OSHA Voluntary Protection Programs

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OSHA Voluntary Protection Programs
OSHA Region III
VPP 101 and the VPP Federal Register
Notice An Overview
December 2006 Peter Brown Region III VPP
Outreach Coordinator
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VPP 101

• Coverage.
• All groups covered by OSHA jurisdiction,
  including federal agencies, are eligible to join
  and participate in the OSHAs Voluntary
  Protection Program.
• VPP participation means OSHA recognizes that the
  worksite has implemented and is maintaining a
  superior safety and health management system for
  its employees. Each worksite that applies for
  VPP must show OSHA that upper management is
  commitment to VPP principles.
• It must encourage effective employee and union
  engagement, ownership and involvement in site
  safety and health. In VPP government (OSHA),
  management and labor work together to make their
  site a world class safety leader in their
  industry.

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VPP 101 (contd)

• Effective and on going safety and health
• programs.
• OSHA believes an effective safety and health
  management system is the best way to prevent
  occupational illnesses and injuries.
• VPP includes compliance with all applicable OSHA
  regulations and standards. By meeting the
  performance-based VPP criteria and elements, the
  VPP participant is expected to use a
  comprehensive system geared toward each
  worksite's needs. Visible management leadership
  and employee engagement and participation in
  addition to company self-evaluations, are key
  elements of this process. Annual self-evaluations
  measure results driven success and identify areas
  needing improvement.

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VPP 101 (contd)

• Cooperation.
• VPP emphasizes trust and cooperation among OSHA,
  the employers, employees and employee
  representatives. Since VPP began in 1982,
  cooperation and the level of protection found at
  VPP sites complements OSHAs enforcement
  activity.
• This assists OSHA to focus its inspection
  resources on higher
• risk establishments. Although VPP sites are
  exempt from programmed inspections, employers and
  employees retain their rights and
  responsibilities under the Occupational Safety
  and Health Act.

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VPP 101 (contd)

• Good Performance.
• Voluntary Protection Programs participants are
  selected based on their written safety and health
  management system, and ongoing performance.
• OSHA also conducts a thorough onsite evaluation
  to judge how well the site's protective systems
  are working, including a review of site
  injury/illness rates. Continuous improvement is
  required to stay in the VPP.

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VPP 101 (contd)

• The VPP Star Program.
• Star is designed for exemplary worksites with
  comprehensive, successful safety and health
  management systems. Companies in the Star
  Program have achieved injury and illness rates
  significantly below their industrys national
  average. Star sites are self-sufficient in their
  ability to control workplace hazards.
• Star participants are reevaluated (recertified)
  initially at the three year anniversary, and then
  every three to five years after that. However,
  injury and illness incident rates are reviewed
  annually.

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VPP 101 (contd)

• VPP Applicant Sites.
• Applicants are encouraged to invite OSHA onsite
  for an informal pre-visit after submittal of the
  application and review by OSHA VPP staff members.
  
• OSHA VPP staff members will share information and
  best practices with the site to assist in
  preparing for the upcoming team review

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VPP 101 (contd)

• Application Review.
• Each VPP applicant undergoes an OSHA review of
  its safety and health management system. The
  multi-stepped onsite team review requires about
  two to four days, depending on the size of the
  facility and complexity of the operations.
• In addition to a review of records, logs and
  inspection history, the on-site review includes
  an initial meeting or opening conference with
  management staff and employees, walk-throughs of
  the facilities to determine hazards and
  precautions, formal and informal interviews, and
  a closing conference to discuss findings and
  recommendations.

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VPP 101 (contd)

• Inspections.
• Participation in VPP does not eliminate the
  rights or responsibilities of employers or
  employees under the Occupational Safety and
  Health Act (OSH Act of 1970).
• OSHA enforcement inspections will result from
  valid complaints, workplace accidents or
  fatalities, chemical leaks and spills and other
  significant/media events.

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Federal Register Notice Overview

• The Voluntary Protection Programs (VPP), adopted
  by OSHA in Federal Register Notice 47 FR 29025,
  July 2, 1982, have established the efficacy of
  cooperative action among government, industry,
  and labor to address worker safety and health
  issues and expand worker protection. VPP
  participation requirements center on
  comprehensive management systems with active
  employee involvement to prevent or control the
  safety and health hazards at the worksite.
  Employers who qualify generally view OSHA
  standards as a minimum level of safety and health
  performance and set their own more stringent
  standards where necessary for effective employee
  protection.

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Federal Register Notice (contd)

• OSHAs experience with VPP and other programs led
  it to publish its voluntary Safety and Health
  Program Management Guidelines (the Guidelines) in
  the Federal Register Notice 54 FR 3904 on January
  26, 1989, The Guidelines present effective
  criteria for organizing a managed safety and
  health program. To maintain consistency in
  OSHA's approach to safety and health program
  management, the Agency has decided to reorganize
  the VPP criteria to conform more closely to the
  Guidelines.

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Federal Register Notice (contd)

• This reorganization has been accomplished by
  merging the six elements (or criteria) of the VPP
  into the four criteria of the Guidelines.
• The reorganization changed Management Commitment
  and Planning to Management Leadership and
  Employee Involvement Hazard Assessment became
  Worksite Analysis Hazard Correction and Control
  became Hazard Prevention and Control Safety and
  Health Program Evaluation has become part of
  Management Leadership and Employee Involvement
  and Safety and Health Training continues as one
  of four basic program criteria, as it is today.

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Federal Register Notice (contd)

• The VPP elements of the four criteria also have
  been rewritten to make them more easily
  understood. This has involved changes in
  language and organization. However, except for a
  variety of minor clarifications, the substance
  and scope of the criteria has changed little.
  The three most notable changes in VPP scope is an
  expansion of eligibility to certain classes of
  worksites previously not covered by the program,
  increased expectations concerning the management
  of the safety and health of contractors
  employees working at VPP sites, and a new illness
  reporting requirement. This last means OSHA will
  consider a worksites illness experience together
  with its injury performance when assessing the
  sites level of achievement.
• In summary, the July 24, 2000 Federal
  Register Notice contains the official Voluntary
  Protection Programs Requirements the VPP FRN.

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Federal Register Notice, Content Outline

• I. Introduction
• II. Rationale for Change
• III. The Voluntary Protection Program
• A. Purpose of VPP
• B. Purpose of this Notice
• C. Program Description

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Federal Register Notice, Content Outline

• E. Assurances
• F. The Star Program
• G. The Demonstration Program
• H. The Merit Program
• I. Application for VPP
• J. Pre-Approval Onsite Review
• K. Recommendation for Program Approval

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Questions? Where do you get the FRN?

• The Region III VPP staff recommends that everyone
  who is interested in the VPP
• begin by reading the July 2000 VPP FRN. This
  document can be located on
• The OSHA website through this link. Its fairly
  brief and very readable.
• http//www.osha.gov/pls/oshaweb/owadisp.show_docum
  ent?p_tableFEDERAL_REGISTERp_id15440
• This presentation may be copied, and distributed
  by anyone.
• This document creates no new OSHA requirements.
• Region III is Pennsylvania, West Virginia,
  Virginia, Delaware, Maryland, and the District of
  Columbia.
• Peter Brown
• brown.peter_at_dol.gov
• The Philadelphia Regional Office