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U.S. Department of Labor | |
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| Occupational Safety & Health Administration | ||||||
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 Recognizing Excellence in Safety and Health Are you ready for VPP? Do you have what it takes to be one of the best? Are you prepared to adopt a comprehensive, rigorous safety and health management system that you tailor to your worksite's specific needs? Are you willing to try a cooperative, action-oriented approach where managers, employees, and OSHA work together to combat workplace hazards and reduce injuries and illnesses? Do you want to be recognized for your commitment to worker safety and health? If the answer is yes, then maybe you are ready for OSHA's Voluntary Protection Programs. VPP is open to private sector and federal agency worksites in most industries where OSHA has jurisdiction.
The Voluntary Protection Programs Concept OSHA is not just a regulatory enforcement agency. OSHA also encourages private and public sector efforts to improve occupational safety and health. Through the Voluntary Protection Programs (VPP), OSHA recognizes workplaces with excellent safety and health management systems and promotes them as model workplaces. The Programs place significant reliance on the cooperation and trust inherent in partnership. To qualify for VPP, applicants must have in place an effective safety and health management system that meets rigorous performance-based criteria. In addition, all relevant OSHA standards must be met. OSHA verifies qualifications through a comprehensive onsite review process. OSHA approves successful applicants as Star, Merit, or Demonstration participants, with an exemption from programmed or scheduled inspections. Participation in VPP does not diminish the rights or responsibilities of employers or employees under the Occupational Safety and Health Act (OSH Act). Complaints, accidents, chemical spills, and other significant events will result in an OSHA enforcement inspection according to agency policies. Achieving VPP shows your employees, industry, and the community you are a leader in safety and health. As a model workplace, you demonstrate that a voluntary, cooperative, proactive safety and health partnership of management, labor, and a federal regulatory agency benefits all parties. OSHA invites you to go for VPP. By accepting the challenge, you can save lives, increase productivity, and improve the working environment of your organization. Become a leader! Gain the recognition you deserve for being among the Nation's best in worker safety and health. An Overview of VPP What is VPP? Working with industry and labor, OSHA created the Voluntary Protection Programs (VPP) in 1982 to recognize and partner with worksites that implement exemplary systems to manage worker safety and health. The managers, employees, and any authorized representatives at these sites voluntarily implement comprehensive safety and health programs — hereinafter referred to as safety and health management systems — that go beyond basic compliance with OSHA standards. Using one set of flexible, performance-based criteria, the VPP process emphasizes holding managers accountable for worker safety and health, the continual identification and elimination of hazards, and the active involvement of employees in their own protection. These criteria work for the full range of industries, union and non-union, and for employers large and small, private and public. The VPP places significant reliance on the cooperation and trust inherent in partnership. Sites choosing to apply for VPP recognition show their commitment to effective worker protection by inviting a government regulator into their workplace. In return, OSHA removes them from programmed inspection lists and does not issue them citations for standards violations that are promptly corrected. Sites qualifying for VPP attain Star, Merit, or Demonstration status. Star participants meet all VPP requirements. Merit participants have demonstrated the potential and willingness to achieve Star status, but some aspects of their programs need improvement. Demonstration participants test alternative ways to achieve safety and health excellence that may lead to changes in VPP criteria. Statistical evidence for VPP's success is impressive. Consistently over its 20-year history, the average VPP worksite has had an incidence rate for days away from work, restricted work activity, and/or job transfer that is at least 50 percent below the average for its industry! In VPP,
There is some paperwork required in the application process, but we encourage you to use as much existing material as possible. Most worksites have found that, in the process of applying, they gain a greater understanding of worker protection and discover ways to improve their safety and health management system. VPP reviewers don't look for a single correct way to meet VPP requirements. They want to see a system that works for you. Some successful safety and health management systems involve substantial written documentation, and others do not. Small businesses, in particular, often are able to implement excellent safety and health processes with relatively little documentation. Will my program qualify? We have included a Self-Assessment Checklist in this packet. Use this checklist to see if your safety and health management system meets the VPP criteria and to identify and correct any deficiencies or weaknesses that need your attention. Discussing your qualifications with your Regional VPP Manager is also recommended. How do I apply? We have included Application Instructions in this packet. We encourage you to involve employees and managers in completing your application. After OSHA reviews and accepts your written submission, we will schedule an onsite review. The enclosed booklet—"What Happens During a VPP Onsite Review?"—describes this process. If you are in a state that operates its own OSHA-approved program, check with your state agency to learn specifics regarding its VPP application process. Where can I get more information? You can contact your nearest OSHA VPP Manager through OSHA's regional and area offices. If your worksite is under state jurisdiction, contact the office that administers your state program. For agency regional and area office locations, state contacts, and more about VPP, log onto OSHA's website, www.osha.gov. Your Regional VPP Manager or the VPP Participants' Association (VPPPA) (703-761-1146) also can refer you to VPP worksites in your area. We encourage you to contact participating sites. They are happy to share their experience. VPP Benefits Who benefits from VPP? The foremost beneficiaries of OSHA's VPP are the workers who, at day's end, arrive home safe and healthy to families who needn't fear the tragedy of worker death, injury, and illness.
Stephen Brown Union Safety Representative PACE Local #712 Potlach, Consumer Products Division Lewiston, ID Why pursue VPP? The VPP process of managing safety and health systematically—using one set of flexible, performance-based criteria—is working in workplaces large and small. VPP has been effective in various industries— from construction to poultry processing to petrochemical plants, from tree nurseries to nursing homes, and from mom-and-pop operations to federal laboratories. It works in union and non-union shops. More than 180 distinct industrial classifications are represented, and the number is growing. VPP has proven more successful in reducing work-related injuries and illnesses than mere compliance with specific regulations. "For those of you who have not yet joined the ranks of VPP, I'd like to take this opportunity to encourage you to do so. Not often do you get a chance like this to forge a new relationship with a regulatory agency based on trust and cooperation. This is a powerful partnership with all long-lasting results. It's also a tremendous responsibility, yet a smart one, that will pay your business back." Rich Guimond Vice-President and Corporate Director of Environment, Health and Safety Motorola Schaumburg, IL Why partner with OSHA? VPP demonstrates that management, labor, and government can work together successfully as partners in excellence. Very few worksites opt out of VPP, despite continuing high performance requirements that OSHA verifies in comprehensive, periodic onsite reviews at every VPP site. Clearly, participants are pleased with the VPP experience and with the outstanding worker protection they voluntarily achieve year after year. "I've been involved with this program since making our application in 1996. You can spend all the money you want on the variety of programs available designed to improve EHS performance, and I've looked at them all. For my money, and it isn't that much when compared to the other programs, I believe you get your best bang for the buck with VPP." Hans Hoefgen, MS, CSHM EHS Group Coordinator Moore North America, Inc. Albany, NY Does VPP really work? The evidence of VPP's success is impressive. Recent data show VPP worksite injuries and illnesses that keep employees away from work or necessitate their restricted work activity or job transfer are dramatically below industry experience. As a result, VPP worksites have saved more than a BILLION dollars since the program began in 1982. In addition, many VPP participants report workplace improvements such as lower turnover rates, reduced absenteeism, and improved employee morale. "Voluntary Protection Programs work for everyone. We at Samaritan Regional Health System are proof of that. All of us at Samaritan are extremely proud of this outstanding achievement. We strive to be leaders in health and safety in the health care community. It is our goal to lead other health care facilities into this worthwhile program through outreach and mentoring programs we have implemented. VPP works, as evidenced by our lost-workday injury rate in 1999, which was 0.2. As a result, our workers' compensation costs decreased dramatically, adding directly back to the bottom line." Connee Cantrill Director, Environmental Service and Safety Samaritan Regional Health System Ashland, OH VPP Self-Assessment Checklist The items listed below will help you gauge your eligibility for the VPP. Check each item you currently have or are willing to implement. This self assessment should give you a good idea of what you may need to do to improve your safety and health program — hereinafter referred to as a safety and health management system — and qualify for VPP. Call the VPP Manager in your OSHA Regional Office if you have questions about VPP requirements or the application process. Even if you don't have questions, it's a good idea to let the VPP Manager know you are considering applying. A listing of OSHA offices is online at www.osha.gov. Rates
* "DART rate" is the successor term OSHA has adopted to replace Lost Workday Injury (LWDI) rate and Lost Workday Injury and Illness (LWDII) rate. It will also replace DARCIR, which was briefly used within VPP and had the same meaning as LWDII. ** When BLS changes from the Standard Industrial Classification (SIC) system to the North American Industry Classification System (NAICS) and begins publishing data under the new system, VPP applicant/participant site rates will be compared with the rates generated under NAICS.
What Happens When OSHA Comes Onsite for VPP? Why does OSHA need to come to my site? OSHA must verify that the safety and health management system described in your VPP application is fully operational and effectively addresses the hazards at your site. Who comes on a VPP onsite review? The OSHA review team usually consists of a team leader, a safety specialist, an industrial hygienist, and often a backup team leader. At larger sites or sites with more complex processes, the team may include additional personnel. Most team members are OSHA employees. Many teams also include a qualified employee from a VPP participating site. All of these team members are acting in a non-enforcement mode and understand that your site, as an applicant to the VPP, is committed to implementing an outstanding safety and health management system. When will OSHA come? An OSHA VPP representative will call you to arrange a mutually convenient time. How long will OSHA stay? Usually about 4 days, depending on the size of your facility and complexity of your operations. Must I wait until the review ends to learn if the team will recommend approval? Yes. At the end of each day, however, the team members will discuss the day's findings with your site representatives. The team also will answer questions and detail next steps in the approval process. The OSHA team will base its final recommendation regarding approval on its comprehensive assessment of your operations in relation to the VPP requirements. To do this, the team must gather all needed information and complete its review. The Assistant Secretary for OSHA makes the final approval. What will the team do onsite? The OSHA team will perform a review that includes several steps:
What happens at the initial meeting? The team will hold a brief introductory meeting with you, your management staff, and other employees who play key roles in your safety and health efforts. Anyone who may be expected to explain aspects of your safety and health management system should attend. You may want to introduce key staff and provide a brief overview of your site and its safety and health management system. A site tour for the OSHA review team may follow the initial meeting. What is a walkthrough? The OSHA review team will walk through pertinent areas of your facility to verify you have controlled hazards appropriately and implemented a comprehensive safety and health management system successfully. There will be an initial primary tour and usually follow-up tours by individual team members. The team must see enough to understand the hazards that exist and to determine that these hazards are being addressed systematically by your safety and health management system. Any work performed by contract employees is also included in the walkthrough. The team will have brief, informal interviews with site and contractor employees as they tour the facility. The informal talks are held close to where employees work to minimize any work interruption. Questions will typically address work procedures, emergency procedures, and personal protective equipment. What is the document review? The OSHA team will examine records to verify implementation of your safety and health management system. Collecting and organizing these materials beforehand will greatly facilitate the review. The team will need a private area such as a conference room to review the documents. Prior to the onsite visit, the team leader will confer with you about the materials the team will want to see. Documents and programs typically requested during a VPP review include:
The walkthrough is not an enforcement process. The OSHA review team will work with you to determine how and when to correct any hazards they see. If you cannot complete corrections while the team is onsite, you will have up to 90 days to correct the hazards and provide documentation of your corrections to the OSHA team leader. The team will not issue citations. Should all attempts at cooperative resolution fail, however, the team has a responsibility to recommend enforcement action to the OSHA Assistant Secretary. Why does OSHA need to talk to employees? Interviews with management will provide OSHA team members with information about your safety and health management system and the management oversight system. Employee interviews will help gauge the extent of employee awareness, their involvement in the safety and health management system, and their knowledge about any exposures to hazards. The team leader will randomly select employees from an employee roster, with the goal of interviewing a crosssection of hourly workers, supervisors, managers, and contractors in both operations and maintenance. Each formal interview takes place in a private setting and usually does not exceed 1/2 hour. All questions asked will relate to the safety and health management system. How does the team prepare its findings? 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:
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. What happens during the closing meeting? Before leaving, the OSHA review team and site representatives will meet to discuss team findings and recommendations. In most cases, the team will also provide its draft report. During this meeting, and before the report is sent to the Assistant Secretary, the team members will be receptive to any information from you that they may have overlooked or that will help make their findings or report more accurate. If the team recommends my worksite to the program, what happens next? The report goes to the Assistant Secretary for Occupational Safety and Health for approval. The Assistant Secretary sends a copy of the final report and a decision letter to your manager, or other appropriate company official, announcing OSHA's approval of your site for participation in the VPP. After approval, the regional VPP Manager will order a certificate and flag and will communicate with you about the best time to present them. What if I still have questions? You can contact your nearest OSHA VPP Manager through OSHA's regional and area offices. If your worksite is under state jurisdiction, contact the office that administers your state program. For agency regional and area office locations, state contacts, and more about VPP, go online at www.osha.gov. VPP Application Instructions A. General Information 1. Applicant Site Name Site Address Site Manager Title Site VPP Contact for OSHA correspondence Title Phone Number E-Mail Address 2. Company/Corporate Name Name (if different from above) Address VPP Contact (if applicable) Title Phone Number E-mail Address 3. Collective Bargaining Agent(s) (list information on each separately) Union Name and Local # Agent's Name Address Phone Number E-mail Address 4. Number of Employees and Contractor Employees Number of Employees working at Applicant's site Number of Temporary Employees supervised by Applicant Number of Applicable Contractor* Employees 5. Type of Work Performed and Products Produced Provide a comprehensive description of the work performed at your site, the type of products produced, and the type of hazards typically associated with your industry. 6. Applicant's Standard Industrial Classification (SIC) Code (3-4 digit number) Provide your site's SIC code. When the Bureau of Labor Statistics (BLS) changes from the SIC system to the North American Industry Classification System (NAICS) and begins publishing data under the new system, provide your site's NAICS code. 7. Recordable Nonfatal Injury and Illness Case Incidence Rates Complete and submit the tables at the end of this application (Section G), then
*An Applicable Contractor has employees working 1,000 or more hours in at least 1 calendar quarter at the Applicant's site. ** TCIR is the total case incidence rate for recordable nonfatal injuries and illnesses. The DART rate is the incidence rate for recordable injury and illness cases involving days away from work, restricted work activity, and/or job transfer.
B. Management Leadership and Employee Involvement Management Leadership 1. Commitment Attach a copy of your top level safety policy specific to your facility. Note: Management must clearly demonstrate commitment to meeting and maintaining the requirements of the VPP. 2. Organization Describe how your company's safety and health function fits into your overall management organization. Attach a copy of your organization chart. 3. Responsibility Describe how your line and staff are assigned safety and health responsibilities. Include examples of specific responsibilities. 4. Accountability Describe your accountability system used to hold managers, line supervisors, and employees responsible for safety and health. Examples are job performance evaluations, warning notices, and contract language. Describe system documentation. 5. Resources Identify the available safety and health resources. Describe the safety and health professional staff available, including appropriate use of certified safety professionals (CSP), certified industrial hygienists (CIH), other licensed health care professionals, and other experts as needed, based on the risks at your site. Identify any external resources (including corporate office and private consultants) used to help with your safety and health management system. 6. Goals and Planning Identify your annual plans that set specific safety and health goals and objectives. Describe how planning for safety and health fits into your overall management planning process. 7. Self-Evaluation Provide a copy of the most recent annual selfevaluation of your safety and health management system. Include assessments of the effectiveness of the VPP elements listed in these application guidelines, recommendations for improvement, assignment of responsibility, and documentation of action items completed. Describe how you prepare and use the self-evaluation. Employee Involvement 8. Three Ways List at least three meaningful ways employees are involved in your safety and health management system. Provide specific information about decision processes that employees impact, such as hazard assessment, inspections, safety and health training, and/or evaluation of the safety and health management system. 9. Employee Notification Describe how you notify employees about site participation in the VPP, their right to register a complaint with OSHA, and their right to obtain reports of inspections and accident investigations upon request. (Various methods may include new employee orientation; Intranet or e-mail, if all employees have access; bulletin boards; tool box talks; or group meetings.) 10. Contract Workers' Safety Describe the process used for selecting contractors to perform jobs at your site. Describe your system for ensuring that all contract workers who do work at your site are provided the same healthful working conditions and the same quality protection as your regular employees. 11. Site Map Attach a site map or general layout. C. Worksite Analysis 1. Baseline Hazard Analysis Describe the methods used for baseline hazard analysis to identify hazards associated with your specific work environment, for example, air contaminants, noise, or lead. Identify the safety and health professionals involved in the baseline assessment and subsequent needed surveys. Explain any sampling rationale and strategies for industrial hygiene surveys if required. 2. Hazard Analysis of Routine Jobs, Tasks, and Processes Describe the system used for examination and analysis of safety and health hazards associated with routine tasks, jobs, processes, and/or phases. Provide some sample analyses and any forms used. You should base priorities for hazard analysis on historical evidence, perceived risks, complexity, and the frequency of jobs/tasks completed at your worksite. In construction, the emphasis must be on special safety and health hazards of each craft and phase of work. 3. Hazard Analysis of Significant Changes Explain how, prior to activity or use, you analyze significant changes to identify uncontrolled hazards and the actions needed to eliminate or control these hazards. Significant changes may include nonroutine tasks and new processes, materials, equipment, and facilities. 4. Self-Inspections Describe your worksite safety and health routine general inspection procedures. Indicate who performs inspections, their training, and how you track any hazards through to elimination or control. For routine health inspections, summarize the testing and analysis procedures used and qualifications of personnel who conduct them. Include forms used for self-inspections. 5. Employee Reports of Hazards Describe how employees notify management of uncontrolled safety or health hazards. Explain procedures for follow-up and tracking corrections. An opportunity to use a written form to notify management about safety and health hazards must be part of your reporting system. 6. Accident and Incident Investigations Describe your written procedures for investigation of accidents, near-misses, first-aid cases, and other incidents. What training do investigators receive? How do you determine which accidents or incidents warrant investigation? Incidents should include first-aid and near-miss cases. Describe how results are used. 7. Pattern Analysis Describe the system you use for safety and health data analysis. Indicate how you collect and analyze data from all sources, including injuries, illnesses, near-misses, first-aid cases, work order forms, incident investigations, inspections, and self-audits. Describe how results are used. D. Hazard Prevention and Control 1. Engineering Controls Describe and provide examples of engineering controls you have implemented that either eliminated or limited hazards by reducing their severity, their likelihood of occurrence, or both. Engineering controls include, for example, reduction in pressure or amount of hazardous material, substitution of less hazardous material, reduction of noise produced, fail-safe design, leak before burst, fault tolerance/redundancy, and ergonomic design changes. Although not as reliable as true engineering controls, this category also includes protective safety devices such as guards, barriers, interlocks, grounding and bonding systems, and pressure relief valves to keep pressure within a safe limit. 2. Administrative Controls Describe ways you limit daily exposure to hazards by adjusting work schedules or work tasks, for example, job rotation. 3. Work Practice Controls Describe and provide examples of your work practice controls. These include, for example, workplace rules, safe and healthful work practices, specific programs to address OSHA standards, and procedures for specific operations. Identify major technical programs and regulations that pertain to your site, such as lockout/tagout, process safety management, hazard communication, machine guarding, and fall protection. 4. Personal Protective Equipment Describe and provide examples of required personal protective equipment your employees use. 5. Safety and Health Rules Describe your general safety and health rules. Demonstrate that there is a disciplinary system for equitably enforcing these rules for managers, supervisors, and employees. 6. Preventive/Predictive Maintenance Describe your written system for monitoring and maintaining workplace equipment to predict and prevent equipment breakdowns that may cause hazards. Provide a brief summary of the type of equipment covered. 7. Occupational Health Care Program Describe your on-site and off-site medical service and physician availability. Explain how you utilize the services of licensed occupational health care professionals. Indicate the coverage provided by employees trained in first aid, CPR, and other paramedical skills, their training, and available equipment. 8. Emergency Preparedness Describe your emergency planning and preparedness system. Provide information on emergency drills and training, including evacuations. E. Safety and Health Training Describe the formal and informal safety and health training provided for managers, supervisors, and employees. Identify training protocols, schedules, and information provided to supervisors and employees on programs such as hazard communication, personal protective equipment, and handling of emergency situations. Describe how you verify the effectiveness of the training given. F. Assurances VPP applications must include a signed statement affirming that 1. Compliance You will comply with the Occupational Safety and Health Act (OSH Act) and correct in a timely manner all hazards discovered through self-inspections, employee notification, accident investigations, OSHA onsite reviews, process hazard reviews, annual evaluations, or any other means. You will provide effective interim protection, as necessary. Federal applicants also agree to comply with Title 29 of the Code of Federal Regulations (CFR), Part 1960—Basic Program Elements for Federal Employees. 2. Correction of Deficiencies Within 90 days, you will correct safety and health deficiencies related to compliance with OSHA requirements and identified during any OSHA onsite review. 3. Employee Support Your employees support the VPP application. At sites with employees organized into one or more collective bargaining units, the authorized representative for each collective bargaining unit must either sign the application or submit a signed statement indicating that the collective bargaining agent(s) support VPP participation. OSHA must receive concurrence from all such authorized agents to accept the application. At non-union sites, management's assurance of employee support will be verified by the OSHA onsite review team during employee interviews. 4. VPP Elements VPP elements are in place, and management commits to meeting and maintaining the requirements of the elements and the overall VPP. 5. Orientation Employees, including newly hired employees and contract employees, will receive orientation on the VPP, including employee rights under VPP and under the OSH Act or 29 CFR 1960. 6. Non-Discrimination You will protect employees given safety and health duties as part of your safety and health management system from discriminatory actions resulting from their carrying out such duties, just as Section 11(c) of the OSH Act and 29 CFR 1960.46(a) protect employees who exercise their rights. 7. Employee Access Employees will have access to the results of selfinspections, accident investigations, and other safety and health data upon request. At unionized construction sites, this requirement may be met through employee representative access to these results. 8. Documentation You will maintain your safety and health management system information and make it available for OSHA review to determine initial and continued approval to the VPP. This information will include:
Each year by February 15, you will submit the following information to your designated OSHA Regional VPP Manager:
Whenever significant organizational or ownership changes occur, you will provide OSHA within 60 days a new Statement of Commitment signed by both management and any authorized collective bargaining agents. 11. Collective Bargaining Changes Whenever a change occurs in the authorized collective bargaining agent, you will provide OSHA within 60 days a new signed statement indicating that the new representative supports VPP participation. G. Rate Calculations and Tables Follow these steps to complete the two tables below. Submit with your application. You must fill out and submit a Table 2 for each applicable contractor (see step 9).
Table 1. Site Employee Recordable Nonfatal Injury and Illness Case Incidence Rates
Table 2. Site Applicable Contractors Recordable Nonfatal Injury and Illness Case Incidence Rates
Note: Applicable contractor rates do not have to be submitted with your application, but must be maintained at the site for review by the OSHA VPP Team. |
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