2.1 What is the purpose of this chapter? This chapter describes:
A. The U.S. Fish and Wildlife Service (Service) policy and responsibilities for ensuring we have the appropriate resources to support the Collateral Duty Safety Officer (CDSO) program, and
B. The duties CDSOs must perform and the requirements with which they must comply.
2.2 What is the Service policy for the CDSO program?
A. All of our duty stations must have a CDSO either on site or at another site to advise and assist Project Leaders/Supervisors/Facility Managers (called “Project Leaders” throughout this chapter) to achieve the Project Leader’s responsibility to implement the station’s safety and occupational health program (see Table 2-1). Duty stations include, but are not limited to, field stations, complexes, Regional offices, Headquarters, and the National Conservation Training Center (NCTC).
Table 2-1: When Duty Stations Need a CDSO
If the duty station has… | Then… |
4 or more employees | It must have a CDSO whose primary duty station is the facility. A Project Leader for a large duty station may choose to have more than one CDSO. |
3 or fewer employees | The CDSO does not have to be stationed at the facility. If the station does not have a CDSO on staff, the Project Leader must ensure that the smaller station is adequately served by a qualified CDSO from another station. |
B. In the Regional offices, Headquarters, and NCTC, a CDSO’s responsibilities may cross program divisions and represent multiple Project Leaders in the same facility. The Station Safety Plan must describe the selection process and responsibilities of their CDSO(s).
C. Regional Safety Managers are responsible for assisting and advising CDSOs to perform their duties (see section 2.4).
2.3 What are the authorities for this chapter?
A. Occupational Safety and Health Act (OSHA) Federal Agency Safety Programs and Responsibilities (Public Law 91-596, Sec. 19).
B. Executive Order 12196, Occupational Safety and Health Programs for Federal Employees.
C. Basic Program Elements for Federal Employee Occupational Safety & Health Programs and Related Matters (29 CFR 1960).
D. Department of the Interior (Department) Occupational Health and Safety Training Guide.
E. 485 Departmental Manual (DM) 1, Safety and Occupational Health Program: Authority, Purpose, and Policy.
F. 485 DM 11, Staffing Safety and Health Positions.
G. 485 DM 13, Safety and Health Training.
H. 485 DM 28,Collateral Duty Safety Officer Program.
2.4 Who is responsible for the CDSO program? Table 2-2 shows who is responsible for the Service CDSO program.
Table 2-2: Responsibilities for the CDSO program
This official… | Is responsible for… |
A. The Director | (1) Ensuring that the Service maintains an effective and comprehensive safety and occupational health program, and (2) Approving our CDSO program policy. |
B. The Assistant Director - Business Management and Operations | (1) Monitoring the effectiveness and recommending improvements to the CDSO program, and (2) Providing sufficient support and resources to the Chief, Division of Safety and Health, to ensure that the Chief can accomplish program goals. |
C. Regional Directors and the Director, National Conservation Training Center (NCTC) | (1) Ensuring that there are sufficient resources and support in place to implement an effective and comprehensive CDSO program within their areas of responsibility, (2) Overseeing and providing resources for their safety and occupational health programs, and (3) Ensuring trained and qualified staff evaluate duty stations’ (and NCTC’s) implementation of safety and occupational health program requirements. |
D. The Chief, Division of Safety and Health | (1) Revising and updating this chapter, as necessary, and (2) Interpreting the requirements in this chapter and resolving Servicewide issues and questions about our CDSO program. |
E. Regional Safety Managers | (1) Advising managers and CDSOs on the implementation of the CDSO program in their Regions; (2) Providing guidance and assistance to Project Leaders, when requested, to enable Project Leaders to select a CDSO for their facilities; (3) Interpreting program requirements and resolving Regionwide issues and questions; (4) Preparing or recommending additional safety and occupational health training for CDSOs, as appropriate; and (5) Evaluating how well duty stations are meeting Servicewide safety and occupational health program requirements, including those in the CDSO program. |
F. Project Leaders | (1) Implementing an effective safety and occupational health program for the duty station for which they are responsible; (2) Appointing a CDSO (or for small duty stations, working with another station to appoint a CDSO) for a term of at least 2 years and certifying the appointment (see section 2.5); (3) Ensuring Regional Safety Managers are notified of nominations and appointments; (4) Ensuring that CDSOs receive required training within 6 months of appointment (see section 2.8); (5) Entering information showing employees’ completion of CDSO training into the Department’s Learning Management System (e.g., DOI Learn); (6) Providing CDSOs a minimum of 10 percent of official duty time to work on safety and occupational health-related responsibilities. If the field station’s safety and occupational health program requires more of the CDSO’s time to achieve safety and occupational health program compliance, the Project Leader must address the needs (e.g., authorizing more duty time for safety and occupational health or using contract support); (7) Ensuring CDSOs have adequate support, appropriate equipment, and sufficient resources to perform their assigned duties (equipment requirements and availability vary depending on the location); (8) Addressing safety and occupational health-related issues that the CDSO does not have the authority or technical expertise to resolve; and (9) Immediately stopping activities that are of imminent danger to individuals. |
G. Collateral Duty Safety Officers (CDSOs) | (1) Reporting directly to the Project Leader and assisting him/her/them to implement the safety and occupational health program, (2) Performing required CDSO duties (see section 2.10 for more information), (3) Maintaining open communication with the Regional Safety Office about the facility’s safety and occupational health program and any related issues, (4) Requesting support from the Regional Safety Office to address complex hazards or exposure monitoring, and (5) Immediately stopping activities that are of imminent danger to individuals. |
H. Employees | (1) Immediately reporting the following to their Project Leader or the CDSO: (a) Unsafe or unhealthy working conditions, (b) Job-related accidents that result in, or have the potential to result in, harm to people, damage to property, or a potential tort claim, and (c) Any personal conditions that could adversely affect the person’s ability to perform his/her/their job in a safe and healthful manner; (2) Cooperating: (a) During safety and occupational health evaluations and inspections, and (b) With implementing safety and occupational health-related corrective actions; and (3) Immediately stopping activities that are of imminent danger to individuals. |
2.5 How does an employee become appointed and certified for a CDSO position, and how long do they serve?
A. The Project Leader appoints an employee to serve as the CDSO for at least 2 years.
B. First, the Project Leader must tell the Regional Safety Manager who he/she/they is appointing. The Regional Safety Manager fills out and signs FWS Form 3-2420, (CDSO Certification Form) and sends it to the Project Leader.
C. The Project Leader and the CDSO identify the CDSO training attended (when training is completed) and complete and sign the remaining portions of the form. The form is kept at the facility while the current CDSO is serving in the position, and retained there for 5 years after the CDSO has completed his/her/their time serving as CDSO.
D. The Project Leader must inform the Regional Safety Manager when a CDSO position is vacated or there is any other change. The Regional Safety Manager then initiates changes on FWS Form 3-2420 (CDSO Certification Form) and sends it to the Project Leader.
(1) If a CDSO position is temporarily vacated, the Project Leader must identify and appoint an interim CDSO.
(2) The interim CDSO:
(a) May be employed at the facility, serve from a nearby facility, or serve from a facility at the next higher organizational level, and
(b) Must meet the qualification, training, and certification requirements of this chapter.
2.6 What are the qualifications for a CDSO? The CDSO must:
A. Meet the training requirements in this chapter (see section 2.8),
B. Have the skills, knowledge, experience, and judgment to:
(1) Assist the Project Leader in managing an effective safety and occupational health program,
(2) Recognize and evaluate occupational health and safety hazards of the working environment and recommend corrective actions, and
(3) Assist supervisors, employees, volunteers, and other staff with safety and occupational health-related information and issues.
2.7 Does the Project Leader need to put the CDSO duties in the employee’s position description? Although we do not require that the CDSO duties be in the employee’s position description, we have included example language in Exhibit 1 to show how a Project Leader could amend a position description. You can find more information on collateral duty position descriptions in 225 FW 1, Position Classification, or contact your Regional Human Resources Office.
2.8 What are the training requirements for CDSOs?
A. Within 6 months of appointment, a CDSO must take training on the following topics (unless the CDSO has already had the training in the last 3 years) (see section 2.9 for resources):
(1) Basic elements of organizing, planning, and managing an effective safety and occupational health program.
(2) Section 19 of OSHA, Executive Order 12196, and 29 CFR 1960.
(3) Departmental and Service safety and occupational health program.
(4) Procedures for reporting, evaluating, and abating safety and occupational health hazards.
(5) Procedures for reporting and investigating allegations of reprisal related to safety and occupational health.
(6) Recognition of hazardous conditions and environments.
(7) Identification and use of safety and occupational health standards.
(8) Other appropriate rules and regulations, including any specific Regional or duty station policies.
B. The CDSO must acquire any additional training needed to meet OSHA or Service training standards for their safety and occupational health program responsibilities. Some programs—confined spaces, respirator program coordinator, competent person to oversee excavations, etc.—may require additional specific training or certification.
2.9 Where can CDSOs find training resources? We recommend:
A. The following types of courses if the Regional Safety Manager approves them first:
(1) CDSO training that the Service or Regional Safety and Occupational Health staff sponsor or teach;
(2) Safety management courses that an accredited college, university, or Federal agency offers;
(3) Safety management seminars or classes that a professional safety organization (e.g., American Society of Safety Engineers) sponsors; and
(4) OSHA outreach courses (you can use an Internet search engine to find a course offering near you):
(a) 30-hour General Industry/ 29 CFR 1910,
(b) 30-hour Construction Industry/ 29 CFR 1926,
(c) OSHA 511 General Industry, and
(d) OSHA 510 Construction Industry.
B. OSHA 6000 course – Collateral Duty Safety Course for Federal Agencies. You can use an Internet search engine to find a course offering near you.
C. The Department’s Collateral Duty Safety Officer online courses (see Exhibit 2 for a list). These courses are available online on the Department’s Learning Management System (i.e., DOI Learn). Once completed, the system issues a CDSO certificate.
2.10 What are the duties of the CDSO? With guidance from the Project Leader, CDSO duties include, but are not limited to:
A. Advising management in the development and implementation of an effective safety and occupational health program. This includes raising safety and occupation health-related issues, problems, or potential problems to managers.
B. Recommending the services of a safety and occupational health professional to the Project Leader when the site needs technical information and support.
C. Working with the Regional Safety Office staff, as necessary, to implement the safety and occupational health program.
D. Maintaining a working knowledge of OSHA, Departmental, Service, and field station safety and occupational health standards, regulations, and policies.
E. Monitoring the effectiveness of the safety and occupational health program at their duty stations.
F. Attending safety and occupational health management and technical training to remain proficient, including completing program-specific training as needed to meet applicable standards.
G. Completing or assisting with the required annual facility safety and occupational health inspection and related follow-up reports.
H. Based on facility safety occupational health inspection findings, recommending appropriate actions to correct deficiencies and abate hazards, and assisting the Project Leader to track identified hazards through the abatement process.
I. Where applicable, serving as a member and advisor to the duty station’s safety and occupational health committee. In this capacity, the CDSO:
(1) Schedules and attends committee meetings,
(2) Ensures minutes of the meetings are prepared and filed, and
(3) Chairs the meetings when the Project Leader is unavailable (see 240 FW 1).
J. Serving as a member and advisor to local safety and occupational health working groups.
K. Using accident data to identify accident, injury, and illness trends and proposing to the Project Leader and safety committee actions to prevent accidents (including management, supervisory, and employee training).
L. Either completing job hazard assessments (JHAs) for hazardous tasks or ensuring other staff complete them, and ensuring the Project Leader reviews and certifies the JHAs (see 240 FW 1).
M. Conducting or coordinating safety and occupational health training for duty station employees, and reviewing the station’s system of maintaining training records to ensure it meets requirements.
N. Assisting Regional Safety Office staff during safety and occupational health inspections and evaluations.
O. Assisting the Project Leader to make sure all accidents are investigated, reported, and reviewed according to Service policy.
P. Reviewing and posting OSHA form 300A, Summary of Work-Related Injuries and Illnesses, for the duty station, and maintaining files of these logs as required.
Q. Reviewing the Station Safety Plan on at least an annual basis and recommending changes as appropriate.
2.11 How much time does a CDSO have to spend on collateral safety duties? CDSOs must devote a minimum of 10 percent of their duty time to safety and occupational health program responsibilities. If the field station’s program requires more than 10 percent of the CDSO’s time to achieve compliance, the Project Leader must address the situation appropriately (e.g., authorizing more of the CDSO’s duty time to achieve compliance, hiring contractor support, etc.).
2.12 Should CDSO duties be in Employee Performance Evaluation Plans (EPAP)? While not required, it is beneficial to have a critical element in your EPAP related to your CDSO duties. This helps both you and your supervisor communicate clearly about one another’s expectations for the CDSO position. See Exhibit 3 for an example critical element related to CDSO duties.
2.13 Where can CDSOs and Project Leaders find more information about the Service safety and occupational health program?
A. You can contact your Regional Safety Manager for more information about our safety and occupational health program.
B. You can also find information in the Department of the Interior Occupational Health and Safety Training Guide.
C. Also be sure to read all the other safety and occupational health program chapters in Part 240 through Part 244 of the Service Manual. These chapters include, but are not limited to covering:
(1) Safety Program Management,
(2) Safety and Health Training and New Employee Orientation,
(3) Safety and Occupational Health Inspections,
(4) Employee Reports of Unsafe or Unhealthful Working Conditions,
(5) Accident Investigation and Reporting, and
(6) Safety Program for Volunteer and Youth Programs.
D. Also review any safety and occupational health-related Regional policies or Regional Director’s Orders.