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OSHA proposes VPP for construction firms

OSHA has launched "VPP for Construction" (VPPC) to allow more construction companies to enter the Voluntary Protection Program. Until now, many construction firms were not able to participate, mainly due to eligibility requirements based on the culture of fixed workplaces.

"OSHA has crafted a program we believe will maintain VPP’s high performance standards while, at the same time, respond to the (construction) industry’s unique needs," said OSHA chief John Henshaw.

VPP for Construction is a shift away from an exclusively site-based focus, explained Henshaw. It will open VPP to a broad range of previously ineligible employers — subcontractors, general contractors with short-term projects, mobile workforce employers, specialty trade contractors, and construction managers.

VPPC joins “VPP Corporate Pilot” and “OSHA Challenge Pilot” (both launched last May) as the newest member of OSHA’s premier cooperative program that recognizes and promotes effective health and safety management systems.

The agency is seeking public comment on the VPPC proposal, which has been published in the Federal Register.

The core of the construction initiative continues the VPP focus on effective safety and health management systems. It mirrors general VPP design by offering participation at either the Star or Merit level.

A departure from general VPP set-ups creates two categories of participation — one for long-term, site-based construction projects, and the other for companies, divisions and other business units that employ mobile workforces and work at various sites or projects not always controlled by the participant.

This is how it works:

  • Applications will cover the work an applicant is “contractually responsible for” instead of a specific site the applicant controls.

  • Companies, divisions or business units (C/D/BU) will apply for approval within a defined geographic area. The current proposal is for an area no broader than state-wide, with the option to expand after initial approval if OSHA’s regional administrator and the participant agree that this is appropriate.

  • OSHA will conduct a corporate onsite evaluation, including review of C/D/BU-wide safety and health management policies and procedures, and corporate safety and health oversight strategies.

  • Then OSHA will conduct on-site evaluations for a representative sample of work. The number of on-sites will depend on the number of sites/projects operating within the defined area.

  • During these visits, if the walk-through and employee interviews indicate that the safety and health systems are working well, OSHA will propose to do an abbreviated review.

  • OSHA has added quarterly updates to the requirement for annual reports to OSHA.
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