OSHA Voluntary Protection Programs

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OSHA Voluntary Protection Programs
OSHA Region III VPP
Mileposts Talking Points
December 2006
Peter Brown
Region III VPP Outreach Coordinator
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Introduction

• OSHA Voluntary Protection Programs represents one
  part of OSHAs effort to extend both private
  sector and federal worker protection beyond the
  minimum required by OSHA standards. In VPP
  management, labor and OSHA establish cooperative
  relationships at workplaces that have implemented
  a comprehensive safety and health management
  system. Approval into VPP is OSHAs official
  recognition of the outstanding efforts of
  employers and employees who have achieved
  exemplary worksite safety programs.
• This document is in the public domain and may be
  reproduced without permission. It establishes no
  new OSHA requirements.

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Introduction
In practice, VPP sets performance-based criteria
for a managed safety and health system, invites
sites to apply, and then assesses applicants
against these criteria. OSHAs verification
includes an application review and a rigorous
onsite evaluation by a team of OSHA and private
sector safety and health experts. Qualified
sites are approved to one of three programs
Star, Merit, and Mobile Workforce Demonstration
in Construction (recognition for worksites that
address unique safety and health challenges, such
as a mobile workforce or short term
construction). Once approved, VPP participant
sites are required conduct annual
self-assessments with self-recommendations for
program improvements. OSHA periodically
reevaluates (recertifies) all VPP participants.
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VPP Highlights

• What is the differences and similarities between
  OSHA Enforcement and OSHA Partnerships and
  Recognition programs? Choose your OSHA. How the
  safety and health goals are the same, yet the
  approaches and results may be very different.
• The Voluntary Protection Programs four Criteria
  and their related Elements, in plain talk. What
  they are, what OSHA needs to see happening, and
  who should be involved? What do these elements
  look like in real life in big sites, and in small
  sites?
• There are many look- a-like approaches to EHS
  Management Systems, such as OHSAS 18001, British
  Standard 8800, AIHA ANSI Z10, NSC's Campbell
  Award and the ILO-OSH 2001, to mention a few

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VPP Highlights (contd)

• However, in VPPs spotlight is on employee
  ownership and involvement, a very big
  difference, and if you think of it, another
  difference is VPP is free.
• Coast to coast, overseas, -in all communities,
  OSHA VPP participants represent the best of the
  best. They share a commonwealth of technical
  support and networking opportunities.
• Since 1982, VPP has been recognizing government,
  labor and management partnerships. Yes, VPP is
  about the best companies and their employees, but
  its also about working together to meet the
  greatest EHS challenges of our Industrial Legacy.
  

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VPP Eligibility

• Who can be in the VPP?
• Implementation of the criteria and program
  elements for a year to be eligible.
• VPPPA Application Workshops and Conferences.
• Regional OSHA Compliance Assistance Specialists
  and OSHA VPP Outreach assistance available
  through out the Region.
• The VPPPA, the Department of Defenses VPP Center
  of Excellence, VPP mentors, the Department of
  Energys VPP, State Plan State VPPs- a wealth of
  VPP information is available including
  eligibility, visit all their VPP websites
  (including OSHA's)!

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Eligibility (contd)

• VPP eligibility requirements in the Federal
  Register Notice (FRN) and OSHA VPP Policy and
  Procedures Manual.
• How are your injury and illness rates doing? How
  they are calculated, and their significance to be
  eligible for VPP.
• Maintaining eligibility the obligations,
  requirements and responsibilities in VPP. Yearly
  and the long view.
• What happens if you leave VPP? Can you leave?
  Can you be asked to leave? Hotel California
  paradox.

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VPP Applications

• What OSHA means by the document called an
  Application. Its purpose, nature and scope. See
  the FRN and the TED for primary guidance.
• Examples/samples are easily obtained. No
  pre-printed forms or charges. How is it defined
  and what it should include (and not include).
• Suggestions for the Applications attachments.
  The idea of less is better than more, not too
  fancy.
• Why knowledge of injury and illness recordkeeping
  procedures are important. How do the rates
  impact VPP Star and how is OSHA recordkeeping
  data best presented in the application. The Over
  recording paradox.
• Management Letter of Assurances and Union Support
  Letters.

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VPP Applications (contd)

• What OSHA means by the application Process. What
  happens after the application is submitted to
  OSHA (or, when it leaves your finger tips and
  falls forever into the mailbox)?
• The application is the first formal step to the
  VPP partnership with OSHA.
• How it opens the door that leads to the onsite
  VPP Team Evaluation, and OSHA VPP approval.
• What are Post application Pre-visits?
• Time frames leading up to the onsite evaluation.

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The VPP Onsite Team Evaluations

• What is the purpose, nature and scope of the VPP
  Team Evaluation? Who are these guys youre
  inviting in anyways?
• How much time to when they arrive?
• VPP Team composition compliance officers,
  specialists, volunteers, observers. How many,
  and for how many days?
• What are the multiple roles and importance of the
  team member escorts?
• Joint venturing with the sites management,
  unions, employee committees, employees, and
  contractors.
• What are the possible team evaluation outcomes?
• How do you prepare your site to assure maximum
  success?
• What happens after the visit? General time
  frames. VPP Report finalization.
• Flag Presentation Ceremony. 

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Interviews Conducted by Team Members

• What does OSHA means by interviews? Why and how
  it works.
• As a barometer of employee knowledge and
  ownership, site safety culture, and management
  leadership. Perception is reality.
• Site ramping up, communication and preparation.
  How to test the waters. Use of VPP Core Teams
• Formal, Informal and Group Interviews defined.
  How many is enough?

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Interviews (contd)

• Getting Region IIIs examples of best interview
  questions and interactions, and how to use them.
• Upper and middle management, First Line
  Supervision, and Outside Contractor Interviews.
• Using the example interview questions as a Gap
  Analysis Technique.
• OSHA knows, not everyone is a happy camper.

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Who are the VPP Team Members?

• The Team Leader.
• Back-up Team Leaders.
• Industrial Hygienists.
• Safety Specialists.
• Special Government Employees.
• All OSHA teams vs. mixed.
• Regional Compliance Assistant Specialists (CASs)
• Suggested Roles for your Team Members.
• You can be on a VPP team.

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Opening and Closing Conferences

• Purpose, Nature and Scope, kick off and
  conclusion.
• What is covered, who should attend, duration and
  details.
• OSHA Team Leaders role
• Plant Managers role
• Site EHS role
• Unions role
• Findings presented.
• The Teams Recommendation, three choices.
• What happens next, closure.

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What to Expect

• The main team activities living up to the
  Previsit discussions.
• Tour of the site after the Opening Conference
• Verification vs. Discovery modes.
• Documentation reviews, arranging the documents.
• Interviews and selections.

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What to Expect (contd)

• Walking the site.
• Help from the escorts, revisited.
• Report and Worksheets preparation. Drafts.
• Where to get more information

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What about the VPP Team Recommendation?

• Star or Merit Recommendation, VPP team consensus.
• Why is it called a Recommendation?
• Star as defined in the Federal Register Notice
  (FRN). What is Merit?
• How Merit sites become Star.

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What are 90-day Contingency Items, Merit Goals,
Site Program Recommendations?

• How VPP teams approach OSHA violations at VPP
  applicant sites.
• Revisiting the Letter of Assurances.
• Isolated incidences vs. trends, what OSHA expends
  to find.
• The self-audit VPP element.
• Following the thread.
• What gets written down, escorts again.

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What is the VPP Reevaluation Process, -the
Recerts?

• Why Recerts are necessary. You cant step into
  the same worksite twice.
• The founding principle of VPP is constant
  improvement, keeping it Evergreen.
• Who conducts the Recerts?
• Time frames.
• The paradox of injury and illness rate
  improvement.
• Contingent Stars.

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What are the Annual VPP Self-assessments?

• Revisit the Letter of Assurances.
• Annual Self-assessments are not compliance
  audits.
• Who should do them?
• Follow the OSHA Template, requested data, due in
  February.

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And finally, why go VPP?

• Stimulates culture change (trust in management).
• VPP requires a culture change.
• Improves the visibility of management leadership
  and the Safety and Health Program.
• Leverages safety and health in the company.
• Keeps everyones eye on the safety ball.
• Improves relationships with unions. Promotes a
  higher level of
• union/management cooperation.
• Enhances positive relationships with OSHA at all
  levels.

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Why not go VPP?

• You simply may not need it (you can do all this
  without OSHA)!
• Be careful of what you ask for, Recertifications
  and maintenance is required. Recertification
  requires continuous improvement and rate
  reductions.
• VPP is not the flavor of the month, its a
  continuous process and should be seen as a
  lifetime commitment.

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More why not go VPP

• Costs though VPP is free--your taxes have paid
  for this federal government program. it isnt
  cheap. To be in the program you have to do all
  the elements. Most companies have to grow and
  polish their safety systems to qualify. Do a
  gap analysis and determine the costs and time
  commitment to fill the gaps. Look before you
  leap.
• Timing. Are you really ready? Make sure you are
  culturally ready as well as technically ready.

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Please Consider and Questions

• Make Everything as Simple as Possible, But Not
  Simpler
• Albert Einstein
• 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