Common Deficiencies Found on VPP Evaluations

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Common Deficiencies Found on VPP Evaluations

• By Matt Gaines
• VPP Manager

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Two Types of Evaluations

• Initial Certification
• Recertification

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Recertifications

• 18 24 Months for MERIT
• STAR, First Recertification 3 years
• STAR, After First Recertification 5 years

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Emphasis on Initial Certification

• Verify what is stated in Application
• Does site meet the requirements of VPP
• Understanding of OSHA and VPP requirements

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Emphasis on Recertification

• What has changed since last audit?
• Special emphasis on SH Program improvements
  (Looking for continual improvement!)
• Is site still meeting VPP requirements?
• Recertification report will include a special
  section entitled Program Changes and
  Improvements

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Meeting the Requirements?

• Sites are encouraged to be familiar with the
  questions in the VPP Site Worksheet!
• MR Minimum Requirement (Must be met to be
  in/remain in VPP)
• Non MRs MERIT Goal or STAR Conditional Goal

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6 Focus Areas

1. Injury/Illness Rates
2. Management Commitment
3. Employee Involvement
4. Worksite Analysis
5. Hazard Prevention Control
6. Training

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Common Deficiencies Found in the Six Focus Areas
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Injury Illness Rates

• Increase in rates
• 1) Trend analysis?
• 2) Hazard recognition training?

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Recordkeeping

• Properly recording on OSHA Logs is now a Minimum
  Requirement!
• Ensure that you record-keeper is properly
  recording injuries illnesses.
• Improper recording can lead to application denial
  or withdrawal from VPP!!

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Management CommitmentInitial Certification

• Are management and employees knowledgeable about
  safety health/VPP???
• Are you applying for VPP for the right
  reasons?.......
• To keep OSHA Compliance OUT or Wanting just a
  free consultation visit vs.
• To improve your safety and health management
  systems and join the elite

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Management CommitmentRecertifications

1. Change of management personnel??
2. Redirection of priorities? (production vs.
   safety) Economic Issues
3. Less time spent on safety/VPP
4. Less resources for safety ()
5. Are new managers/employees knowledgeable about
   safety health/VPP???

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Employee InvolvementInitial Recertification

• 1) Employees MUST be involved in all aspects of
  VPP evaluation (open to close!)
• 2) There must be at least 3 meaningful ways for
  employees to participate
• (If you eliminate one means of participation,
  you must come up with another!)
• 3) Employees not knowledgeable of VPP or elements
  (New employees on recert)
• 4) No follow-up with employee suggestions or
  reports of hazards

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Employee Involvement, Continued

• Submittal of application before you have
  employee/local union buy-in.
• Remember.For VPP you must have established a
  safety and health culture. That means employee
  involvement and buy-in!

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Worksite AnalysisInitial Certification

• Those tasked with performing safety and health
  audits have poor hazard recognition skills (ie.
  numerous 90-day items) Know the OSHA
  Standards!!!
• JSA/JHAs for routine tasks not developed

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Worksite AnalysisRecertifications

• Site no longer performs monthly inspections or
  ensures quarterly coverage of entire site.
• New equipment, process, or chemicals and no new
  IH sampling
• New process and no new JSA/JHA
• New equipment and no specific LOTO procedure
• Analyze new equipment for safety prior to
  purchase (ie machine guarding)
• Poor hazard recognition skills of new staff (90
  day items)

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Hazard Prevention and ControlInitial
Recertification

1. Site not following the hierarchy of controls
2. Emergency drills not held annually
3. First Aid/CPR response must cover ALL shifts.
4. Inadequate contractor safety program

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Safety Health TrainingInitial Recertification

• Inadequate training for new hires
• Inadequate training for temporary employees
• Lack of knowledge of VPP
• Lack of hazard recognition skills as evidenced by
  numerous hazards noted on walkthrough

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Other Deficiencies

• Safety incentive programs tied solely to
  injury/illness rates
• Failed to correct a 90-day item from the previous
  VPP audit that you said you corrected!!!!
• Little or no improvements to SH program since
  the last VPP evaluation

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Other Concerns Continued

• Employee complaints filed with OSHA (SH and 11c)
• OSHA Citations
• The above could lead to termination of VPP
  participation!

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Emerging Trend

• Upper Management or Corporate Push
• You will submit the VPP application by
  XX/XX/2010OR ELSE!

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SPEAK UP!

• Safety and Health Culture MUST be established.
• If the site is not ready, the results of the
  onsite may result in embarrassment.

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Incentive Programs!

• Incentives cannot create a disincentive to
  report injuries and illnesses.
• Examples Monetary bonuses
• Meals
• Gift Cards
• Days off

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Incentives, cont.

• Incentive programs should promote safety
  awareness and participation in safety-related
  activities. (VPP PP Manual)
• There is no problem with celebrating milestones
  so long as they are not advertised in advance.
• We just.. vs. IF we

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Incentives, cont.

• Examples of positive incentives
• Rewards for near-miss reporting
• Rewards for involvement
• Reward for hazard identification and or abatement
  ideas

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Incentives, cont.

• Regardless of the monetary value of the reward
  offered, a company whose incentive program has
  the potential to discourage worker reporting
  fails to meet the VPPs safety and health
  management system requirements.
• VPP Policy Memorandum 5 Dr. David Michaels

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Conclusion

• Keep looking for ways to improve your program.
• Benchmark with other VPP sites.
• Participate as an SGE.
• Keep abreast of new VPP policies.
• Keep your STAR!!!!

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Questions??
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• Contact information
• Matt Gaines
• 816/283-0545 ex247
• gaines.matt_at_dol.gov