VPP Mobile Workforce Demonstration for Construction

1
VPP Mobile Workforce Demonstration for
Construction
2
Highlights

• Eligibility
• Application Process
• Approval Process
• Continuing Participation Requirements

3
Eligibility
Contact Initiated Demonstration Candidate
Eligibility Determination and Application
Guidance VPP Manager or Coordinator
4
Who is Eligible?

• Construction industry SIC/NAICS
• 3 years operating in construction industry
• GCs and Specialty Trade Contractors at the
  Corporate, Division, or Business Unit level
• Long-term and short-term projects
• May or may not have authority and responsibility
  for safety and health over the entire site
• Inspection History
• No open citations

5
Application Process
Contact Initiated Demonstration Candidate
Eligibility Determination and Application
Guidance VPP Manager or Coordinator
Application Review VPP Manager or Coordinator
Application Submittal Demonstration Candidate
6
Unique Application Features

• Designated Geographic Area (DGA)
• Union Support
• Participation Plan
• Applicants Prescreening/Oversight Processes
• Injury and illness data

7
Designated Geographic Area (DGA)

• No smaller than an Area Office
• May cover multiple AOs within a single Region
• AOs do not have to be within the same state
• No larger than a Region
• May cover multiple states within a Region
• Applicants who want to participate in multiple
  Regions should contact the NO

8
Union Support

• OSHA expects each applicant to determine whether
  the requirement for union support applies.
  Calculate the percentage of your employees
  (including temporary employees) and subcontractor
  employees who are represented by unions at the
  time of your application. Then use the chart
  below.

9
Applicant Participation Plan

• Designed to address elements of VPP that are
  different from those published in the current VPP
  FRNs, such as
• DGA
• Annual Emergency Evacuation Drills
• Baseline hazards analysis
• Employee Involvement
• Alternative program elements must provide
  protection equal to that of traditional VPP
• Emphasis on good practices

10
Applicants Prescreening/Oversight Processes

• Applicant must perform onsite prescreening/oversig
  ht processes for all worksites within DGA
• Assure VPP-quality safety and health protection
  at all active worksites within the DGA
• Demonstrates direct corporate oversight and
  involvement in SH at worksites
• OSHA will verify effectiveness of and compliance
  with an applicants processes
• Review documentation during the corporate onsite
  evaluation
• Verify effectiveness during worksite evaluation(s)

11
Calculating Injury Illness Data

• Injury and Illness Rate Requirements
• 3-year TCIR and DART rate reflecting experience
  of the participants workforce throughout the DGA
  
• Required at Application
• Company-only data for the first two years
• Combined injury and illness data, including all
  subcontractors, for the most recent calendar year
• Subsequent reporting must continue to build upon
  the combined rate data

12
First Year Combined Injury and Illness Data
(Sample)
13
Application Format

• Largely follows the current VPP application
  format
• Emphasize subcontractors, where applicable
• Injury and Illness data
• Prescreening
• Supplemental application instructions cover
  differences

14
Participation Decisions
Contact Initiated Demonstration Candidate
Eligibility Determination and Application
Guidance VPP Manager or Coordinator
Application Review VPP Manager or Coordinator
Application Submittal Demonstration Candidate
Participation Decisions VPP Manager/RA (in
conjunction with Candidate)
15
Participation Decisions

• Determine applicants eligibility
• Review application, including
• Applicants Participation Plan
• Union Support
• Prescreening Process
• Injury and Illness Data
• Active/anticipated worksite list
• OSHA, after consulting with the applicant, will
  determine the DGA

16
Two Phase Onsite Evaluation
Contact Initiated Demonstration Candidate
Eligibility Determination and Application
Guidance VPP Manager or Coordinator
Application Review VPP Manager or Coordinator
Application Submittal Demonstration Candidate
Participation Decisions VPP Manager/RA (in
conjunction with Candidate)
Corporate Onsite Evaluation OSHA Evaluation Team
Worksite Evaluation(s) OSHA Evaluation Team
17
Two-Phased Onsite Evaluation

• Corporate Onsite Evaluation
• Worksite Evaluation(s)

18
Phase 1 - Corporate Onsite Evaluation

• The focus is to verify that the applicant has all
  of the policies, procedures, and programs (e.g.
  confined space) in place to effect VPP Star
  quality safety and health at all locations within
  the DGA
• Verify all information described in the
  application
• and participation plan
• Length of onsite evaluations may vary

19
Corporate Onsite Evaluation Elements

• Evaluation elements will include
• Assessment of management leadership
• Assessment of employee involvement
• Review of corporate SHMS
• Review of prescreening/oversight processes
• Measure safety and health performance
• Review Recordkeeping
• Annual Evaluations

20
How Many Worksites Do We Evaluate?

• The Regional Administrator has the discretion to
  select the number of onsite evaluations based on
  the following criteria
• The number needed to cover all the types of work
  performed
• The phases of construction and the nature of the
  hazards
• The geographic scope of the application
• Other factors which OSHA determines may affect
  its ability to fully and accurately assess the
  effectiveness of the SHMS
• Normally will not exceed the number of programmed
  inspections the Regional Administrator would
  otherwise expect an applicant to receive
• F.W. Dodge Reports serve as basis, where
  applicable

21
Phase 2 - Worksite Evaluation(s)

• Number and Location determined by OSHA
• Evaluated using a similar process to a VPP
  Corporate Facility
• Verify that the corporate SHMS is in place and
  effective
• Interview employees and management
• Review any site-specific elements
• Verify compliance with OSHA regulations
• Non-controlling applicants will need to gain
  written assurance from controlling employer that
  OSHA can come onsite

22
Selected Worksite VPP Approval

• Decisions
• VPP Star
• VPP Merit
• Application Denial
• One or more sites do not meet VPP minimum
  requirements (MR)

23
Report Format

• Use VPP Site Report and VPP Worksheet to Document
  Corporate SHMS
• Will provide supplemental instructions regarding
  differences
• Temporary solution
• One report that documents and verifies findings

24
Continuing Participation Requirements
25
Reapproval, Withdrawal and Termination

• Reapproval
• Evaluate additional worksite(s) every 12 to 18
  months
• Number of sites same rules as application process
• Evaluate corporate SHMS every 5 years
• Withdrawal/Termination
• RA will
• Give the company 30 days to meet requirements or
  
• Ask the company to withdraw from the
  Demonstration.
• May terminate if employer fails to withdraw
• Appeals to Assistant Secretary

26
Annual Evaluation

• Submit by February 15th
• Same format as traditional VPP with few
  exceptions
• Employment estimates for previous Year TCIR and
  DART Rates
• Active/anticipated worksite list for current year
• Union support update for current year

27
The Path Forward

• Effective October 1, 2006, all current VPP Star
  Demonstration Programs will terminate
• Current Demo participants grandfathered into new
  Mobile Workforce Demonstration for Construction
• Traditional VPP still available
• Long-term sites
• Resident contractors at VPP sites
• VPPC FY 2007