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6.4 OSHA Voluntary Protection Program

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The VPP is a government‐based management system approach managed by the OSHA in the United States. Numerous state‐operated OSHA programs have developed state‐operated VPPs. This program contains several components, including the actual VPP approach language and a certification scheme operated by OSHA. The term “VPP approach language” is used instead of “standard” since in OSHA nomenclature, the VPP is not a standard, but in the context of discussing other management system approaches such as ISO 45001, OHSAS 18001, the ILO OHSMS, and ANSI Z10, one can think of VPP as equivalent to an OHSMS standard.

The VPP approach began in California in the late 1980s as the result of regulatory actions at the San Onofre power generating facility. It has evolved to represent the most comprehensive OH&S management system approach within OSHA and encompasses elements of other systems approaches in OSHA, such as the 1989 OSHA OH&S Program Management Guidelines (11), Consultation's SHARP/form 33 (74), the defunct Performance Evaluation Profile (PEP) (75), and the draft OHS program standard (20).

For certification, the OSHA VPP site inspection team verifies OHS program adequacy in the following six areas (5):

1 Management Commitment and Planning

2 Work site Analysis

3 Hazard Prevention and Control

4 Safety and Health Training

5 Employee Involvement in Program Evaluation

6 Annual Evaluation of Safety and Health Program

The site review team balances all available site information, including employee interviews, to determine if systematic management procedures that address hazard assessment, prevention and control are being effectively implemented. The site inspection team's findings are reviewed by OSHA management personnel who, typically were not involved with the on‐site review. This Administrative Review is the last step in the process. Those companies that satisfy the above requirements become VPP “Participants” (76).

The organization's management receives a letter from the Assistant Secretary of Labor congratulating them on being awarded VPP status. Furthermore, these companies are “rewarded” by receiving immunity from programmed OSHA inspections. OSHA may still inspect VPP sites in response to employee complaints, fatalities, significant chemical releases, or catastrophes. Most sites are reevaluated every three years to ensure they are continuing good management practices and following the VPP requirement.

There is a hierarchy of VPP achievement recognition, with the designations Star, Merit, and Demonstration. Sites awarded Star status generally have safety and health programs that are recognized as comprehensive and effective. The Merit designation is provided to those work sites with the potential to be Star but may have some minor health and safety program elements to be corrected. For example, OSHA may elect to give Merit status to a company with an overall good health and safety program but whose illness and injury rates have yet to drop below national averages. The third award is the Demonstration designation. Demonstration status may be awarded to companies that are not construction or general industry oriented, such as maritime or agriculture businesses. Merit and Demonstration sites receive annual onsite inspections (12).

The VPP criteria contain a number of best practices that can lead to superior safety and health performance. Certain elements are strong, such as employee involvement. Other elements that would make it a complete management system are weaker such as management review and continual improvement aspects. OSHA VPP gets employees involved in safety and health management unlike traditional OSHA approaches.

Patty's Industrial Hygiene, Program Management and Specialty Areas of Practice

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