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Smithfield Packing

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So you think you’re ready for OSHA VPP?

By W. Jon Wallace, CSP, MBA

A plant manager recently requested I perform an OSHA Voluntary Protection Program (VPP) assessment at his facility. “Jon, we have a great safety program here—I doubt you’ll find any major deficiencies.” Needless to say, the plant manager was quite bewildered during our closing conference when I informed him his facility was at least 2–3 years away from even being considered for OSHA VPP. I have performed numerous VPP assessments for clients—listed below are some pointers on attaining VPP status at your site.

History of OSHA VPP

The Voluntary Protection Program (VPP) began in California in 1979. In 1982, Federal OSHA formally announced the VPP and approved the first VPP site. According to OSHA, the average VPP worksite has a Days Away Restricted or Transferred (DART) case rate of 52% below the average for its industry. These sites typically do not start out with such low rates. Reductions in injuries and illnesses begin when the site commits to the VPP approach to safety and health management and the challenging VPP application process.

How Does VPP Benefit Employers?

Fewer injuries and illnesses mean greater profits as workers’ compensation premiums and other costs plummet. Entire industries benefit as VPP sites evolve into models of excellence and influence practices industry-wide.

VPP Program Elements

To qualify for VPP a facility must have the four VPP elements:

Management Leadership and Employee Involvement

Worksite Analysis

Hazard Prevention and Control

Safety and Health Training

Preparing for VPP

Applying for VPP is typically a lengthy process. Most companies I work with prepare a 3 ring binder containing all program elements. It is important to note the four VPP elements must be in place for one year prior to OSHA performing their onsite review. This helps ensure a facility has had an opportunity to critique the elements and made necessary changes to enhance element effectiveness. Another important component is employees understanding and supporting VPP. This typically consists of educational sessions on VPP as well as promotional campaigns. Also, to attain VPP status you must go above and beyond basic OSHA compliance. A VPP site is considered the gold standard with respect to safety & health programs.

OSHA onsite VPP review

After submitting your VPP application, OSHA will schedule an onsite review. The OSHA review team usually consists of a team leader, a safety specialist, an industrial hygienist, and often a backup team leader. Depending on facility size and technical complexity, the onsite review typically lasts 4 days. Existence of the four VPP elements is confirmed. In addition, OSHA conducts EXTENSIVE employee interviews. This is an excellent barometer of a company’s overall safety and health program. Here are some typical interview questions:

During the onsite review, OSHA will also review work practices that are currently experiencing a high number of incidents. Some typical examples:

Closing Meeting

Prior to the closing meeting, usually on the last full day of the onsite review, the OSHA team will meet to discuss its recommendation and to draft a report detailing its findings.

In determining its recommendation, the team will consider the following:

The team will pay particular attention to consistency—how close the match is—between the safety and health management system described in your application, the documentation provided onsite, workplace conditions, and your employees’ experience with the safety and health management system.

The team may determine that you have met all the requirements for one of the following VPP designations: Star, Merit, or Demonstration.

The team may identify site deficiencies related to compliance with OSHA requirements. You must correct these deficiencies within 90 days or, if you need more than 90 days for certain corrections, have in place interim protection and an agreed upon longer term plan. You must meet this requirement before the OSHA team will send its report and recommendation to the Regional Administrator and ultimately to the OSHA Assistant Secretary.

If your site is not eligible for the VPP at this time, the team will suggest that you withdraw your application. The team also will indicate significant areas needing development should you desire to reapply in the future.

Summary

Attaining VPP status is a lengthy process but the benefits are significant—improved worker safety, increased employee involvement, reduced workers’ compensation premiums as well as continuous safety and health program improvement.

If you have any questions concerning this article or other safety issues, please contact W. Jon Wallace, "The Safety Guru", at 919.933.5548 or by