OSHA Voluntary Protection Programs

1. OSHA Voluntary Protection Programs OSHA Cooperative Programs Partnerships and Recognition VPP Overview Peter Brown, OSHA VPP Outreach General Electric Company – Energy EHS VPP Mentoring Program

2. VPP OverviewIntroduction • This presentation is in the public domain and may be reproduced. No permission is needed. This presentation establishes no new OSHA requirements. • There are 10 OSHA Regions across the nation. Each has a Voluntary Protection Program (VPP) Coordinator. • OSHA Region III includes Pennsylvania, West Virginia, Virginia, Delaware, Maryland, and the District of Columbia. For Region III VPP information contact brown.peter@dol.gov.

3. VPP Overview The Concept • OSHA’s VPP concept recognizes that enforcement of OSHA standards alone cannot fully achieve the objectives of the Occupational Safety and Health Act of 1970. • Good safety and health management systems go beyond the OSHA standards. A quality safety program must be approached as a business priority, just as productivity, quality, and customer satisfaction is. A safety culture can protect workers more effectively than stand alone, one dimensional OSHA compliance. The OSHA standards primarily address the physical worksite. Safety must be both regulatory and people centered. • VPP worksites have a performance-based approach to safety that includes the VPP criteria and elements as a foundation. These criteria give participants latitude to address their safety and health concerns in ways that are both effective and appropriate to their specific needs, culture, and industry.

4. VPP Overview VPP Star • OSHA VPP Star sites demonstrate exemplary safety and health management systems. They are recognized and publicized by OSHA for their achievements in: • Visible safety leadership. • Employee trust and participation. • Worksite hazard recognition, evaluation and control . • Exemplary safety and health training. • Upper management must be committed to VPP Star principles and must provide the best in safety resources and expertise for worker protection.

5. VPP Overview VPP Star • Worksites must achieve meaningful employee and union (where applicable) involvement and ownership in safety. In VPP, OSHA will assist management and labor in making their site a safety and health leader in the industry. The site receives the OSHA VPP Star Flag. • As a result of implementing VPP criteria and maintaining a Star safety culture, worksites enjoy reductions in injury frequency, severity rates, mishaps, accidents, and near misses. • Absenteeism and costs go down; productivity goes up.

6. VPP Overview Other VPP Programs • OSHA VPP Merit The Merit Program provides a planned set of "stepping stones" to Star recognition for those employers who have demonstrated their potential and willingness to achieve Star requirements. The site receives the OSHA VPP Merit Flag. • OSHA VPP Mobile Workforce Demonstration in Construction This is a new OSHA program primarily intended to recognize exemplary safety programs of short term contractors and mobile workforces. The job site receives the OSHA VPP Mobile Workforce Demonstration Flag.

7. VPP OverviewCoverage • All industries, large or small, that come under OSHA jurisdiction, including federal agencies, are eligible to be recognized by OSHA as VPP Star workplaces. • This includes union and non-union sites. Approximately 30 % or more of all VPP sites are unionized. • Industry sectors with VPP representatives include manufacturing, construction, healthcare, food processing, chemicals, energy/power generation, shipbuilding, and Part 1960 federal agencies.

8. VPP Overview Cooperation • VPP emphasizes trust, partnership, and cooperation between OSHA, management, and labor. • OSHA’s cooperative partnerships and alliances complement OSHA’s enforcement programs. • Although VPP sites are exempt from programmed enforcement inspections, employers and employees retain their rights and responsibilities under the Occupational Safety and Health Act.

9. VPP Overview Good Performance • VPP Star sites have a fully implemented, results driven safety and health management system. The focus is on continual improvement. VPP Star facilities are 50% or more below their industry’s average injury and illness rates. Rates mean OSHA recordable injuries or illnesses per 100 full time employees. • When OSHA conducts the onsite VPP evaluation, the site's safety systems are verified as to how well they are working. This includes a review of injury and illness rates and trends. • To maintain VPP Star status, sites must host VPP recertification reviews every 3-4 years. This encourages participant sites to improve safety performance, further reduce injury rates, and maintain the VPP elements.

10. VPP Overview Star Points, Adequacies When OSHA conducts the VPP onsite review, the team is verifying Five Star Points and twoAdequacies. Five Star Points • Site Injury and Illness Rates. The three year Total Case Incidence Rate (TCIR) and Days Away, Restricted or Transferred (DART) Case Rate, as determined from the OSHA 300 logs and total hours worked over three years, must be below the Bureau of Labor Statistics published national rates (BLS) for the site’s industry. • Compliance with all OSHA standards, plus hierarchy of hazard control. • VPP Support and Knowledge by management, unions, employees and contractors at the site. • Safety and Health Annual Self-assessments with yearly recommendations done in accordance with the OSHA VPP Policy and Procedures Manual CSP 03-01-002, Appendix D. • Sufficiency of Worksite Hazard Analysis-in particular good JSAs or JHAs are done.

11. VPP Overview Star Points, Adequacies and Two Adequacies… • Is the safety and health program adequate for the size of the site? • Is the safety and health program adequate to control the type of hazards inherent and anticipated in the site’s industry? Region III acknowledges the concept of latitude in the application of the VPP elements.

12. VPP Overview The VPP Criteria The following slides, #11 through #36, summarize the VPP Criteria and their Elements. The Criteria are published and described in OSHA’s VPP Federal Register Notice, and on OSHA’s newly updated (April 2007) VPP website http://www.osha.gov/dcsp/vpp/index.html Criteria I Management Leadership & Employee Involvement Criteria II Worksite Analysis Criteria III Hazard Prevention and Control Criteria IV Safety and Health Training

13. VPP Overview Criteria I Management Leadership & Employee Involvement • Management CommitmentElement • Clearly established safety and health policies that have been communicated to and understood by all employees. • Established safety and health goals and objectives are revised annually. • VPP CommitmentElement • Management must clearly demonstrate commitment to meeting and maintaining VPP requirements. • Employees and onsite contractors are informed of this commitment.

14. VPP Overview Criteria I Management Leadership & Employee Involvement • Planning Element • Planning for safety and health must be a part of the overall management planning process. • The Written Safety and Health Program Element • Written program must include all four VPP Criteria and their sub-elements. • Federal Agencies must also meet requirements for 29 CFR 1960.

15. VPP Overview Criteria I Management Leadership & Employee Involvement • Top Management LeadershipElement Managers must provide visible leadership by: • Establishing clear lines of communication. • Creating an environment that allows for reasonable employeeaccess to top site management. • Setting an example of safe and healthful behavior. • Ensuring all workers, including contractors, are provided equally high quality safety and health protection. • Clearly defining responsibilities in writing.

16. VPP Overview Criteria I Management Leadership & Employee Involvement • Authority and ResourcesElement • Commensurate authority must be given to those with safety & health responsibilities. • Site must ensure adequate resources to those with responsibility and authority. • Line AccountabilityElement • Must hold managers, supervisors, and non-supervisory employees accountable through a documented system.

17. VPP Overview Criteria I Management Leadership & Employee Involvement • Contract Worker CoverageElement • All contractors and sub-contractors, whether in general industry, construction, maritime, or at federal agency sites, must follow worksite safety and health rules and procedures applicable to their activities while at the site. • VPP sites are expected to encourage contractors to develop effective safety and health program management systems. • VPP site contractor programs must include a documented oversight and management system that ensures the contractor’s site employees are provided effective protection.

18. VPP Overview Criteria I Management Leadership & Employee Involvement • Employee InvolvementElement • The site culture must offer, enable, and encourage effective employee involvement in the planning and operation of the safety and health programs as well as in decisions that affect employees’ safety and health. • In accordance with the VPP Federal Register Notice, there must be a minimum of three ways employees can be involved in safety, in addition to notifying management of unsafe conditions.

19. VPP Overview Criteria I Management Leadership & Employee Involvement • Annual Safety & Health Program Self-assessment Element • The site must have an annual self-assessment system for evaluating the operation and results of the safety and health program. • The system will judge the site’s success in meeting the program’s goals and objectives. It will identify and assist those responsible for determining and implementing changes for continually improving worker safety and health protection.

20. VPP Overview Criteria I Management Leadership & Employee Involvement • The annual self-assessment system is not a compliance audit. It must include: • A written, narrative report. • Recommendations included for improvements. • Assignment of responsibility. • Documented timely follow-up. • OSHA recommends that the assessment follow the “Suggested Format for Annual Submissions” – Appendix D of the VPP Policies and Procedures Manual, published by OSHA and found on OSHA’s VPP web page.

21. VPP Overview Criteria II Worksite Analysis • Management UnderstandingElement • Management of safety and health programs must begin with a thorough understanding of all hazards and unsafe conditions/behaviors to which employees may be exposed and have the ability to recognize and correct all hazards as they arise. • Baseline Industrial HygieneElement • The program must include a site wide, baseline identification of health hazards and employee exposure through an industrial hygiene sampling rationale and strategy. • All sampling, testing, and analysis should use nationally recognized procedures and protocols, with maintenance of documented results.

22. VPP Overview Criteria II Worksite Analysis • Pre-Use AnalysisElement • All newly acquired or altered facilities, processes, materials, equipment, and/or phases must be analyzed before use begins to identify hazards and the means for prevention and control. • Hazard AnalysisElement • The site must perform routine examination and analysis of safety and health hazards associated with individual job tasks, processes, or phases. May be in the format of JSAs, JHAs, PHRs (process hazard reviews), etc. for routine and non-routine jobs. The results must be included in training, new assignments, and hazard control programs.

23. VPP Overview Criteria II Worksite Analysis • Routine InspectionsElement • Site must have a system for conducting routine self-inspections (self- audits), preferably involving employees. • System must include written procedures and guidance that must result in written reports of findings. Tracking of hazards must result in elimination or control. • There should be appropriate follow-up to verify continual control. • In general industry, federal agencies, and maritime, these inspections must occur at least monthly and cover the whole worksite at least quarterly.

24. VPP Overview Criteria II Worksite Analysis • Employee Hazard Reporting SystemElement • Site must have a written, workable system employees may use to notify management of unsafe conditions, behaviors, safety and any health related issues, questions, and observations. • System must include timely and appropriate responses and be free of discrimination or retribution. • System must include tracking of responses and of hazard elimination or control to completion.

25. VPP Overview Criteria II Worksite Analysis • Employee Hazard Reporting System …continued • System should also have a component which allows employees to make anonymous reports of conditions appearing to be hazardous. • System should allow for responding to anonymous reports using employee bulletin boards, newsletters, etc.

26. VPP Overview Criteria II Worksite Analysis • Accident/Incident Investigation SystemElement The system must include: • Written procedures/guidance. • Written reports of findings. • Hazard elimination or control tracking to completion. • Procedures for investigation of near misses. • Investigations that seek out root causes for the accident/incident. Fix the causes and not the blame.

27. VPP Overview Criteria II Worksite Analysis • Trend and Pattern AnalysisElement • The safety and health management system must include analysis of important data and information for trending and pattern analysis. • Information that might be used in trending includes, injury/illness history, hazards identified during inspections, employee reports of hazards, accident/near miss investigations, body parts, departments, business cycles, etc.

28. VPP Overview Criteria III Hazard Prevention and Control • Controlling HazardsElement • Site hazards identified during and through the hazard analysis process (see Criteria II) must be eliminated or controlled by developing and implementing the most protective systems first and the least protective last. This is known as the Hierarchy of Controls. • The hazard control methods a site chooses to implement must be understood and followed by affected parties and be appropriate for the size of the worksite and type of hazards associated with the worksite.

29. VPP Overview Criteria III Hazard Prevention and Control • Certified Professional ResourcesElement • The site must have reasonable access to Certified Safety Professionals (CSP), Certified Industrial Hygienists (CIH), and/or other certified professionals including Ergonomists. • Certified professionals do not have to be stationed onsite. They can be corporate based, outside consultants, or insurance company representatives. If they are not based onsite, however, they should periodically visit the site and function as an additional expert resource for the safety staff.

30. VPP Overview Criteria III Hazard Prevention and Control • Hierarchy of ControlsElement The following hierarchy should be used in selecting actions to eliminate or control hazards: Engineering Controls:Most reliable and effective, best practices. Administrative Controls:Significantly limit daily exposure to hazards by controlling, managing, or manipulating the work schedule or manner in which work is performed (e.g., job rotation, change shift duration, etc.).

31. VPP Overview Criteria III Hazard Prevention and Control • Hierarchy of ControlsElement …continued Work Practice Controls:Includes workplace rules, safe and healthful work practices, and procedures for specific operations. Personal Protective Equipment:Covering the body up. Hazard Control Programs:Includes, but is not limited to, control of hazardous energy (lock out/tag out), confined space entry, hazard communication, respiratory protection, hearing conservation, blood borne pathogens, fall protection, etc.

32. VPP Overview Criteria III Hazard Prevention and Control • Preventive Maintenance ProgramElement • PM System must be written. The monitoring and maintenance of workplace equipment must be documented. • Preventive and Predictive maintenance prevents equipment from becoming hazardous or contributing to unsafe conditions in the physical workplace.

33. VPP Overview Criteria III Hazard Prevention and Control • Hazard Correction TrackingElement The site must have a formal system for initiating and tracking hazards identified through the various safety and health programs, in a timely manner. • Occupational Health Care ProgramElement The program must include licensed health care professionals who assess employee health status for prevention of, as well as early recognition and treatment of, injury and illness. In conjunction with the IH program, health care professionals should be involved with site self-audits and inspections.

34. VPP Overview Criteria III Hazard Prevention and Control • Occupational Health Care Program …continued • Provide access to certified first aid and CPR providers as well as physician and emergency medical care on all shifts. • Progressive Disciplinary Program Element • A safety disciplinary system must be written, clearly communicated, and equitably enforced.

35. VPP Overview Criteria III Hazard Prevention and Control • Disciplinary Program…continued • Include procedures for disciplinary action or reorientation of managers, supervisors, and non-supervisory employees who break or disregard safety and health rules, safety work practices, proper material handling, or emergency procedures. Must be documented.

36. VPP Overview Criteria III Hazard Prevention and Control • Emergency Response Program and ProceduresElement • Emergency procedures must be developed for all shifts worked. • Must be written and communicated to all, including outside contractors and temporary employees. • Must list requirements for PPE, first aid, medical care, and emergency egress. • Must include provisions for emergency telephone numbers, exit routes. • Must have training drills including, at a minimum, annual evacuation drills.

37. VPP Overview Criteria IV Safety and Health Training • Managers and SupervisorsElement • Understand their safety and health responsibilities as discussed in Criteria I, Management Leadership and Employee Involvement, and are able to carry them out effectively. • Managers, Supervisors, and Non-supervisory Employees, including ContractorsElement • Are made aware of and taught how to recognize hazards, unsafe conditions, and the signs and symptoms of workplace-related illnesses.

38. VPP Overview Criteria IV Safety and Health Training • Managers, Supervisors, and Non-supervisory Employees, including ContractorsElement …continued • Must learn safe work procedures to follow in order to protect themselves from hazards. • Training includes reinforcement and reviews of procedures to notify supervision of hazards. • EmergenciesElement • Managers, supervisors, non-supervisory employees, contractors, and visitors must understand what to do in emergency situations.

39. VPP Overview Criteria IV Safety and Health Training • Personal Protective EquipmentElement • Where and when PPE is required, employees understand why it is required, its limitations, how to use it, and how to maintain it. • Managers, supervisors, employees, outside contractors, and visitors all use PPE properly.

40. VPP Overview Getting Started • Become familiar with VPP Star requirements, elements, and process. • Understand the expectations and obligations. • Learn what a VPP application is and how is it written. • Determine when you and your employees are ready to pursue VPP. • Learn who your OSHA VPP contact people are and how to request VPP outreach and assistance at your site. • Invite an OSHA VPP Outreach staff member to your site to discuss the VPP program, including the application process, how to conduct a safety program gap analysis, how to fill the gaps, what takes place during the onsite VPP evaluation, and especially, how to prepare for it.

41. VPP Overview Getting Started • Outreach assistance will help you spot useful corrections or needed changes before you begin the application process. OSHA encourages questions and frank discussion about what is required to implement a Star quality safety and health management system. This puts everyone on the same page and leads to a good conclusion for all stake holders. • OSHA offers a program self-assessment kit on the OSHA VPP webpage. Additional guidance, samples of actual applications, sample checklists, templates, and gap analysis tools are available and free from VPP Outreach Coordinators in all Regions.

42. VPP Overview Application • The VPP application process is designed to be rigorous, to assure that only the best programs qualify. OSHA VPP reviewers don't look for a single correct way to meet VPP requirements. They want to see a successful system that works for you.Some successful programs involve a lot of written documentation, while others do not. • There is some paperwork required in the application process, but we encourage you to use as much existing material as possible. • An application is a written, descriptive narrative covering general company and site information, and how the site has implemented the VPP criteria and elements. Attachments are added to clarify and amplify the narrative. There are no forms or fees. VPP is free, your taxes have already paid for it.

43. VPP Overview The Team Review • Each VPP applicant site undergoes a VPP team evaluation of the site’s safety and health management system. The multi-step review usually requires about two to four days depending on the size and complexity of the facility. • In addition to a review of records, logs and inspection history, the site review includes an initial meeting or opening conference with management and employees, an escorted walk-through of the facility to verify that hazards have been controlled, formal and informal employee and management interviews, and a closing conference to discuss team findings and recommendations. • A VPP report is prepared by the VPP team which is transmitted to the Assistant Secretary of Labor through the OSHA Regional Administrators.

44. VPP Overview VPP Benefits • The onsite process includes a VPP team review (team size varies usually from 3-6 OSHA and volunteer VPP professionals) who document and evaluate the accomplishments and success of the site’s programs. As a fresh pair of eyes, highly experienced VPP teams contribute to your safety programby offering guidance and team recommendations for further improvements, as applicable. • Establishing and maintaining safety and health programs based on VPP models are reflected in substantially lower worker injury and illness rates. Site injury, illness, and near miss rates are often 50-70+ percent lower than industry national averages. This claim is based on a VPP track record that goes back to 1982.

45. VPP Overview VPP Benefits • VPP sites are recognized by OSHA as models of excellence of their industries. Cooperative interactions with OSHA gives VPP companies the opportunity to provide OSHA with input on safety and health matters and to provide industry with models of effective means for accomplishing workplace safety and health objectives. • VPP sites are not subject to routine OSHA inspections because a VPP review team has observed and documented the site’s capability to analyze and correct its own problems and hazards. • The VPP elements provide for safety and health audits with employee involvement, baseline safety and health surveys, adequate expertise and resources, training and information, and prioritized corrective action plans in place to provide superior protection. • The VPP re-evaluation or recertification process encourages sites to continually maintain and improve their programs.

46. VPP Overview VPP Benefits The following benefits have been cited by current VPP participants: • Improved employee motivation to work safely, leading to better communication, productivity, and quality of business. • Reduced workers' compensation costs. • Reduced absenteeism. • Recognition in industry and in the community. • Improvement of programs that are already good, through the internal and external review that's part of the VPP application process.

47. The End and the Beginning…Questions? • To learn the whole VPP story, visit OSHA’s newly updated VPP Website…http://www.osha.gov/dcsp/vpp/index.html • The Spanish translation was provided by Jose Jimenez, Environment, Health and Safety, Madrid, Spain. The project was coordinated through Richard Lubert, General Manager of EHS, and Barbara Peck, SGE/VPP Mentor. All General Electric Company participants are with the Energy business. • The translation for this PowerPoint may be requested from Peter Brown, Philadelphia VPP Outreach Coordinator, (215) 861-4914, or e-mail: brown.peter@dol.gov. “Make Everything as Simple as Possible, But Not Simpler.” Albert Einstein April/2007