BACKGROUND
The Assistant Secretary of Labor for Occupational Safety and Health has
challenged the Occupational Safety and Health Administration (OSHA) to
significantly expand participation in OSHA’s Voluntary Protection Program (VPP).
To meet this challenge, the agency is considering new ways to increase VPP
membership, including a streamlined process for multiple sites within a
corporation to apply for and gain VPP recognition. OSHA’s Directorate of
Cooperative and State Programs (DCSP) has had informal discussions on the
concept with Regional VPP managers and well-known corporations. Several
corporations – including Johnson and Johnson, DuPont, Dow, and GE – have
communicated to OSHA their desire to further explore streamlined processes.
This paper describes the proposed Corporate VPP participation, based on ideas
from OSHA field staff and representatives of large corporations.
OBJECTIVE
OSHA’s objective is to establish an elite category of VPP participation for world-class
corporations that make a top-level commitment to reducing injuries and
illnesses through meaningful corporate-wide safety and health programs. This
new category of participation will be challenging but, at the same time, will
provide maximum support to corporations through streamlined application and
onsite evaluation processes for their sites.
BENEFITS
Corporate VPP will result in benefits to corporations, their employees, and OSHA:
| CORPORATIONS |
EMPLOYEES |
OSHA |
- Conserves corporate
resources by eliminating
redundancy in preparing
applications for multiple
sites in the same
corporation
- Conserves corporate
resources through a
simplified onsite review
process for multiple sites
- Provides world class, elite
status
|
- Increases the number of corporate employees benefited by the adoption of best practices
throughout the corporation’s operations
|
- Conserves OSHA resources through streamlined application review processes, especially for
multiple sites
- Conserves OSHA resources through a streamlined onsite review processes, especially for
multiple sites
- Helps OSHA meet the Assistant Secretary’s challenge of significantly expanding VPP
participation by bringing in more corporate sites into the program
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ELIGIBILITY CRITERIA
Participation in Corporate VPP will be limited to corporations that make a top-level
commitment to reducing injuries and illnesses through the implementation
across the corporation of a comprehensive safety and health management system that achieves
exemplary occupational safety and health.
Corporations will be eligible if they demonstrate the following:
- Corporate commitment. The corporation has made a written top-level
commitment to reducing injuries and illnesses and achieving exemplary
occupational safety and health throughout its organization by actively
seeking VPP recognition for the corporation as well as its multiple facilities.
The corporation may develop its own commitment statement or adopt
the commitment statement to be developed by OSHA.
- Corporate philosophy and vision. The corporation has a written corporate
philosophy and vision for safety and health.
- Corporate goals and progress report. The corporation establishes annual
performance goals, develops a system to track its progress on these goals,
and prepares an annual corporate report that describes its progress in
meeting these goals.
- Significant corporate participation in VPP. [This section will be developed
after review of data regarding current VPP participants and the regional
pilots and, based on the data, to recommend the percentage of VPP
participation to be required of corporate participants and how
corporations can demonstrate progress in VPP participation. Such factors
as the number of sites and the number of employees in a corporation will
be taken into account. Update: group agreed on 9/30/03 to consider a
graduated approach. Update: group agreed on 10/2/03 to provide
general guidelines, but keep this flexible.
- Senior leadership commitment. The corporation’s senior leadership and
management demonstrate commitment to VPP through their actions and
are available for interview during OSHA’s corporate onsite review.
Examples of ways to demonstrate this commitment include the following:
- Policy statements, memos, and other forms of communication that
specify a corporate commitment to occupational safety and health
signed by a corporate executive or senior manager
- Oral and written statements recognizing the importance of safety and health
- Documents describing a performance management system that holds
senior leadership and management staff accountable for achieving
corporate safety and health goals (e.g., performance plans for
executives and senior managers that include safety and health
elements)
- Documents describing a system, supported by senior leadership and
management, to recognize and reward safety and health
achievements in the organization
- Documents to show adequate budget allocations for safety and
health programs throughout the corporation
- Documents or oral statements (e.g., an organizational chart, a
functional chart, statements in an interview during the onsite review
process) that demonstrate how significantly safety and health fit in the
organization
- Documentation or oral statements that demonstrate awareness of
hazards by executives and senior managers of the corporation
- Established pre-screening process. The corporation has an established
internal process for pre-screening its potential VPP sites, including a
process for reviewing site applications prior to submission and for
conducting a corporate VPP audit.
- Corporate safety and health programs. The corporation has written safety
and health programs that are consistently and uniformly implemented
throughout the corporation, including at each of its facilities. Some
examples we may look for include programs, processes, or systems
around:
- Goals and objectives
- Business integration of safety and health
- Accountability and performance appraisal
- Employee engagement
- Contractors
- Quantifiable measures
- Measurement processes
- Industrial hygiene
- Hazards analysis
- Risk identification and elimination
- Accident/Incident investigation
- Safety and health training protocols and tracking
- Audit/self-evaluation
- Process for evaluating progress
- Annual report on corporate progress
- Comparison of corporate performance with overall national performance
- Outreach and mentoring. The corporation actively mentors another
corporation, another company’s site, or a Federal agency. The
corporation may mentor an organization recommended by OSHA or itself
identify the organization it would like to mentor.
- Active participation in Safety and Health Community. The corporation
participates in the Safety and Health Community, such as by being
actively involved in business schools, the National Safety Council, or
Federal Safety and Health Councils.
- Renewal/recertification. OSHA will develop a process for renewal and
recertification of Corporate VPP recognition every ____ years.
CORPORATE APPLICATION AND ONSITE REVIEW PROCESSES
A corporation that seeks Corporate VPP participation will be required to submit
a corporate VPP application and participate in a corporate onsite review.
- Corporate VPP application. The Corporate VPP application will be
prepared following these guidelines:
- The corporate applicant will submit a corporate application that
includes all VPP elements and describes corporate-wide safety and
health policies that are consistently and uniformly implemented at all
of the corporation’s facilities.
- To make the process easier for corporate applicants, OSHA will
develop a “model application,” template which applicants can use as
an example to follow.
- OSHA will conduct priority review of all corporate VPP applications.
- Corporate onsite review. OSHA will expedite the scheduling of onsite
reviews for Corporate VPP applicants. The corporate onsite review of one
to two days will cover the following:
- Interviews with the CEO and other senior leadership and management
staff to verify top-level corporate commitment to safety and health
(Note: This interview may be waived for corporations with a long
history of VPP participation.)
- Interviews with safety and health staff to establish adequacy of
resources, integration of safety and health into the organization,
corporate philosophy and approach, and how safety and health staff
relate with other staff in the corporation
- Interviews with employees to verify employee involvement and
establish the adequacy of the safety and health culture
- OSHA to develop protocols for what corporate evaluation will look like.
APPLICATION AND ONSITE REVIEW PROCESSES FOR INDIVIDUAL CORPORATE SITES
Once accepted for Corporate VPP participation, a corporation may apply for
VPP recognition for its various facilities or may allow its facilities to directly apply
for VPP recognition, following these guidelines:
- VPP application for an individual facility of the corporation. The VPP
application for facilities belonging to a Corporate VPP participant will
follow these guidelines:
- To facilitate the preparation of VPP applications from the corporation’s
various facilities, a Corporate VPP participant will share its corporate
VPP application with its facilities. Each facility will develop a
streamlined VPP application.
- The application must cover all VPP elements, without duplicating the
documentation of policies, systems, programs, and procedures that
are corporate-wide in nature. However, the application must describe
how these policies, systems, programs, and procedures are actually
executed at the applicant facility’s site.
- OSHA will conduct an expedited review of all VPP applications from
the facilities of a Corporate VPP participant. To facilitate this review,
OSHA will share all approved Corporate VPP applications with OSHA
Regional and Area Offices.
- OSHA to develop a site application template.
- Onsite review for a corporate facility. OSHA will expedite the scheduling
of onsite reviews for facilities of Corporate VPP participants. The onsite
review of one to two days will be conducted following these guidelines:
- OSHA will conduct a full-scale onsite sampling for the first few
corporate facilities.
- Once OSHA is able to establish that the corporation’s safety and
health programs are consistently and uniformly implemented
(executed?) at the corporate facilities, the agency will conduct a
more abbreviated onsite review, with one or two surprise elements.
- OSHA to develop protocols for facility onsite evaluations.
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