This publication does not itself alter or determine compliance responsibilities, which are set forth in OSHA standards themselves, and the Occupational Safety and Health Act. Moreover, because interpretations and enforcement policy may change over time, for additional guidance on OSHA compliance requirements, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the courts. Material contained in this publication is in the public domain and may be reproduced, fully or partially, without the permission of the Federal Government. Source credit is requested but not required. This information will be made available to sensory impaired individuals upon request. Voice phone: (202) 219-7266; Telecommunications Device for the Deaf (TDD) referral phone: 1-800-326-2577.

You’ve Been Selected to Be a VPP Onsite Team Member! Now What? U.S. Department of Labor Occupational Safety and Health Administration 1997

• voluntary workplace safety and health excellence, and
• cooperation among industry, labor, and government.

• Verification. Ascertain the accuracy of the information supplied in the application.
• Program Assessment. Identify both the strengths and weaknesses of the site’s safety and health program as currently implemented.
• Recommendation. Compile data for the Assistant Secretary of Labor to make an approval decision.

• Program Assessment. Determine that the program continues to provide effective safety and health protection to employees.
• Goal Progress (for Merit and 1-year conditional evaluations). Determine the progress toward reaching Merit goals or 1-year conditional goals.
• Program Effectiveness (for Demonstration evaluations). Determine the effectiveness of alternative requirements being tested.
• Recommendation. Compile for the Assistant Secretary of Labor or the Regional Administrator, as appropriate, information necessary to make a decision to continue the site in its current program or advance the site to the Star program.

• If the site has met all its Merit goals, and if the site’s performance remains strong with regard to the other requirements for Star, the team may recommend that the Assistant Secretary of Labor approve the site as a Star site.
• If the site is making good progress toward meeting its Merit goals, but if time remains in the approved Merit period, the team may recommend continuation as a Merit site. This recommendation is made to the OSHA Regional Administrator, who has the authority for approval.
• If the site is not making good progress toward meeting its Merit goals, and if the time in the approved Merit period has elapsed, the team may recommend to the Regional Administrator that the site discontinue participation in the VPP.
• If the site has not completed its Merit goals and the approved period for Merit has expired, but the site has made a consistent and good effort to meet the goals and has had its performance affected by significant change, such as a change in plant manager, the team may recommend that the Regional Administrator extend the Merit period.

• If the site continues to meet all the requirements for Star, the VPP onsite review team may recommend that the Regional Administrator approve continuation of the Star program. The Director of the Directorate of Federal-State Operations in the national office should be informed of the approval, and the Assistant Secretary of Labor will send a letter to the plant manager indicating his knowledge of the approval.
• If the site has a good program in place, but one or two of the program elements has slipped slightly in quality, the VPP onsite review team may recommend to the Regional Administrator a 1-year conditional approval, with specified goals to meet within that 1 year. When the team reviews the site at the end of that year, if it recommends to the Regional Administrator a return to full Star status, that date of approval is considered the site’s first year in Star for purposes of future evaluation.
• If the site has slipped so far from Star quality that the team judges the site’s commitment to safety and health excellence to be insufficient, the team may recommend to the Regional Administrator that the site withdraw from the VPP.

• If the team determines that the alternatives require futher testing, it recommends approval for continuation in the Demonstration Program.
• If the team determines that the alternatives provide effective protection, it recommends that the Star program requirements be changed to permit inclusion of the alternative requirements.
• If the team determines that the alternatives are creating ineffective protection, it recommends that the Demonstration be ended and the worksite withdraw from the Demonstration program.

• A team leader (OSHA)
• A safety professional (OSHA or SGE), and
• An industrial hygienist (OSHA or SGE).

• Other safety and health professionals, such as a PSM specialist (OSHA or SGE), and
• A back-up team leader (OSHA).

• Be thoroughly familiar with the site’s application;
• Provide pertinent information, including sections of the application, to team members;
• Coordinate the timing and duration of the review with team members and site management; and
• Determine what personal protective equipment (PPE) team members should bring and what PPE will be provided by the site.

• Review of injury log and recalculation of rates,
• Review of the written safety and health program and supporting documentation,
• Site walkthrough and informal employee interviews,
• Formal interviews, and
• Draft preparation of the review report.

• OSHA 200 injury/illness logs for the past 3 full calendar years and year-to-date, with supporting documents such as workers’ compensation first reports of injuries, first-aid logs, and employee medical records. In advance of the onsite visit, the team leader will provide the site with a medical access order. The employer must post this order in an obvious place. The team will review site logs and site logs for the contractors whose employees have worked on the site at least 500 hours a quarter.
• Baseline surveys for safety and health hazards, including all industrial hygiene sampling records and material safety data sheets (MSDSs).
• Evidence of line accountability, such as performance evaluations and bonus systems.
• Hazard analyses, such as change analyses, process hazard reviews, job hazard analyses, and phase hazard analyses.
• Employee reports of safety and health hazards and suggestions, including documented responses.
• Reports of site inspections and accident investigations, including documented responses.
• Preventive maintenance records.
• Emergency procedures, including critiques of drills and documented responses to recommendations for improvement.
• All specialized programs required for complilance with OSHA regulations, such as lockout/tagout, confined spaces, and bloodborne pathogens, to name a few.
• Safety Committee mminutes, if applicable, and/or records of other methods of elmployee involvement.
• Training records, including types of training given, how curriculum is developed and reviewed, how understanding of training is assessed, and how an individual employee’s training is documented.
• The annual evaluation of the site’s safety and health program, including documented responses to the evaluation’s suggestions for improvement.

• Follow the entire process/operation flow, where possible;
• Suggest revisions to the corresponding safety and health management system documents (e.g., emergency planning, self-assessment procedures and reports, and employee complaints or reports of hazards) where work procedure improvements are needed; and
• Note specific hazards needing correction and discuss a time frame for correction.

• Follow the entire process/operation flow, where possible;
• Check known hazard areas, where applicable (e.g., ventilation, storage, handling and use of toxic materials, emergency equipment, respirator use and maintenance, and radiation and noise protective measures), based on review of monitoring records and material safety data sheets. Look for possible problems in work practices;
• Look for evidence that these hazards are appropriately managed and that no other hazards have escaped management’s attention; and
• Suggest program revisions to the corresponding safety and health management system documents where improvements are needed (e.g., safe work practices and training, respirator program, industrial hygiene sampling and analysis, and hazard communication systems).

• During the tour, team members will interview randomly selected employees at their work stations. Interviewers should include supervisors, maintenance personnel, safety committee members, and contract and temporary employees.
• Typical questions should address work procedures, emergency procedures, and PPE.
• Interviews should be conducted in a manner that avoids disruption of normal operations.
• Interviews are to be conducted in a confidential manner that encourages employees to speak freely.
• Contractor employees should be included in the informal interviews to ensure that equally effective protection is provided to all employees involved in the contractor’s operations.

• Items that cannot be corrected immediately will be described along with proper correction. This list, referred to as the “90-Day Items,” will be attached to the draft report given to the site management.
• The draft report of the team’s findings will not be prepared for the Assistant Secretary’s signature until the regional VPP manager has received assurances in writing that all 90-day items have been corrected.

• If the team decides that the site is eligible for Merit, the team then must agree on the Merit goals (the programmatic improvements the site must make), the evidence the site must produce to show that the goals have been met, and the amount of time the site will be allotted to make these improvements, usually from 2 to 4 years.
• If the team decides that the site is eligible for Star, the team will write the report recommending Star approval. This report will stress the particularly impressive aspects of the site’s safety and health program. Important considerations include whether
  • A Star site has few 90-day items to correct,
  • All safety and health program elements and subelements have been in place and operating effectively for at least 1 year, and
  • Injury incidence and lost-workday case rates are at or below the most recently published industry average.

• The team leader is responsible for preparing a report following the format prescribed in TED 8.1a, VPP Policies and Procedures Manual,* Appendix F or H, as appropriate. He or she may assign other team members to prepare sections of the report.
• The draft report will be written before the team leaves the site, whenever possible.
• Each team member will review the draft report, which will reflect the team’s consensus on the applicant’s qualifications for approval.