting inspections, information on employer rights and responsibilities, and other safety and health information available at osha.gov.
4-2.2 Installation Heads
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Installation heads must do the following:
n Achieve compliance with OSHA standards within the facilities under their control.
n Review and be familiar with ELM section 825, “OSHA Inspections.” (The ELM is available at blue.usps.gov/cpim/manuals.htm.)
n Review OSHA guidance on conducting inspections, information on employer rights and responsibilities, and other safety and health information available at osha.gov.
Information on OSHA inspections and compliance activity, and employer rights and responsibilities following an OSHA inspection is available on the “OSHA® FactSheet: Occupational Safety and Health Administration (OSHA) Inspections” at osha.gov/sites/default/files/publications/factsheet–inspections.pdf.
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4-2.3 Occupational Safety and Health (OSH)
OSH Headquarters:
n Oversees the citation management process for Headquarters.
n Coordinates with the General Counsel and affected Headquarters organizations responses to citations for violations.
n Oversees quality control of citation information entered in the OSHA Citation Management in SHMT.
n Resolves discrepancies in the information with the responsible safety specialist.
n Analyzes citation information.
n Reports the results of the analysis to key Postal Service personnel.
n Identifies national opportunities to prevent further citations and improve safety and health programs based on the analysis of citation data.
n Assists on-site to resolve citation issues as required.
4-2.4 General Counsel
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The Postal Service General Counsel’s centralized OSHA unit:
n Oversees legal aspects of the citation management process nationally, at Headquarters and in the field.
n Is responsible for approving citation-related correspondence to be sent to OSHA.
n Prepares all protective notices and notices of contest and mails them to OSHA.
n Prepares and distributes additional correspondence to OSHA for selected citations as determined citation by citation.
n Provides consultative assistance to Occupational Safety and Health field staff and Senior Field Safety and Health personnel.
n Helps Occupational Safety and Health field staff and Senior Field Safety and Health personnel resolve citation issues.
n Oversees and handles all required litigation with the Occupational Safety and Health Review Commission and federal courts.
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4-2.5 Maintenance Policy and Programs, Engineering
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n Helps implement programs to abate systemic maintenance-related hazards.
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4-2.6 Maintenance Operations (Area)
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Managers of Maintenance Operations (Area):
n Oversee abatement of hazards resulting in violations in their area of responsibility.
n Support district and plant managers in abating hazards.
n Help implement programs to abate systemic maintenance-related hazards.
4-2.7 Facilities Service Offices
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Personnel in Facilities Service offices confirm that processes are in place to ensure prioritizing projects based on OSHA citations and abatement schedules.
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4-2.8 Safety Specialists
Field safety specialists, assigned by managers of Safety and Health within each field office, enter OSHA inspection and citation data into SHMT. To perform this task, they must:
n Enter citation information for facilities in their area of responsibility (including Headquarters field units) as soon as they are received, but no later than by close of business (COB) on the day the citation is received from OSHA.
n Fax or email copies of the citation to OSH, the General Counsel at Headquarters, and Senior Field Safety and Health, preceding the faxes or emails with a telephone call.
n Keep the citation information current and accurate as hazards are abated and citation management activities progress. Enter this information as soon as these activities are accomplished, but no later than COB that day.
n Enter abatement actions as soon as they are accomplished, but no later than COB that day.
n Keep informed Senior Field Safety and Health and the responsible manager.
n Facilitate abatement actions with responsible managers.
n Before transmittal, coordinate all citation-related correspondence to OSHA with OSH, the General Counsel at Headquarters, managing counsels, field offices, and Senior Field Safety and Health.
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4-2.9 Senior Field Safety and Health
Senior Field Safety and Health personnel will oversee the citation management process within their areas. Senior Field Safety and Health personnel:
n Identify facilities, program areas, and procedures within their areas that require improvement, and notify management.
n Support implementation of nationally targeted efforts to improve program areas and procedures.
n Before transmittal, coordinate all citation-related correspondence to OSHA with OSH, the General Counsel at Headquarters, and with their area Legal Department staff representative.
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4-3 OSHA Citation Management in SHMT
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4-3.1 About SHMT
The Safety and Health Management Tool (SHMT) is a real-time application that safety specialists use to record OSHA inspection and citation information. Once safety specialists digitally enter key information from OSHA citations, the information is made electronically available in a series of views, reports, and charts. SHMT users with authorized access may view the data or print the presentation-quality reports and charts. The views, reports, and charts present the inspection information in logical, easy-to-understand formats that simplify analyzing the data.
The benefit of using SHMT is to provide quick and reliable access to OSHA inspection information so that managers:
n Address citation settlement promptly.
n Ensure prompt abatement of hazards.
n See the types of citations their facilities or like facilities receive and take appropriate preventive or corrective action at their facilities.
n May identify trends in the OSHA citations and develop action plans to prevent similar citations at like facilities.
SHMT also allows the Postal Service to maintain an accurate electronic record of OSHA citations.
4-3.2 Access
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The opening inspection screen shows the main view of the citation data, year to date, and provides:
n A list of inspections by area and access to the full text of each inspection report.
n Access to data-entry forms for new citations by:
n Clicking the Audit tab at left on the home page;
n Then clicking Inspection Management; and then
n Clicking Inspections.
To locate the applicable OSHA inspection, use the search option to view details of each violation associated with the citation. To review entries, select report tabs located at the bottom of the page.
For help, contact Senior Field Safety or local Field Safety.
[Revise the title and text of Appendix A to read as follows:]
Appendix
Postal Service Executives’ and Managers’ Safety and Health Planner
[Delete Appendix B in its entirety.]
The Postal Service will incorporate these revisions into the next online edition of Handbook EL-802.
Handbook EL-802 is available on the Postal Service PolicyNet website:
n Go to blue.usps.gov.
n In the left-hand column, click Essential Links, and then click PolicyNet.
n Go to the right-hand side under “Published Forms and Directives.”
n Click Handbooks.
The direct URL for the Postal Service PolicyNet website is blue.usps.gov/cpim.
— Occupational Safety and Health,
Human Resources, 9-19-24
