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
- A management commitment to worker safety and health protection
- Top site management’s personal involvement
- A system in place to address safety and health issues/concerns during overall management planning/purchasing/contracting
- Safety and health management integrated with your general day-to-day management system
- A written safety and health management system—often referred to as a safety and health manual with policy and procedures specific to your site—appropriate for your site’s size and your industry
- A safety and health policy communicated to and understood by employees
- Safety and health management system goals and results-oriented objectives for meeting those goals
- Clearly assigned safety and health responsibilities, with documentation of authority and accountability from top management to line supervisors to site employees
- Necessary resources to meet responsibilities, including access to certified safety and health professionals, other licensed health care professionals, and other experts, as needed
- Selection and oversight of contractors that ensure effective safety and health protection for all workers at the site
- At least three ways employees are meaningfully involved in activities and decision-making that impact their safety and health. These must be in addition to your system of hazard reporting
- Annual safety and health management system evaluations on VPP elements in a narrative format, recommendations for improvements, and documented follow-up
- Formal signed statements from all collective bargaining agents indicating support of your application to VPP
- Where no collective bargaining agent is authorized, written assurance by management that employees understand and support VPP participation.
- A baseline hazard analysis identifies and documents common hazards associated with your site, such as those found in OSHA regulations, building codes, and other recognized industry standards and for which existing controls are well known
- Documentation within the baseline hazard analysis of your sampling strategy to identify health hazards and accurately assess employees’ exposure, including duration, route, frequency of exposure, and number of exposed employees
- Hazard analysis of routine jobs, tasks, and processes that identifies uncontrolled hazards and leads to hazard elimination or control
- Hazard analysis of significant changes, including non-routine tasks, new processes, materials, equipment, and facilities, that identifies uncontrolled hazards prior to the activity or use and leads to hazard elimination or control
- Samples, tests, and analyses that follow nationally recognized procedures
- Self-inspections that cover the entire site at least quarterly (weekly for construction) conducted by trained staff, with written documentation and hazard correction tracking
- A written hazard reporting system that enables employees to:
- —report their observations or concerns to management without fear of reprisal, and
- —receive timely responses
- Accident/incident investigations conducted by trained staff; written findings that aim to identify all contributing factors
- A system that analyzes injury, illness, and related data—including inspection results, observations, near-miss and incident reporting, first aid, and injury and illness records—to identify common causes and needed corrections in procedures, equipment, or programs.
Hazard Prevention and Control
- An effective system for eliminating or controlling hazards. This system emphasizes engineering solutions that provide the most reliable and effective protection. It may also utilize, in preferred order, administrative controls that limit daily exposure, such as job rotation; work practice controls, such as rules and work practices that govern how workers do a job safely and healthfully; and personal protective equipment. All affected employees must understand and follow the system.
- A system for tracking hazard correction. It includes documentation of how and when hazards are identified, controlled or eliminated, and communicated to employees
- A written preventive/predictive maintenance system that reduces safety-critical equipment failures and schedules routine maintenance and monitoring
- An occupational health care program appropriate for your workplace. It includes, at a minimum, nearby medical services, staff trained in first aid and CPR, and hazard analysis by licensed health care professionals as needed
- A consistent disciplinary system that operates for all employees—including supervisors and managers—who disregard the rules
- Written plans to cover emergency situations, including emergency and evacuation drills for all shifts
Safety and Health Training
- Training for managers and supervisors emphasizing safety and health leadership responsibilities
- Training for all employees on the site’s safety and health management system, hazards, hazard controls in place, and the VPP
- Training that enables employees to recognize hazardous conditions and understand safe work procedures
- A method for assessing employee comprehension and training effectiveness
- Documentation of all training that individual employees receive
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:
- What has senior management done recently to improve worker safety?
- If you were the plant manager for one day what would you do to improve safety?
- Where is the next injury going to occur?
During the onsite review, OSHA will also review work practices that are currently experiencing a high number of incidents. Some typical examples:
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:
- Safety and health conditions, including hazards found, plans to correct those hazards, and needed system improvements, if any
- Information gathered from informal and formal interviews
- Successful implementation of VPP elements of an effective safety and health management system
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.
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