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Course 716 - Safety Management System Evaluation

Safety guides and audits to make your job as a safety professional easier

The Voluntary Protection Program (VPP)

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The Voluntary Protection Programs (VPP) recognize employers and workers in the private industry and federal agencies who have implemented effective safety and health management systems and maintain injury and illness rates below national Bureau of Labor Statistics averages for their respective industries.

To participate, employers must submit an application to OSHA and undergo a rigorous onsite evaluation by a team of safety and health professionals. Union support is required for applicants represented by a bargaining unit.

VPP participants are re-evaluated every three to five years to remain in the programs. VPP participants are exempt from OSHA programmed inspections while they maintain their VPP status.

Benefits

The VPP has a 20+ year history, and the average VPP worksite has a Days Away Restricted or Transferred (DART) case rate that is 52% below the average for its industry. VPP participation can also lead to lower employee turnover and increased productivity and cost savings.

In VPP, management, labor, and OSHA work cooperatively and proactively to prevent fatalities, injuries, and illnesses through a system focused on: hazard prevention and control; worksite analysis; training; and management commitment and worker involvement.

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. OSHA's verification includes an application review and a rigorous onsite evaluation by a team of OSHA safety and health experts.

Three Levels of Participation

OSHA approves qualified sites to one of three programs:

  1. Star: Recognition for employers and employees who demonstrate exemplary achievement in the prevention and control of occupational safety and health hazards the development, implementation and continuous improvement of their safety and health management system.
  2. Merit: Recognition for employers and employees who have developed and implemented good safety and health management systems but who must take additional steps to reach Star quality
  3. Demonstration: Recognition for employers and employees who operate effective safety and health management systems that differ from current VPP requirements. This program enables OSHA to test the efficacy of different approaches.

1. Which of the following VPP levels is awarded to employers take additional steps to achieve higher recognition from OSHA?

a. Demonstration
b. Merit
c. Star
d. Sharp

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Three Categories of Participation

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The VPP was designed originally to primarily offer participation to fixed worksites, however Mobile Workforces and Corporations can also participate.

  1. Site-Based Worksite participation continues VPP's traditional acceptance of applications from fixed worksites and some long-term construction sites.
  2. Mobile Workforce participation is for companies that typically function as contractors or subcontractors and for those companies whose employees move site-to-site.
  3. VPP Corporate is designed for corporate applicants who demonstrate a strong commitment to employee safety and health and VPP.

Click on the buttons below for more information on the three categories of participation.

Fixed Worksites

Site-based participation continues VPP's traditional acceptance of applications from fixed worksites and some long-term construction sites. OSHA welcomes site-based VPP participation and accepts VPP applications from the owners and site officials who control site operations and have ultimate responsibility for assuring safe and healthful working conditions of:

  • Private-sector fixed worksites in general industry and the maritime industry
  • Construction worksites/projects that will have been in operation for at least 12 months at projected time of approval and that expect to continue in operation for at least an additional 12 months
  • Federal-sector fixed worksites
  • Resident contractors at participating VPP sites for the contractors' operations at those VPP sites
  • Resident contractors at non-participating sites for the contractors' operations at those sites, so long as the resident contractors are part of a larger organization approved to participate under the corporate option

Mobile Workforces

Based on positive experiences with past VPP Mobile Workforce Demonstrations and other VPP Demonstrations, OSHA introduced a VPP program designed for mobile workforces. OSHA believes this new way to participate will work for companies that typically function as contractors or subcontractors who may or may not have the authority for safety and health for an entire worksite and for those companies that have employees that move site-to-site such as a specialty trade contractor or repair and maintenance company regardless of size or length and duration of the project or service.

Following OSHA's review and acceptance of the application, a two-phased on-site evaluation takes place. In the first phase, OSHA's onsite evaluation team will review the applicant's corporate, division or business unit policies and procedures which include a review of safety and health management programs, document review and assessment of the management commitment to safety and health, and to VPP. The second phase is dedicated to review one or more worksites to verify the safety and health management programs are actually working outside the home office where employees may work unsupervised at sites that are not owned or controlled by the applicant.

VPP Corporate

VPP corporate is designed for corporate applicants, who demonstrate a strong commitment to employee safety and health and VPP. These applicants, typically large corporations or Federal Agencies, have adopted VPP on a large scale for protecting the safety and health of its employees. VPP corporate applicants must have established, standardized corporate-level safety and health management systems, effectively implemented organization-wide as well as internal audit/screening processes that evaluate their facilities for safety and health performance. Under VPP corporate, streamlined processes have been established to eliminate these redundancies and expand VPP participation for corporate applicants in a more efficient manner.

The VPP Safety and Health Management System

OSHA requires VPP applicants/participants to have a comprehensive safety and health management system consisting of four basic elements and sub-elements. These elements work together to prevent fatalities, injuries, and illnesses in the workplace. Within this system, all parts are interconnected and affect one another.

Click on the button below to see the four main elements of a safety & health management system (SHMS).

The Four Elements of the VPP Safety and Health Management System

The VPP SHMS consists of four critical interrelated elements. Effective implementation requires that they function together in one comprehensive and systematic effort.

  1. Management Leadership and Employee Involvement. In a VPP-quality organization, management regards worker safety and health as a fundamental value and applies its leadership to safety and health protection with as much commitment, planning, and visibility as it does to other organizational purposes. In organizations with the most effective system, employees are actively and meaningfully involved in the planning and operation of the safety and health management systems and in decisions affecting their own safety and health.
  2. Worksite Analysis. The successful management of workplace hazards begins with a thorough understanding of all hazardous situations to which employees may be exposed and the implementation of a meaningful system to recognize hazards as they arise.
  3. Hazard Prevention and Control. Workplace hazards identified during the hazard analysis process must be eliminated or controlled by developing and implementing specified systems and by using the specified hierarchy of controls.
  4. Safety and Health Training. Training is necessary to reinforce and complement management's commitment to prevent exposure to hazards. All employees must understand the hazards to which they may be exposed and how to prevent exposure to themselves and others from such hazards. Effective training enables employees to accept and follow established safety and health procedures, as well as to understand they are protected from retaliation for reporting hazards.

2. Which of the following groups was originally allowed to participate in OSHA's VPP?

a. Fixed worksites
b. Mobile workplaces
c. Corporations
d. Public agencies

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Guiding VPP Principles

These essential Principles are key to all VPP participants. To maintain Star-level participation, an applicant/participant is required to include, and maintain their SHMS with all of the elements listed.

  1. Safety and Health Management System (SHMS) Excellence. The SHMS must effectively identify, analyze/evaluate, and prevent/control hazards, ensuring the protection of employees and supporting the prevention of workplace injuries and illnesses. Star participants, in particular, are expected to be on the leading edge of hazard prevention methods and technology.
  2. Cooperative Relationship. OSHA expects cooperation in the interaction between labor, management, and OSHA. VPP's emphasis on open dialogue and cooperation complements the agency's enforcement programs. OSHA continues to investigate safety and health complaints, fatalities, catastrophes, serious injury or illness, and other significant events at VPP participant sites.
  3. Employee Support for VPP Participation. VPP applications must reflect the support of the applicant's employees.
  4. Compliance with the OSH Act. All VPP applicants and participants will comply with the OSH Act, OSHA standards/requirements, and in the case of Federal agencies, 29 CFR 1960.
    • Correcting Deficiencies. Any deficiencies related to compliance that are uncovered through OSHA on-site reviews, self-inspections, employee reports, incident investigations, process hazard reviews, annual self- evaluations, or any other means must be corrected promptly.
    • Employee and Employer Rights. Participation in VPP does not diminish employee and employer rights and responsibilities under the OSH Act and, for Federal agencies, under 29 CFR 1960.
  5. Voluntarism. Participation in VPP is strictly voluntary. The applicant who wishes to participate freely submits information to OSHA on its safety and health management system (SHMS), goes above and beyond compliance with the OSH Act and applicable OSHA requirements, and opens itself to agency review.
  6. OSHA History. If an applicant has been inspected by OSHA within the 60-month period preceding application, the inspection, abatement, and/or any other history of interaction with OSHA will be reviewed and must indicate good faith attempts to improve safety and health.
  7. Assurances. Applications to VPP must be accompanied by assurances describing steps the applicant agrees to undertake if OSHA approves the application.
  8. Continuous Improvement. VPP participants must demonstrate continuous improvement in the operation and impact of their SHMS. Annual VPP self- evaluations help participants to measure success, identify areas needing improvement, determine needed changes, and track the implementation of these changes.
  9. Protecting Whistleblower Rights. All VPP participants and applicants will agree to protect the rights of whistleblowers per 29 CFR Part 1977, will train managers on whistleblower protections during regular OSHA trainings and will post OSHA literature on whistleblower rights in a place visible to employees.
  10. Outreach. VPP participants serve as models of safety and health excellence in their industries and in their communities. As such, all VPP participants are required to conduct outreach and mentoring beyond their own facility.

3. According to the VPP guiding principles, who is expected to be on the leading edge of hazard prevention methods and technology?

a. Sharp participants
b. Demonstration participants
c. Merit participants
d. Star participants

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VPP Recognition

When OSHA approves an applicant for participation in VPP, the agency recognizes that the applicant is providing, at a minimum, the basic elements of ongoing, systematic protection of workers in accordance with rigorous VPP criteria.

  • Exemption from General Schedule Inspection. The protection provided by VPP participants should make general schedule inspections unnecessary. Therefore, the site-based employer's approved worksites, mobile workforce, and VPP Corporate employers who work within an approved Designated Geographic Area (DGA), are removed from OSHA's programmed inspection lists (unless the participant chooses not to be removed).
  • Publicity. OSHA publicizes VPP participant successes in a variety of ways, including stories on the agency's website; press releases and other agency media; and recognition during agency speeches and presentations.
  • Symbols of Recognition. The VPP symbols of recognition are plaques and program flags, normally presented at approval ceremonies. The participant also may choose to use the VPP logo on such items as letterhead, shirts, mugs, pins, and magnets.

4. Which of the following is TRUE regarding the VPP exemption from OSHA inspections?

a. Employers will be notified prior to any inspection
b. Only Star participants are not subject to inspections
c. Employers may be removed from the programmed inspections list
d. OSHA continues to inspect, but does not issue citations

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VPPPA

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The Voluntary Protection Programs Participants' Association, Inc. (VPPPA) comprises a global community of dedicated safety and health professionals empowering occupational safety culture across more than 50 industries.

VPPPA is the leading organization committed to occupational safety, health and environmental management systems and has created a complex network of cooperation between companies, the Occupational Safety and Health Administration (OSHA), state OSHA leaders, members of congress, the Department of Defense and Department of Energy. (Source: VPPPA)

For more information on becoming a VPP participant, contact OSHA's Office of Partnerships and Recognition at (202) 693-2213 or the VPP Manager at your OSHA Regional Office.

5. Which organization comprises a global community of dedicated safety and health professionals to empower occupational safety cultures?

a. State Sharp Participant Association (SSPA)
b. VPP Participant's Association (VPPPA)
c. Star Participant Advisory Group (SPAG)
d. VPP Society of America (VPPSA)

Check your Work

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Final Exam

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