Provide Input on OSHA’s New VPP

OSHA has recently announced that they’re inviting public and workplace safety stakeholders to share their comments to expand its Voluntary Protection Program (VPP), looking for feedback on how the agency can best honor companies who make exceptional commitments to workplace safety and health, while encouraging others to follow.

What is the Voluntary Protection Program?
OSHA's Voluntary Protection Program was established in 1982 to recognize workplaces that demonstrate best practices in safety and health management and serve as industry models 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 the last 40 years, the program has attracted a wide variety of organizations in many industries, although its success has stretched OSHA resources and made it more difficult to ensure the quality of program applicants' safety and health management systems.

How does VPP Membership Benefit Employers?
Statistical evidence for VPP’s success is impressive, and is essential for the program to keep evolving and providing incentives to employers and employees alike. Direct benefits seen from VPP participation include:

• Injury and illness rates at VPP site have been recorded at an average of 52 percent below industry norms per OSHA
• Reduced compensation costs, absenteeism, and worker facing insurance premiums reflected to employees
• Increased employee morale and an improved relationship between labor and management
• Lower worker’s compensation premiums for the company’s worksite
• Direct input into OSHA’s standard setting process, with real life examples to provide from your worksite

Participating VPP workplaces have the opportunity to get sorted into one of three programs based on performance based criteria:

• 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.
• 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.
• Demonstration: Recognition for employers and employees who operate effective safety and health management systems that differ from current VPP requirements. This is a program that enables OSHA to test the efficacy of different approaches.

How to Start Participating in OSHA’s Current VPP
Commentary periods like the upcoming one in April often are the predecessor of several months to even years of debate at the government level to redesign programs like these, so in the meantime, workplace participation in the current model is still possible.

To participate in OSHA’s VPP, 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 even exempt from OSHA programmed inspections while they maintain their VPP status. For online VPP applications, you must meet the following key criteria:

1. You must have a worksite that is in Federal OSHA jurisdiction. If you’re in a State Plan area, then you must apply through your state’s designated VPP manager.
2. Your worksite must have a 3-year average that is below at least one of the past three years of published BLS rates for your industry in nonfatal injuries and illnesses. (Alternative rates can be considered for smaller worksites). Through your online application, you’ll still be scheduled for an on-site inspection to confirm this.
3. If your worksite has ongoing OSHA mandated enforcement activities or investigations you’ll be disqualified from VPP and the application process.
4. If your employees are unionized, you’ll need a signed Union written letter that approves of VPP before your application will be considered.

Further application details are available here at OSHA’s application web page.

The VPP Commentary Questions
By opening the program to public comments, OSHA seeks input from all perspectives to assist the agency as it modernizes and enhances the VPP, and continues to promote the use of workplace safety and health management systems. The Voluntary Protection Program's modernization project is seeking stakeholder input on issues such as:

• Aligning the program more closely with recent occupational safety and health management practices and system standards.
• The general effectiveness of the program and areas that haven’t been working well with recommendations for improvement.
• How the program can contribute to expanding the use and effectiveness of safety and health management systems.
• How the program can offer better incentives to participate or to encourage more types of workplaces to be included.
• Whether and how resources and tools such as “special government employees,” consensus standards, third-party auditors and other methods could serve to expand the program's capacity without compromising effectiveness and oversight.
• Whether particular categories of hazards need special attention in the VPP certification process.
• If OSHA should introduce a tiered approach to the VPP to align extra benefits with the tiers.
• Suggestions for rebranding or renaming the ‘Voluntary Protection Program’.

OSHA’s VPP questions are in 10 sections that are broken down further into some of the above statements to elicit useful responses to support the project's aims. Interested members of the public and EH&S professionals can submit their comments and attachments, identified by Docket No. OSHA-2022-0012, using the Federal e-Rulemaking Portal. The deadline for your comments is April 14, 2023.

Workplace Safety Best Practices
Whether or not you participate in VPP, we understand that the pathway to workplace safety is not exactly the same for every organization. Keep in mind that our team at Clarion Safety is here as your partner in safety; and, we’re able to provide much more than just your safety labels, tags, and signage. You can rely on us to help with:

• Workplace Safety Services for Machine Users: In addition to services for machine builders, we offer machine safety and compliance services for machine users. This includes risk assessment programs and machine safeguarding, functional safety/control reliability, and specialized training for EH&S professionals. Our TUV-certified safety engineers specialize in OSHA, ANSI, NFPA, RIA, and ISO/EN – and are ready to help today!
• A Holistic Approach To Machinery Safety: For OEMs, we can look at your product safety program as a whole, whether that means focusing on the labels you use across a product or product lines – or taking an even wider approach, as we offer services for machine builders, like product risk assessments, manual audits/writing, and CE/UKCA/UKNI mark compliance. Not sure where to start? Try a safety label or sign assessment. You’ll get personalized optimization opportunities for your warnings – free of change, with no strings attached.

If you have questions, contact our team now!

• Standards Insider