OSHA Voluntary Protection Programs

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OSHA Voluntary Protection Programs
OSHA Region III
The VPP Elements An
Overview December
2006 Peter Brown Region III VPP Outreach
Coordinator
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Criteria I Management Leadership Employee
Involvement

• July 2000 Federal Register Notice, Description of
  the Voluntary Protection Programs, Source of VPP
  Requirements
• Management Commitment
• VPP Commitment
• Planning
• Written Safety Health Program
• Top Management Leadership

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Criteria I Management Leadership Employee
Involvement (contd)

• Authority Resources
• Line Accountability
• Contract Workers
• Employee Involvement
• Safety Health Management System Evaluation

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Criteria I Management Leadership Employee
Involvement (contd)

• A Closer Look
• Management Commitment
• Clearly established policies that have been
  communicated to understood by all
  employees.
• Established goals and objectives for meeting
  the goals.
• VPP Commitment
• Management must clearly demonstrate commitment
  to meeting maintaining VPP requirements

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Criteria I Management Leadership Employee
Involvement (contd)

• Planning
• Planning for safety health must be a part of
  the overall management planning process.
• Written Safety and Health Program
• Written program must include all 4 Criteria
  elements of the VPP.
• Federal Agencies must also meet requirements
  for 29 CFR 1960

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Criteria I Management Leadership Employee
Involvement (contd)

• Top Management Leadership Managers must provide
  visible leadership by
• Establishing clear lines of communication.
• Creating an environment that allows for
  reasonable employee access to
• top site management.
• Setting example of safe healthful behavior.
  
• Ensuring all workers, including contractors,
  are provided equally high
• quality safety health protection.
• Clearly defining responsibilities in writing.

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Criteria I Management Leadership Employee
Involvement (contd)

• Authority and Resources
• Commensurate authority must be given to those
  with safety health responsibilities.
• Site must ensure adequate resources to those
  with responsibility authority.
• Line Accountability
• Must hold managers, supervisors,
  non-supervisory employees
• accountable through a documented
  system.

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Criteria I Management Leadership Employee
Involvement (contd)

• Contract Worker Coverage
• All contractors and subcontractors, whether in
  general industry, construction, maritime, or
  federal agency sites, must follow worksite
  safety and health rules and procedures applicable
  to their activities while at the site.
• VPP Sites are expected to encourage
  contractors to develop effective safety and
  health program management systems.
• VPP site contractor programs must
  include a documented oversight and management
  system that ensures the contractors site
  employees are provided effective protection.

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Criteria I Management Leadership Employee
Involvement (contd)

• Employee Involvement
• The site culture must enable encourage
  effective employee involvement in the planning
  operation of the safety health programs, in
  decisions that affect employees safety
  health.
• In accordance with the FRN, there must
  be a minimum of three ways employees can be
  involved in addition to notifying management of
  unsafe conditions.

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Criteria I Management Leadership Employee
Involvement (contd)

• Safety Health Program Evaluation (the Annual
  self-assessment)
• The site must have a system for annually
  evaluating the operation of the safety
  health program.
• The system will judge the sites success
  in meeting the programs goals objectives
  assist those responsible for determining
  implementing changes for continually improving
  worker safety health protection.

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Criteria I Management Leadership Employee
Involvement (contd)

• The annual evaluation system must include
• A written, narrative report.
• Recommendations included for improvements.
• Assignment of responsibility.
• Documented timely follow-up.
• OSHA recommends it should follow the Suggested
  Format for Annual Submissions Appendix D of the
  VPP Policies and Procedures Manual, published by
  OSHA and found on OSHAs webpage www.osha.gov
  -scroll down to VPP.
• In VPP construction, an additional program
  evaluation must be conducted prior to completion
  of job.

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Criteria II Worksite Analysis

• Management Understanding
• Baseline Industrial Hygiene evaluations
• Pre-use Analysis
• Hazard Analysis
• Routine Inspections
• Employee Hazard Reporting System

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Criteria II Worksite Analysis (contd)

• Accident/Incident Investigations
• Trend Analysis
• DART
• 
  ( Severity Rate)

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Criteria II Worksite Analysis (contd)

• Management Understanding
• Management of safety and health programs must
  begin with a thorough understanding of all
  hazards and unsafe conditions/behaviors to which
  employees may be exposed, and the ability to
  recognize and correct all hazards as they arise.
• Industrial Hygiene
• Program must include a site wide, baseline
  identification of health hazards and employee
  exposure through an industrial hygiene sampling
  rationale and strategy.
• All sampling, testing, and analysis should be
  conducted using nationally recognized procedures
  and protocols, with maintenance of documented
  results.

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Criteria II Worksite Analysis (contd)

• Pre-Use Analysis
• All newly acquired or altered facilities,
  processes, materials, equipment, and/or phases
  must be analyzed before use begins to identify
  hazards and the means for their prevention and
  control.
• Hazard Analysis
• The site must perform routine examination and
  analysis of safety and health hazards associated
  with individual jobs, processes, or phases.
• May Include JSAs, JHAs, PHRs, etc.
• The results must be included in training and
  hazard control programs.

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Criteria II Worksite Analysis (contd)

• Routine Inspections (self-audits)
• The site must have a system for conducting
  routine self-inspections, preferably involving
  employees.
• System must include written procedures/guidance,
  and must result in written reports of findings
  and tracking of hazard elimination or control to
  completion.
• In general industry, federal agencies and
  maritime, these inspections must occur at least
  monthly and cover the whole worksite at least
  quarterly.
• In construction, these inspections must cover the
  entire worksite at least weekly.

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Criteria II Worksite Analysis (contd)

• Employee Hazard Reporting System
• The site must have a written, workable system
  employees may use to notify management of unsafe
  conditions, behaviors, safety and any health
  related issues, questions, observations.
• System must include timely and appropriate
  responses, and be free of discrimination or
  retribution.
• The system must include tracking of responses and
  tracking of hazard elimination or control to
  completion.

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Criteria II Worksite Analysis (contd)

• Employee Hazard Reporting System (contd)
• The system should also have a component which
  allows employees to make anonymous reports of
  conditions appearing hazardous.
• The system should allow for responding to
  anonymous reports using employee bulletin boards,
  newsletters, etc.

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Criteria II Worksite Analysis (contd)

• Accident/Incident Investigation System
• The system must
• Include written procedures/guidance.
• Include written reports of findings.
• Include hazard elimination or control tracking
  to completion.
• Procedures should also be included for
  investigation of near misses.
• The investigations should seek out
  root causes for the accident/incident, fix the
  cause, not the blame.

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Criteria II Worksite Analysis (contd)

• Trend Analysis
• The program must include analysis of data and
  information for trending and pattern analysis.
• Information that might be used in trending
  includes, injury/illness history, hazards
  identified during inspections, employee reports
  of hazards, accident/near miss investigations,
  body parts, departments, business cycles, etc.

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Criteria III Hazard Prevention and Control

• Certified professionals as a resource
• Hazard Elimination and Control including
• Engineering Controls
• Administrative Controls
• Safety and Health Rules
• Hazard Control Programs
• Personal Protective Equipment (PPE)

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Criteria III Hazard Prevention and Control
(contd)

• Process Safety Management
• Occupational Health Care Program
• Preventive Maintenance
• Hazard Correction Tracking
• Disciplinary System
• Emergency Preparedness

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Criteria III Hazard Prevention and Control
(contd)

• Hazard Controls
• Site hazards identified during and through the
  hazard analysis process must be eliminated or
  controlled by developing and implementing the
  systems discussed in this section. The Hierarchy
  of Controls.
• The hazard control methods a site chooses to
  implement must be understood and followed by
  affected parties, and appropriate to the hazard
  and size of the worksite.

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Criteria III Hazard Prevention and Control
(contd)

• Certified Professional Resources
• The site must have adequate access to certified
  safety professionals (CSP), certified industrial
  hygienists (CIH), other certified professionals.
• Hazard Elimination or Control
• The following hierarchy should be used in
  selecting actions to eliminate or control
  hazards

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Criteria III Hazard Prevention and Control
(contd)

• Engineering Controls - Most reliable and
  effective, best practices.
• Administrative Controls - Significantly limit
  daily exposure to hazards by controlling or
  manipulating the work schedule or manner in which
  work is performed, e.g., job rotation, change
  shift duration, etc.
• Work Practice Controls - Includes workplace
  rules, safe and healthful work practices, and
  procedures for specific operations.
• Personal Protective Equipment
• Hazard Control Programs - Includes, but is not
  limited to, control of hazardous energy (lock
  out/tag out), confined space entry, hazard
  communication, respiratory protection, hearing
  conservation, blood borne pathogens, fall
  protection, etc.

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Criteria III Hazard Prevention and Control
(contd)

• Process Safety Management- as applicable
• For sites meeting the threshold requirements for
  coverage outlined in 29 CFR 1910.119, appendix A,
  of OSHAs Process Safety Management Standard.
• Preventive Maintenance System
• System must be written, and document the
  monitoring and maintenance of workplace equipment
  such as
• Preventive and predictive maintenance, to prevent
  equipment from becoming hazardous.

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Criteria III Hazard Prevention and Control
(contd)

• Hazard Correction Tracking
• The site must have a formal system for initiating
  and tracking hazard identified through the
  various safety and health programs, in a timely
  manner.
• Occupational Health Care Program
• The program must include Licensed health care
  professionals to assess employee health status
  for prevention of and early recognition and
  treatment of injury and illness. This in
  conjunction with the IH program, Health care
  professionals should be involved with site
  self-audits and inspections.

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Criteria III Hazard Prevention and Control
(contd)

• Occupational Health Care Program (contd)
• Access to certified first aid and CPR providers
  on all shifts,
• Access to physician care, and emergency medical
  care.
• Disciplinary System
• Must be written and must be clearly communicated
  and equitably enforced.

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Criteria III Hazard Prevention and Control
(contd)

• Disciplinary System (contd)
• Include procedures for disciplinary action or
  reorientation of
• Managers, supervisors, non-supervisory employees
  who
• Break or disregard safety and health rules,
  safety work practices, proper material handling,
  or emergency procedures. Must be documented.

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Criteria III Hazard Prevention and Control
(contd)

• Emergency Response Program and Procedures
• Emergency procedures must be developed for all
  shifts worked.
• Must be written and communicated to all,
  including outside contractor and temporary
  employees.
• Must list requirements for PPE, first aid,
  medical care, emergency egress.
• Must include provisions for emergency telephone
  numbers, exit routes.
• Must include training drills including, at a
  minimum, annual evacuation drills.

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Criteria IV Safety and Health Training

• Emergency Procedures
• Supervisors/Managers
• Employees
• Emergencies
• PPE

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Criteria IV Safety and Health Training (contd)

• Managers and Supervisors
• Understand their safety and health
  responsibilities as discussed in Criteria I
  Management Leadership and Employee Involvement,
  and are able to carry them out effectively.
• Managers, Supervisors, and non-supervisory
• employees including contractors
• Are made aware of and taught how to recognize
  hazards, unsafe conditions, and the signs and
  symptoms of workplace-related illness.

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Criteria IV Safety and Health Training (contd)

• Managers, Supervisors, and non-Supervisory
  employees including contractors
• Must learn safe work procedures to follow in
  order to protect themselves from hazards.
• Training includes reinforcement and includes
  reviews of procedures to notify supervision of
  hazards.
• Emergencies
• Managers, Supervisors, and non-supervisory
  employees including contractors, and Visitors
  must understand what to do in emergency
  situations.

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Criteria IV Safety and Health Training (contd)

• Personal Protective Equipment
• Where PPE is required, employees understand that
  it IS required, why it is required, its
  limitations, how to use it, and how to maintain
  it.
• Managers, supervision, employees, outside
  contractors, and visitors use PPE properly.

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The End and the Beginning

• 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