OSHA’s Voluntary Protection
Programs and You
By
M. Chris Osment
In 1982, the Occupational Safety
and Health Administration (OSHA) unveiled its Voluntary
Protection Program, or VPP. The idea behind the VPP
approach is that organizations with a strong health
and safety program would enter into a partnership
with OSHA, gaining recognition for their exemplary
commitment to worker safety and enjoying some added
benefits thereof. While the VPP system has undergone
some minor changes in the past 20 years, it’s
still an excellent way for a company to reap extra
dividends on its safety investment.
There are three types or levels
of VPP certification: Star, Merit and Demonstration.
Star facilities are those that have met all of the
requirements of the VPP program. Such sites are given
a special flag bearing the VPP Star and a certificate
of achievement. This is the “standard”
level of VPP recognition; when a site is said to have
VPP status or to be an OSHA Star, the Star level is
being cited.
Merit sites are locations showing
promise and an above-average safety and health program/track
record, but are not quite ready for Star status. Many,
if not most, Merit-level facilities go on to earn
their Star.
Demonstration sites are model Star-level
sites that, in association with OSHA, try out alternate
ways to achieve safety and health excellence; in effect,
they are guinea pigs, shaping future VPP rules and
criteria.
The way the VPP system works is
simple: A company with a proven track record and commitment
to workplace safety applies to OSHA for an evaluation.
A team of three to five members comes to the facility
and investigates it for several days, touring the
location, poring over documents and interviewing employees.
Following this inspection, OSHA’s Assistant
Secretary makes a determination based on the team’s
findings.
While all this sounds relatively
simple, the reality is quite a bit more complicated.
The systems, programs, records and documentation your
organization must have in place are considerable.
So too is the level of employee commitment, from top
to bottom – during the evaluation, your firm’s
commitment to safety must by evident when speaking
to the CEO, the part-time janitor and everyone in
between. Given these demanding conditions, it might
not come as any great surprise that, as of September
2003, there were only 10 VPP-registered sites in SIC
32 (Stone, Clay and Glass Products).
The benefits of VPP
Considering the time, monetary
and material investment necessary to bring a facility
up to VPP standards, the prospect is often written
off as being an unattainable goal. Before you join
the “naysayer” club, however, consider
what you have to gain from having a VPP Star:
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Safety
savings. The safety
and health programs and injury/illness/lost workday
reductions necessitated by a VPP facility result
in tremendous direct and indirect monetary savings,
which in practice more than pay for the costs associated
with the safety programs/improvements involved.
And if your organization is already enjoying the
benefits to the bottom line afforded by a top-notch
safety program, you’re unlikely to require
a substantial additional investment in your safety
programs to bring them up to “VPP standards.”
-
Employee
benefits. Employees
of a VPP facility are more productive with fewer
absences and instances of tardiness than the industry
norm. This is due in part to the empowerment and
commitment employees feel. In addition, employees
are likely to see added fringe benefits such as
lower health insurance premiums, higher wages and
better benefits – all as a result of the company’s
bigger bottom line.
-
Marketing
advantages/bragging rights.
VPP status is universally recognized as a symbol
of excellence and reliability; the mileage your
marketing and PR departments can get out of an OSHA
Star are tremendous.
-
Freedom
from OSHA inspections.
VPP Star sites are exempt from OSHA planned/programmed
inspections – meaning that unless you have
a serious accident or alleged safety hazard (both
of which are uncommon in Star sites), you don’t
have to worry about OSHA showing up on your doorstep
unannounced.
Are you ready for VPP?
While VPP preparation has spawned
a cottage industry of safety professionals and firms
ready to assist interested parties attain certification,
such aid usually isn’t necessary. In fact, organizations
that are truly ready to apply for VPP status shouldn’t
need any outside assistance with their safety programs
or in putting their applications together.
On the other hand, companies interested
in exploring the prospect of attaining VPP certification
but aren’t sure where they sit on the “preparedness
scale” should perform an audit using OSHA’s
VPP Self-Assessment Checklist. This tool offers a
way of evaluating your company’s safety program,
policies and history – much like the OSHA VPP
assessment team would do. In addition to providing
an excellent roadmap for VPP preparedness, the checklist
can be used as a good gauge of your firm’s overall
safety and health program.
In a nutshell, here’s what
OSHA is looking for in a VPP candidate:
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Low
incident rates. Ideally,
your organization’s lost workday and injury/illness
rates should be below the industry average. Failing
that, you should have a comprehensive plan in place
that addresses your above-average rates with workable
solutions to reduce your rates.
-
Management
commitment. Your organization’s programs
and practices must show strong involvement on the
part of managers and supervisors, especially among
the “top brass.” Safety and health management
issues must be integrated with standard practices
(i.e., safety must be part of every process, not
an addition to every process). Clear safety and
health management goals should be defined and plans
for meeting these objectives laid out; all of this
must be communicated to the company’s employees.
-
Employee
involvement. Employees must be fully trained
and should demonstrate a commitment to safety and
health practices. They must be aware of safety concerns
and understand the consequences of failing to follow
safety and health requirements. Worker input should
help determine safety policies and practices.
-
Worksite
analysis. You should have a baseline hazard
analysis that highlights areas of importance from
a safety and health perspective. In particular,
any areas addressed by OSHA standards, fire and
safety codes, etc., should receive special attention.
Your analysis should identify all instances of the
various hazards as well as the control or coping
methods for dealing with these hazards. You should
also document tests and analyses of your hazards
to determine if circumstances or technologies have
changed such that you should alter your system accordingly.
Lastly, frequent inspections/self-checks of the
site and workers should be done on a regular basis.
In all cases, detailed records or logs should be
kept detailing actions taken or considered.
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Training
and control. In addition to the safety training
all employees receive, supervisors and trainers
should receive refresher training or training in
new/enhanced techniques as necessary. Some method
of assessing the effectiveness of training must
be in place; it isn’t enough that an employee
sits through a training session – he/she must
have “gotten the message.” Records of
all training received/performed and subsequent assessments
must be maintained, and all employees should be
aware not only of safety rules and requirements
but also of the consequences (both health-related
and punitive) of failing to follow safety practices.
Of course, this is a highly condensed
version of the assessment checklist. Whether your
organization is considering pursuing VPP certification
or not, you should see how your company stacks up
against the full checklist (available from your local
OSHA/ Department of Labor office or from the OSHA
Web site – see Resources at the end of this
article).
The assessment
Your programs are in place,
your people are trained and committed, you’ve
gone a full year without a lost workday, and you’re
ready to try for your flag. Here’s how the evaluation
process breaks down.
-
Setting
the time. You and
an OSHA VPP representative will set up a mutually
convenient time for your evaluation, which will
typically last for 4 days. At the end of each day,
the team will meet with your designated person or
persons (see below) to discuss, in general terms,
the day’s findings.
-
Preparing
for the visit. You
should designate a panel of employees to assist
the inspection team and to be available as needed.
This panel should represent a good cross-section
profile of your organization, and its members should
be able to deal with any issues concerning the evaluation
that may arise. In addition, you should set aside
a private work area for the inspection team where
they can make plans, discuss the evaluation and
conduct employee interviews.
-
The
evaluation team. OSHA
will send an evaluation team consisting of three
to five members, occasionally more. This team will
usually be composed of a team leader, a safety specialist
and an industrial hygienist; in some cases the team
leader will be assisted by a backup, and occasionally
an employee of another VPP site will accompany the
OSHA team members.
-
The
initial meeting. The
evaluation will begin with a meeting in which the
inspection team and your key personnel are introduced
to one another. At this time, you should give a
brief overview of your organization and your safety
and health program, and offer a brief tour of the
facility. You will want to be certain all key staff
members are introduced to the evaluation team so
the inspectors will know whom to ask for assistance.
-
The
walkthrough. The evaluation
team will conduct an inspection of all pertinent
areas of your facility to verify whether you have
properly identified and controlled all hazards.
There will be an initial walkthrough performed by
the team as a whole and subsequent targeted inspections
of various areas by individual members of the inspection
crew. During the walkthrough, brief informal interviews
of workers (both employees and contract labor) will
be conducted.
-
The
document review. The
team will evaluate all your written documents including
safety programs, policy and procedure manuals, accident/injury
reports, hazard analyses, employee reports/suggestions,
site inspections, safety meeting minutes and training
records. Basically, anything your organization has
done or will do that involves safety (and in the
eyes of the investigating team, almost everything
will!) should have written documentation supporting
it – and the team will want to evaluate those
documents.
-
Employee
interviews. In addition
to the short, informal interviews the inspection
team may have with your workers during the walkthroughs,
you can expect key personnel and a random sampling
of “line workers” to be given formal
interviews. The purpose of these interviews is to
determine whether or not your company’s “safety
ethic” goes more than skin deep – they
want to see that all your workers are practicing
what your policies are preaching. These interviews
run a half-hour or less, and all questions asked
will relate to your organization’s safety
and health program.
-
Closing
meeting. As noted
above, the team will conduct a brief meeting with
your designated personnel at the close of each day’s
inspection. In addition, after the team members
are through with their evaluation, they will prepare
a draft report and meet with you to discuss their
findings and recommendation. You will be given an
opportunity at this meeting to discuss any issues
you feel warrant clarification or additional scrutiny.
In essence, it’s your chance to bring up additional
information or evidence to offset any negative impressions
or findings the inspectors may have found.
-
The
determination. After
conducting the closing meeting with your personnel,
the inspection team members will draft a final report
along with their recommendations to the Assistant
Secretary for Occupational Safety and Health, who
is responsible for making the final determination.
The Assistant Secretary will forward a copy of the
final report to you, along with a decision letter
– your “bottom line,” pass-fail
answer.
Inspection fallout
Anytime you invite a regulatory
agency into your facility, a measure of danger accompanies
the visit. In the case of VPP evaluations, however,
the risk is fairly minimal.
First of all, any safety and health
deficiencies noted by the inspection team will be
brought to your attention, and you’ll be asked
to correct them. If you can correct the problem(s)
quickly (before the team leaves), the matter will
end there without counting against you. Otherwise,
you are given 90 days to correct any deficiencies
and will be asked to submit a detailed plan for addressing
the problem(s) as part of your evaluation. Only if
you fail to adequately address a serious safety/health
risk in the time allotted do you run the risk of any
punitive action by OSHA.
What happens next?
Your final determination letter
from the Assistant Secretary can take one of several
forms. You may be congratulated on your astoundingly
impressive performance and be awarded VPP Star status,
in which case a formal ceremony will be held in which
you are presented your flag and certificate—certainly
an excellent photo/public-relations opportunity.
Another possibility is being awarded
Merit status, which means OSHA recognizes the strides
your organization has made toward creating a top-notch
program and has a number of conditions or areas it
wants you to address before awarding you Star status.
While Merit status doesn’t carry all the prestige
of a VPP Star, it’s still quite an achievement
and allows plenty of bragging rights.
Then there’s a third outcome,
in which you are not awarded either Merit or Star
status. While this is certainly not what you’re
looking for, it’s the most likely response,
especially early on in your quest to achieve Star
status. Along with such a “rejection”
letter will come a laundry list of recommendations
for enhancing your safety program and, consequently,
your odds of achieving Star certification on a future
evaluation. Try to follow through on these suggestions
and keep in mind that it’s not uncommon for
firms to labor for years, literally, before getting
their Star.
While opening all your doors and
books to OSHA and challenging it to give your safety
program its best shot may seem akin to drawing a bulls-eye
on your chest, companies with a strong safety and
health program and track record may find the risk
worth taking. Attaining a VPP Star ranking means admittance
into a very select club, especially in our industry.
Such organizations cannot help but be models for their
peers to envy – or emulate. Remember, safety
shouldn’t be a trade secret: If you’ve
got it, share it!
Resources
Occupational
Safety & Health Administration Homepage
VPP
Homepage
Cooperative
Programs
Index
of VPP Publications
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