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Nov 26, 2019

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OSHA VPP

The Occupational Safety and Health Administration (OSHA), on July 2, 1982, announced the establishment of the Voluntary Protection Programs (VPP) to recognize and promote effective worksite-based safety and health management systems.

In the VPP, management, labor, and OSHA establish cooperative relationships at workplaces that are implementing or have implemented comprehensive safety and health management systems.

Approval into VPP is OSHA’s official recognition of the outstanding efforts of employers and employees who have created exemplary worksite safety and health management systems. OSHA offers assistance to sites committed to achieving the VPP level of excellence.

VPP Principles

Voluntarism: Participation in VPP is strictly voluntary. The applicant who wishes to participate freely submits information to OSHA on its safety and health management system, goes above and beyond compliance with the OSH Act and applicable OSHA requirements, and opens itself to agency review.

Cooperation: OSHA has long recognized that a balanced, multifaceted approach is the best way to accomplish the goals of the OSH Act. VPP's emphasis on trust and cooperation between OSHA, the employer, employees, and employees’ representatives complements the Agency’s enforcement activity but does not take its place. VPP staff and VPP participants work together to resolve any safety and health problems that may arise. This partnership enables the Agency to remove participants from programmed inspection lists, allowing OSHA to focus its inspection resources on establishments in greater need of agency oversight and intervention. However, OSHA continues to investigate valid employee safety and health complaints, fatalities, catastrophes, and other significant events at VPP participant sites.

A Systems Approach: Compliance with the OSH Act and all applicable OSHA requirements is only the starting point for VPP participants. VPP participants develop and implement systems to effectively identify, evaluate, prevent, and control occupational hazards to prevent injuries and illnesses to employees. Star participants, in particular, are often on the leading edge of hazard prevention methods and technology. As a result, VPP worksites serve as models of safety and health excellence, demonstrating the benefits of a systems approach to employee protection.

Model Worksites for Safety and Health: OSHA selects VPP participants based on their written safety and health management system, the effective implementation of this system over time, and their performance in meeting VPP requirements. Not all worksites are appropriate candidates for VPP. At qualifying sites, personnel is involved in the effort to maintain rigorous, detailed attention to safety and health. VPP participants often mentor other worksites interested in improving safety and health, participate in safety and health outreach and training initiatives, and provide OSHA with input on proposed policies and standards. They also share best practices and promote excellence in safety and health in their industries and communities.

Continuous Improvement: VPP participants must demonstrate continuous improvement in the operation and impact of their safety and health management systems. Annual VPP self-evaluations help participants measure success, identify areas needing improvement, and determine such changes. OSHA onsite evaluation teams verify this improvement.

Employee and Employer Rights: Participation in VPP does not diminish employee and employer rights and responsibilities under the OSH Act and, for Federal agencies, under 29 CFR 1960 as well.

Participation Levels

There are three levels of participation in the VPP:

  • Star Program: The Star Program recognizes the safety and health excellence of worksites where employees are successfully protected from fatality, injury, and illness by the implementation of comprehensive and effective workplace safety and health management systems. These worksites are self-sufficient in identifying and controlling workplace hazards.
  • Merit Program: The Merit Program recognizes worksites that have functional safety and health management systems and that show the willingness, commitment, and ability to achieve site-specific goals that will qualify them for Star participation.
  • Star Demonstration Program: The Star Demonstration Program recognizes worksites that have Star quality safety and health management systems that differ in some significant fashion from the VPP model and thus do not meet current Star requirements. A Star Demonstration Program tests this alternative approach to ascertain if it is as protective as current Star requirements.

Elements

To qualify for VPP, an applicant/participant must operate a comprehensive safety and health management system that includes four essential elements and their sub-elements. These elements, when integrated into a worksite’s daily operations, can reduce the incidence and severity of illnesses and injuries:

  1. Management leadership and employee involvement.
  2. Worksite analysis.
  3. Hazard prevention and control.
  4. Safety and health training.

STAR Participation

First off, there is no limit to the term of participation in Star, as long as a participant continues to meet all Star requirements and to maintain Star quality.

Injury and Illness History Requirements

OSHA will evaluate the applicant/participant’s injury and illness history by using a 3-year total case incidence rate (TCIR) and 3-year days away, restricted, and/or job transfer incidence rate (DART rate). The 3-year TCIR and DART rates must be below at least 1 of the 3 most recent years of specific industry national averages for nonfatal injuries and illnesses at the most precise level published by the Bureau of Labor Statistics (BLS). Compare both rates to a single year. 

For eligible smaller worksites, companies may use an alternative rate calculation by using their best 3 out of the most recent four years of incidence rates.

Participation Process

The participation process consists of application submittal and review, an onsite evaluation, and an approval or denial process.

OSHA provides the required application template to make it easy for applicants to spell out how the company meets or exceeds the various VPP expectations.

Once approved, OSHA will schedule an onsite visit, and this is where things get interesting. The onsite team will be assembled based on several factors: the size and locations of your various facilities (if more than one), the industry (PSM, construction, and others), the unique conditions at your sites may require IH expertise, ergonomics, or others.

For the most part, OSHA will request volunteers to be a part of this team. Volunteers are from other VPP participating companies and have gone through specialized training with the Department of Labor to become special government employees (SGE) - I use the term employees loosely. OSHA also has provisions in place to prevent competitor companies from being involved as well as guidelines to protect trade secrets.

OSHA will review written programs and documents, interview employees, and conduct site reviews. All of this information will be documented and reviewed each day of the onsite by the OSHA team lead. Any safety deficiencies can be categorized in one of three different ways:

  1. OSHA Requirement
  2. VPP Requirement
  3. STAR Example

Any deficiencies noted that would prevent the approval of the VPP application must be corrected within 90-days of being notified. If not, OSHA may reject the application, and one cannot reapply for another 6-months.

Approval

Once approved, the OSHA Area Office will notify the Assistant Secretary of OSHA regarding the recommended acceptance into the VPP. Once signed, OSHA informs applicants of their acceptance into the program. OSHA awards newly approved participants a plaque and flag, and most companies have a flag ceremony to celebrate this well-deserved achievement.

Maintaining VPP

Companies have to comply with ongoing requirements as well, which means submitting an annual report, maintaining injury/illness rates, not having employee complaints, and a few more you can read about on their website.

Yes, companies can be removed for various reasons. One is if the Union retracts its support for VPP - this has happened before. Any Union representation must co-sign on the application or submit a letter stating they do not object to the VPP application. Again, you can read more about Union support on the OSHA VPP website.

I recorded a 4-part series breaking down all four elements a while back and you can listen to them all by following the links below:

011: VPP Element 1 - Leadership Commitment & Employee Involvement

012: VPP Element 2 - Worksite Safety Analysis

013: VPP Element 3 - Safety Hazard Prevention & Controls

014: VPP Element 4 - Safety & Health Training

As a recap, VPP principles are in line with other leading safety management systems in that they require a systems approach and a process of continuous improvement. What I like about VPP is the support for the program, not only from OSHA and other participants, but there is a world-class organization dedicated to supporting VPP participants. They are called the VPP Participants Association or VPPPA. Please take a look at their website and learn more about how they can help you - whether your company is a VPP site, thinking about applying for VPP or just wanting to learn from the best so that you can improve safety for your people, VPPPA is for you!

So what do you think? ISO 45001, ANSI/ASSP Z10, or VPP? Post a LinkedIn update, letting me know. Be sure to @ mention Blaine J. Hoffmann or The SafetyPro Podcast LinkedIn page. You can also find the podcast on Facebook, Instagram, and Twitter.