- ISHN GLOBAL
- EHS RESEARCH
Considering and completing the application process to the OSHA Voluntary Protection Program can be daunting. The application itself can seem lengthy and confusing, not to mention the big change in mindset required: Many safety professionals spend their days working to keep OSHA out of their facilities, and now must entertain the idea of inviting them in. Luckily, once a company has the line and management commitment to pursue VPP, there are a number of resources available to help, not least of which is the experience of companies who have been there, done that.
Following are some strategies that helped one company achieve OSHA VPP Star status.
Note that a number of states have their own OSHA-approved state safety and health plans. These states may have VPP-type cooperative programs that differ from federal OSHA VPP. Although many of the following concepts can be applied to either type of plan, the website references included to below are federal OSHA.
1) Assess your readiness
A great first stop for those considering VPP is the OSHA website, www.osha.gov. The VPP section contains a number of useful reference documents and templates. We used their Self-Assessment Checklist to assess readiness for application, which includes making sure historical incident rates meet established criteria. The checklist also describes the “Four Basic Elements” that are evaluated when a company applies to participate in VPP:
• Management Leadership and Employee Involvement
• Worksite Analysis
• Hazard Prevention and Control
• Safety and Health Training
If incident rates are acceptable, and employees are comfortable with the “four basics,” it’s time to begin the application process. The application template can also be found in the VPP section of OSHA’s website.
2) Your written evaluation
In addition to completing the VPP application, we conducted a written evaluation of the site safety program using the OSHA Annual Safety and Health Self-Evaluation template as a guide. OSHA requires VPP sites to submit a self-evaluation of their safety program annually, and this is the format that is recommended for the submission.
We were required to have two years of annual self-evaluations completed before our application would be considered, so this was a time-influencing factor. But because the annual evaluation does not necessarily have to be in the OSHA-recommended format for pre-inspection sites, an annual evaluation that has previously been completed may be an acceptable substitute. Note, however, that physical worksite inspection checklists alone are typically not adequate, as the OSHA annual evaluation calls for narrative program assessments, as well as goal- and objective- setting for improvement, and documented follow-up.
3) Your onsite review
Once an application is reviewed and accepted by OSHA, an onsite review will be scheduled. Over several days, a small team of auditors will glean information via three methods: observation, documentation, and interview.
Observation: Site compliance with OSHA regulations will be observed through physical inspection. One of the questions OSHA will answer is, “Did the VPP team find hazards that should have been found through self-inspection?” So it’s important to perform a thorough physical inspection of the facility prior to the onsite team’s arrival. It’s also a good idea to review past self-audits and safety meeting minutes to make sure that all noted hazards have been cleared. And of course, a clean facility always makes a good first impression.
Documentation: We found documentation to be a key component of VPP participation â€” daily walkthroughs, inspections, meeting minutes â€” anything that was not documented or observable was suspect of actually having occurred. We made sure our filing system was well-organized so that we could easily locate any documents that the onsite team requested, and prepared a three-ring binder of documents that the onsite review team would likely be asking to see.
Interviews: The thought of sitting down one-on-one with an OSHA inspector and answering questions can be intimidating for employees. They might worry that a wrong answer from them will jeopardize the entire VPP endeavor or get them in hot water with their boss. A list of recommended interview questions can be found on the OSHA website, and we found it helpful to review these with employees. We asked employees not to worry about giving the “right” answer, or saying what they think OSHA would want to hear, but instead to simply answer honestly. We also let them know that it was acceptable to say they didn’t know the answer if asked a question outside their area of knowledge.
As we prepared for the onsite review, we developed two orientation programs, one for our employees and one for the OSHA onsite review team.
For employees: OSHA’s website provides a resource entitled, “What happens when the VPP Team comes onsite?” We reviewed this document with employees so everyone would know what to expect.
For OSHA: We worked with both line and management employees to create an orientation presentation for the onsite review team. The presentation included information such as:
• Alarm descriptions, evacuation routes, and muster points;
• Review of personal protective equipment requirements;
• A site organizational chart to introduce the facility’s team;
• An overview of our manufacturing process and plant layout;
• Our commonly-used chemicals and their hazards;
• Intellectual property protections, such as photography restrictions.
5) Mental preparation
Stay cool. It’s not so much about the climate, it’s the attitude.
After all of the hard work involved in preparation for the onsite inspection, it can be difficult hear criticism, no matter how constructive or minor.
As an example, we had neglected to label a sampling port on a tank as “Confined Space-No Entry,” thinking it was too small of an opening to require marking. OSHA pointed this out to us, noting that while it was not a large enough opening for bodily entry, an employee could stick his head inside. One of our employees remarked, “Well maybe we should label the toilet, because I could stick my head in there, too.”
Everyone had a good laugh and the frustration level that had been building was diffused with humor. A missing label or sign can seem like an insignificant point, but it’s also a very easy fix. Prepare your employees for the inevitability that corrective actions will be recommended during the onsite inspection, and that this is expected and acceptable.
6) Use other resources
Regional Voluntary Protection Program Participants’ Associations (VPPPAs) are a valuable resource. They offer mentoring opportunities and periodic application workshops where companies considering applying to VPP can get tips on completing the application, see examples of completed applications, and network with employees from area VPP sites.
OSHA’s website also provides a link to find a site’s local VPP coordinator. This liaison can provide information such as how long the application review process might take and if there is any backlog in scheduling onsite reviews.
One final note: We took the “Employee Involvement” aspect of the Four Basic Elements very seriously and decided that each site’s participation in VPP should be an employee-driven endeavor. Although our safety and management leadership encouraged involvement with VPP, the ultimate decision to pursue Star status was left to each facility’s team, and we believe that this commitment was critical to their success.