HEADQUARTERS UNITED STATES AIR FORCE …

1 DEPARTMENT OF THE AIR FORCE HEADQUARTERS UNITED STATES AIR FORCE WASHINGTON, DC AFI91-202_AFGM2017- 01 25 May 2017 memorandum FOR DISTRIBUTION MAJCOMs/FOAs/DRUs FROM: AF/SE SUBJECT: Air FORCE Guidance memorandum to AFI 91-202, The US Air FORCE Mishap Prevention Program By Order of the Secretary of the Air FORCE , this is an AF Guidance memorandum immediately implementing changes to AFI 91-202. This AFGM updates the OSHA events process, and introduces and identifies responsibilities for the new Air FORCE OSHA Process Manager, as directed by the Assistant Secretary of the Air FORCE for Installations, Environment and Energy (SAF/IE). To the extent its directions are inconsistent with other Air FORCE publications, the information herein prevails, in accordance with AFI 33-360, Publications and Forms Management. In advance of a rewrite of AFI 91-202, the Attachment to this memorandum is updated to provide guidance changes that are effective immediately. An asterisk (*) indicates newly revised material.

2 The memorandum becomes void after one-year has elapsed from the date of this memorandum , or upon incorporation of an Interim Change or rewrite of AFI 91-202, whichever is earlier. ANDREW M. MUELLER, Maj Gen, USAF Chief of Safety Attachment: Guidance Changes Attachment Guidance Changes The below changes to AFI 91-202, dated 24 June 2015, are effective immediately. Through the BSC Associate Chief for Bioenvironmental Engineering (AFMSA/SG3PB), coordinates on installation-level proposed responses related to OSHA events. Assigns the Chief of Occupational Safety as the USAF OSHA Process Manager. Develops, implements and oversees the Air FORCE OSHA Process Management system for the cross-functional integration and execution of OSHA events and procedures for Federal or State programs. Coordinates on installation-level proposed responses related to OSHA events. Coordinates the cross-functional integration and execution of OSHA events, responses, and procedures as prescribed within this instruction.

3 Serves as chairperson for OSHA visit meetings to the installation, but may delegate to the vice wing commander or Chief of Safety. (T-2) Ensures proper coordination and is the final signature on official responses from the installation to OSHA. (T-2) The final signature will be delegated no lower than the Vice Wing Commander. (T-2) The Occupational Safety Manager functions as primary point of contact and process manager for cross-functional management of all federal and state OSHA visits to the installation, as well as OSHA requests for self-investigations/inspections. Assigns roles to OSHA cross-functional representatives as needed, including tenant unit safety staffs when the OSHA event involves the tenant unit. (T-2) Attends all DoL OSHA inspector in-briefs and out-briefs, accompanies inspectors during all health-related inspections/investigations and crafts any related correspondence to OSHA for all identified occupational health concerns for installation Commander s endorsement and release after full coordination as specified within this instruction.

4 (T-2) Attends all DoL OSHA inspector in-briefs and out-briefs, accompanies inspectors during all health-related inspections/investigations and crafts any related correspondence to OSHA for all identified occupational health concerns for installation Commander s endorsement and release after full coordination as specified within this instruction. (T-2) Ensures the Bioenvironmental Engineer or Public Health officer, as applicable, attends all DoL and OSHA inspector in-briefs and out-briefs, accompanies inspectors during all health-related inspections/investigations, and crafts any related correspondence to OSHA for identified health concerns for installation Commander s endorsement and release after full coordination as specified within this instruction. (T-1) Ensures a fire department representative attends all DoL OSHA inspector in-briefs and out-briefs, accompanies inspectors during all fire/life safety related inspections/investigations and crafts any related correspondence to OSHA for all identified fire/life safety concerns for installation Commander endorsement and release after full coordination as specified within this AFI.

5 (T-2) Where commanders below the installation level, including tenant unit commanders, have an assigned safety staff, ensure they comply with the host safety office procedures for OSHA related events on the installation. (T-2) The Air FORCE Civil Engineering Center (AFCEC): Ensures agency/center support for OSHA-related events. (T-2) Ensures Air FORCE fire and safety policies meet, exceed or receive proper waiver authority to OSHA, NFPA and other applicable requirements. (T-1) Coordinates on installation-level proposed responses related to OSHA events. (T-2) The Air FORCE Judge Advocate (AF/JA): Ensures Air FORCE meets or exceeds OSHA and other applicable requirements. Ensures Air FORCE correspondence to agencies such as OSHA are in compliance with established requirements. Installation Legal Office ensures a legal representative attends all DoL OSHA inspector out-briefs, and reviews all correspondence to OSHA for installation Commander s endorsement and release after full coordination as specified within this instruction.

6 (T-2) The installation safety office may request a legal representative to attend in-briefs, as needed. Responsible for developing and implementing an OSHA Reception & Action Plan. This plan will address actions to implement prior to, during, and after an OSHA event. (T-1) This includes official OSHA representative installation visits and OSHA requests for self-investigation/inspection. These procedures will address all requirements called for in paragraph , and those contained within DoDI , Enclosure 3. (T-1) The DoL may conduct, as part of its evaluation program, annual targeted inspections or program assistance visits of Air FORCE installations based on the comparative incidence of worker compensation claims. The DoL will prescribe special procedures in the notification process. OSHA representatives may question or privately interview any employee, supervisory employee or official in charge of an operation or workplace. Federal or state OSHA representatives must present identifying credentials and state the purpose of the visit to the installation commander or authorized representative before conducting an inspection of a workplace on an Air FORCE installation.

7 OSHA may also request installations perform self-investigations and self-inspections on a case-by-case basis. Installation commanders, through execution of a locally approved OSHA Reception and Action Plan developed IAW paragraph , will: (T-1) Ensure Security Forces are provided a letter of instruction outlining notification procedures to the installation safety office upon OSHA s arrival at the gate. (T-2) Ensure the OSHA representative(s) are met by a member of the installation safety office and escorted to the initial in-brief. (T-2) A safety representative and/or other functional representative ( , FES, BEE, PH, etc.) will escort the OSHA representative to other parts of the installation after the initial in-brief. (T-2) Host an initial in-brief with DoL and State OSHA representatives. (T-2) The installation safety office will notify their CC/CV, JA and IG of OSHA s arrival. (T-2) Notify Bioenvironmental Engineering, Fire Emergency Services, Public Health, Civilian Personnel Office, Contracting Office, tenant unit safety offices and others as needed of the in-brief meeting details.

8 (T-2) Attendance is optional for IG, Contracting and Civilian Personnel Office. Bioenvironmental Engineering, Fire Emergency Services, Public Health and tenant unit safety offices will be expected to attend based upon the OSHA inspector s stated purpose of the visit. (T-2) Provide, upon request, access to available safety, fire protection and health information on workplaces, unless prohibited by this instruction or other AFI guidance. (T-1) Access to privileged safety information is prohibited by DoDI and AFI 91-204. OSHA officials may review non-privileged portions of mishap reports in the workplace during the course of their inspection. Do not release For Official Use Only -marked reports or materials to them. OSHA requests for copies of such reports or materials will be IAW AFI 91-204. OSHA officials requesting access to additional information and records may obtain the information IAW the provision of DoDI Arrange a closing conference with the OSHA official if requested and invite labor representatives to attend.

9 If significant hazards or deficiencies are identified or problems occur during an OSHA inspection or investigation, call the MAJCOM/FOA/DRU safety staff. The MAJCOM/FOA/DRU will in turn immediately notify AFSEC/SEG. Treat DoL OSHA notices of violations in the same manner as a fire, safety or health Air FORCE inspection report. (T-1) Evaluate and assign a RAC to each hazard identified by OSHA personnel. (T-1) Ensure appropriate members of the fire, safety, or health offices verify DoL inspection results, including all testing. (T-1) Air FORCE tests or sampling for future testing should be accomplished at the same time and at the same location as the DoL testing, if possible. Ensure DoL personnel conducting the inspection receive a coordinated response as required and prescribed by the OSHA Notice of Violations (NoVs) instructions. (T-1) If an OSHA inspection team visits the installation and it appears there may be possible NoVs, the installation commander s staff, to include the applicable representative members ( FES, PH, BEE, etc.)

10 , should be notified and involved in abatement plan establishment. Although a unit will be cited individually at a particular location, the identified hazard may, in fact, be classified a Repeat citation, because a similar finding was previously cited at another Air FORCE location. This practice is due to OSHA considering the Air FORCE as an Enterprise-wide organization and OSHA treats related workplaces within a corporate family as one workplace for purposes of Repeat violations. Therefore, the finding is considered a corporate matter rather than a singular installation matter. With the Enterprise-wide applicability of NoVs, all correspondence to OSHA will be coordinated with the appropriate MAJCOM/DRU/FOA (SE, FES, SG) and HAF (AFSEC, AFCEC, AF/SG). (T-1) If required, AFSEC will coordinate with SAF/IEE. The MAJCOM and AFSEC track all violation(s) from identification through proposed response to OSHA and subsequent closure. Upon receiving a NoV, the cited unit will draft and coordinate the proposed official response to the violation, which will then be sent to the applicable MAJCOM/DRU/FOA safety office and AFSEC in parallel.