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Department of Defense Voluntary Protection Programs Center of Excellence Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense Department of Defense Voluntary Protection Programs Center of Excellence VPP Criteria for Annual Evaluation of the Safety and Health Program
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Objectives Understand how the VPP self-evaluation requirements compare to your written safety and health program Understand how to assess your program Discuss the importance of the annual self- evaluation Understand how the e-tool can assist in the annual self-evaluation process
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Have You Ever Felt Like This When Writing Your Annual Program Review For OSHA?
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Annual Safety and Health Program Evaluation Overview What it is –A quality evaluation is critical for planning and checking on the progress of your safety and health program - Plan, Do, Check, Act –A continuous improvement measurement for all elements and sub-elements of VPP What it is not –An inspection of the worksite – A brief report pointing out hazards or saying everything is okay
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Annual Submission Requirements When Is It Due –February 15 of each year What Is Due –Applicable contractor’s injury and illness (I&I) rates for work conducted on your site, your employees’ I&I rates, average number of employee’s and hours worked for previous calendar year –Copy of most recent evaluation –Description of significant changes/events –Progress made on previous year’s recommendations –Success Stories
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Written Instructions vs. VPP Requirements DoD 6055.1 AFI91-301 AR 385-10 –DA PAM 385-10 ARNG 385-10 DLAM 6055.1 MCO 5100.8F Navy 5100 23g USACE 385-1-1
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VPP Requirements Management Leadership and Employee Involvement Worksite Analysis Hazard Prevention and Control Safety and Health Training
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Gap Sub-element #40 Overall Sub-Element Questions Safety and Health Program Evaluation H3. Does the annual evaluation include written recommendations in a narrative format? H4. Is the annual evaluation an effective tool for assessing the success of the site’s safety and health system? Please explain H5. What evidence demonstrates that the site responded adequately to the recommendations made in the annual evaluation? Stage 1 H3. A baseline evaluation of the installation's entire S&HMS has been conducted using the evaluation procedures developed and a report in narrative form has been produced. Stage 2 H4 & 5. Annual reports (including the baseline) identify the strengths and weaknesses of the installation's S&HMS, specific actions and recommendations, assignment of responsibilities and timeframes for corrective actions, and actions taken to satisfy the action items and recommendations. Stage 3 H4. A follow-up S&HMS evaluation is conducted no more than 12 months after the baseline and at least two S&HMS evaluations have been conducted prior to applying for VPP.
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Management Leadership and Employee Involvement (ML&EI) Top Management Leadership and Employee Involvement Policies, Goals, and Objectives Planning and Resources Responsibilities and Accountability Active Employee Involvement Contractor Worker Coverage
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ML&EI Example I. Management Leadership and Employee Involvement e. Management Leadership – Establishing clear lines of communication with employees; setting an example of safe and healthful behavior; reasonable access to top site management. Program Description: The plant manager and all managers are encouraged to participate in committee meetings when invited since the committees are made up and run by employees. Also, safety is always the first topic discussed during monthly employee meetings. The Plant Manager makes regular visits to the work area to visit with employees regarding safety and health issues and gages their satisfaction. An open door policy is used to ensure employee access to top management and has been used several times over the last year. Managers are required to demonstrate leadership by always wearing appropriate PPE regardless of the amount of time in the work area. Evidence of this is demonstrated by the reporting of a supervisor for not wearing safety shoes and action taken by the Plant Manager. Assessment of Effectiveness: This requirement meets all VPP requirements and is judged to be effective. Recommendations for Improvement: Managers have only attended about half of the committee meetings for which they were invited. Top management needs to make it clear to all management employees that attendance is very important and she be exercised whenever possible. A new policy letter will be distributed immediately and discussed with managers during the next weekly staff meeting. Owner(s): Plant Manager. Target Date for Completion: February 28 th, 2011
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Worksite Analysis Pre-Use Analysis Surveys Industrial Hygiene Sampling Hazard Analysis Routine Inspections Written Employee Reporting System Accident Incident Investigation Trend Analysis – Leading and Lagging 7 arm 3- eye 11- ankle 6-Leg 7- Hand 6-Back
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Worksite Analysis Example Element: B. Worksite Analysis Sub-element: 6. Written Employee Hazard Reporting System Goals: A.2007 Activities: The Enterprise Safety Application Management System (ESAMS) is an electronic database used for recording, storing, tracking and reporting safety and occupational health information. Employees have the ability to report Unsafe/ Unhealthful Working Conditions via ESAMS, in writing, or orally. Blank Unsafe/Unhealthful Working Condition Report forms (OPNAV 5100/11) are readily available throughout the workplace. Employees may report hazards anonymously. Employees may report via their supervisor, union representative, the Safety Department, the Commanding Officer, or directly to OSHA. Most employees choose to report orally to their immediate supervisor, as this has proven effective in getting potential hazards immediately corrected. Reports submitted in writing, ESAMS, or orally are replied to within 3 days or less, depending on the seriousness of the hazard. B. Evaluation of sub-element: This sub-element is effective. A review of the mishap reports do not indicate any unsafe conditions that if previously identified could have prevented the mishap. C. Recommendations for improvement: No major changes needed, however the Safety Office needs to do a better job recording hazards that are reported via telephone. All reported hazards are immediately addressed and are normally completed on-the-spot or within a few days depending on the nature of the hazard. A written log is maintained to ensure tracking and abatement, however not all hazards reported orally are getting recorded. A procedure and hazard reporting sheet will be developed to capture data that is reported via telephone. D. Assignment of responsibility: Sam Safety, Safety Specialist E. Target date for completion: March 2011
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Hazard Prevention and Control Hazard Elimination and Control Initiating and Tracking System Preventive and Predictive Maintenance Occupational Health Care Program Emergency Procedures Engineering, Administrative, Work Practice Controls Personal Protective Equipment Hazard Control Programs
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Hazard Prevention and Control Example Element: C. Hazard Prevention and Control Sub-element: 9. Personal Protective Equipment Goals: A. 2007 Activities: Workplace Assessments are conducted by Industrial Hygienists, Supervisors and Safety Department personnel to determine if hazards are present in the workplace that warrant the use of PPE. These assessments are conducted for all processes/operations to determine PPE requirements, with the understanding that PPE is not a desirable substitute for administrative or engineering controls. Department Heads/supervisors ensure that hazard signs are posted at entrees to hazardous areas and that employees used proper PPE. PPE is furnished by the employer at no cost to the employee. Supervisors and employees are trained in the use of PPE and understand that PPE is a “last line of defense” and does not actually eliminate the hazard itself. An overview regarding the importance of PPE and its usage is included in the New Employee Orientation. B. Evaluation of sub-element: This sub-element is effective. C. Recommendations for improvement: No major changes needed.
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Safety and Health Training Managers Supervisors Non-Supervisory Employees Contractor Employees Visitors Emergencies PPE Safety and Health Rules
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S&H Training Example Element: D. Safety and Health Training Sub-element: 2. Supervisors Goals: A. 2007 Activities: Supervisors were provided training from the Safety Department and/or ESAMS that enabled them to recognize unsafe and unhealthful working conditions and practices in the workplace, as well as provided them with handouts necessary to manage their programs at the work unit level. Supervisory training also included a brief overview of hazard identification and analysis, enforcement of standards, mishap investigation, the use and maintenance of PPE, hazardous materials, lockout/tagout, confined space, etc. In 2007, 63% of the supervisors were trained in Safety Training for Supervisors. Newly appointed supervisors are required to attend this training within 180 days of their appointment. B. Evaluation of sub-element: This requirement meets all VPP requirements and is judged to be effective. C. Recommendations for improvement: Special emphasis will be placed on ensuring all supervisors complete required training. D. Assignment of responsibility: Executive Officer/Director E. Target date for completion April 15, 2011
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These categories enhance what was originally filled out on the OSHA application.
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Tools VPP CX Gap Analysis and Action Plan: – Assigns accountability – Establishes timelines – Documents specific actions a site may take. Electronic application (e-VPP) management tool helps to: – Assign stakeholders responsibility for elements or sub-elements – Facilitate hierarchical review and feedback. – Living Document 1818 / 2 2
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Qualities of a Good Evaluation Honest, critical, objective and comprehensive Conducted in a timely manner Analyzes all VPP elements and sub-elements in accordance with Appendix Focuses on leading indicators while reporting required lagging indicators (TCIR and DART) Sets challenging & attainable goals for upcoming year Celebrate successes and openly discusses shortcomings Provides a detailed action plan to accomplish objectives –E-tool capability Relies on quantitative metrics
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Food for Thought Ask Yourself –Does my safety and health program align with VPP –Do I have a process in place to evaluate all the elements and sub-elements of VPP –Is my safety and health program effective –Am I using the e-tool to it’s maximum capability in capturing data for my annual self evaluation
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