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OSHA Voluntary Protection Programs

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In practice, VPP sets performance-based criteria for a managed safety and health ... Qualified sites are approved to one of three programs: Star, Merit, and Mobile ... – PowerPoint PPT presentation

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Title: OSHA Voluntary Protection Programs


1
OSHA Voluntary Protection Programs
OSHA Region III VPP
Mileposts Talking Points
December 2006
Peter Brown
Region III VPP Outreach Coordinator
2
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.

3
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.
4
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

5
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.

6
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)!

7
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.

8
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.

9
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.

10
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. 

11
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?

12
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.

13
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.

14
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.

15
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.

16
What to Expect (contd)
  • Walking the site.
  • Help from the escorts, revisited.
  • Report and Worksheets preparation. Drafts.
  • Where to get more information

17
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.

18
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.

19
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.

20
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.

21
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.

22
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.

23
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.

24
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
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