Not exactly. Not yet. But it looks like a crisis is brewing.

OSHA chief Dr. David Michaels addressing the Voluntary Protection Program Participants Association meeting last month: “But let me be very clear to you today. We value this program. We want it to continue. But it is very unlikely to continue under the current federal funding formula. The way things stand right now, we believe that the House Appropriations subcommittee is proposing to provide $3 million additional funding to OSHA's budget to fund VPP for FY11, but will be asking for a report on funding alternatives for FY12. The Senate, on the other hand, has cut all funding for the program without any mention of a fee-based system or any other funding sources.

“So, let me say this carefully. The bottom line is that if we are to succeed in saving this program, we -- OSHA and VPPPA together -- need to present a united front on this issue, because in this environment of austere government budgets a fractured fight over VPP risks losing the program entirely. None of us wants that. If OSHA and VPPPA can agree on a road forward, we increase our chances of keeping VPP alive so participants can continue to serve as models for successful worker protection.”

“We have been clear with our Regional staff that while we have eliminated the former annual quotas for new VPP members, we were committed to signing up and reapproving worthy companies. We have heard your complaints that some OSHA regions have not been pursuing new programs and reapprovals aggressively enough and we are seeking to correct that.”

“OSHA and the Department of Labor support the idea of funding VPP through participant fees. While many VPP participants worry that user fees may undermine the integrity of the program, we have reassuring evidence of successful user-fee programs in other agencies.”

Earlier this year, VPPPA chairperson R. Davis Layne urged member companies to “act now and contact our congressional representatives in support of Senate Bill 3257 (S. 3257) to codify the Occupational Safety and Health Administration’s (OSHA) Voluntary Protection Programs (VPP). S. 3257 will not only support and expand the program, especially for small businesses, but it will eliminate the idea of a user-fee system for VPP.”

Stay tuned.