1. OSHA Voluntary Protection Programs OSHA Region III T he VPP Elements An Overview December 2006 Peter Brown Region III VPP Outreach Coordinator

2. Criteria I: Management Leadership & Employee Involvement u July 2000 Federal Register Notice, Description of the Voluntary Protection Programs, Source of VPP Requirements u Management Commitment u VPP Commitment u Planning u Written Safety & Health Program u Top Management Leadership

3. Criteria I: Management Leadership & Employee Involvement (cont’d) u Authority & Resources u Line Accountability u Contract Workers u Employee Involvement u Safety & Health Management System Evaluation

4. Criteria I: Management Leadership & Employee Involvement (cont’d) u A Closer Look u Management Commitment u Clearly established policies that have been communicated to & understood by all employees. u Established goals and objectives for meeting the goals. u VPP Commitment u Management must clearly demonstrate commitment to meeting & maintaining VPP requirements

5. Criteria I: Management Leadership & Employee Involvement (cont’d) u Planning u Planning for safety & health must be a part of the overall management planning process. u Written Safety and Health Program u Written program must include all 4 Criteria elements of the VPP. u Federal Agencies must also meet requirements for 29 CFR 1960

6. Criteria I: Management Leadership & Employee Involvement (cont’d) u Top Management Leadership: Managers must provide visible leadership by u Establishing clear lines of communication. u Creating an environment that allows for reasonable employee access to top site management. u Setting example of safe & healthful behavior. u Ensuring all workers, including contractors, are provided equally high quality safety & health protection. u Clearly defining responsibilities in writing.

7. Criteria I: Management Leadership & Employee Involvement (cont’d) u Authority and Resources u Commensurate authority must be given to those with safety & health responsibilities. u Site must ensure adequate resources to those with responsibility & authority. u Line Accountability u Must hold managers, supervisors, & non-supervisory employees accountable through a documented system.

8. Criteria I: Management Leadership & Employee Involvement (cont’d) u Contract Worker Coverage u All contractors and subcontractors, whether in general industry, construction, maritime, or federal agency sites, must follow worksite safety and health rules and procedures applicable to their activities while at the site. u VPP Sites are expected to encourage contractors to develop effective safety and health program management systems. u VPP site contractor programs must include a documented oversight and management system that ensures the contractors’ site employees are provided effective protection.

9. Criteria I: Management Leadership & Employee Involvement (cont’d) u Employee Involvement u The site culture must enable & encourage effective employee involvement in the planning & operation of the safety & health programs, & in decisions that affect employees’ safety & health. u In accordance with the FRN, there must be a minimum of three ways employees can be involved in addition to notifying management of unsafe conditions.

10. Criteria I: Management Leadership & Employee Involvement (cont’d) u Safety & Health Program Evaluation (the Annual self- assessment) u The site must have a system for annually evaluating the operation of the safety & health program. u The system will judge the site’s success in meeting the programs’ goals & objectives & assist those responsible for determining & implementing changes for continually improving worker safety & health protection.

11. Criteria I: Management Leadership & Employee Involvement (cont’d) u The annual evaluation system must include u A written, narrative report. u Recommendations included for improvements. u Assignment of responsibility. u Documented timely follow-up. u OSHA recommends it should follow the “Suggested Format for Annual Submissions” Appendix D of the VPP Policies and Procedures Manual, published by OSHA and found on OSHA’s webpage www.osha.gov -scroll down to VPP. u In VPP construction, an additional program evaluation must be conducted prior to completion of job.

12. Criteria II: Worksite Analysis u Management Understanding u Baseline Industrial Hygiene evaluations u Pre-use Analysis u Hazard Analysis u Routine Inspections u Employee Hazard Reporting System

13. Criteria II: Worksite Analysis (cont’d) u Accident/Incident Investigations u Trend Analysis DART ( Severity Rate)

14. Criteria II: Worksite Analysis (cont’d) u Management Understanding u Management of safety and health programs must begin with a thorough understanding of all hazards and unsafe conditions/behaviors to which employees may be exposed, and the ability to recognize and correct all hazards as they arise. u Industrial Hygiene u Program must include a site wide, baseline identification of health hazards and employee exposure through an industrial hygiene sampling rationale and strategy. u All sampling, testing, and analysis should be conducted using nationally recognized procedures and protocols, with maintenance of documented results.

15. Criteria II: Worksite Analysis (cont’d) u Pre-Use Analysis u All newly acquired or altered facilities, processes, materials, equipment, and/or phases must be analyzed before use begins to identify hazards and the means for their prevention and control. u Hazard Analysis u The site must perform routine examination and analysis of safety and health hazards associated with individual jobs, processes, or phases. u May Include JSAs, JHAs, PHRs, etc. u The results must be included in training and hazard control programs.

16. Criteria II: Worksite Analysis (cont’d) u Routine Inspections (self-audits) u The site must have a system for conducting routine self-inspections, preferably involving employees. u System must include written procedures/guidance, and must result in written reports of findings and tracking of hazard elimination or control to completion. u In general industry, federal agencies and maritime, these inspections must occur at least monthly and cover the whole worksite at least quarterly. u In construction, these inspections must cover the entire worksite at least weekly.

17. Criteria II: Worksite Analysis (cont’d) u Employee Hazard Reporting System u The site must have a written, workable system employees may use to notify management of unsafe conditions, behaviors, safety and any health related issues, questions, observations. u System must include timely and appropriate responses, and be free of discrimination or retribution. u The system must include tracking of responses and tracking of hazard elimination or control to completion.

18. Criteria II: Worksite Analysis (cont’d) u Employee Hazard Reporting System (cont’d) u The system should also have a component which allows employees to make anonymous reports of conditions appearing hazardous. u The system should allow for responding to anonymous reports using employee bulletin boards, newsletters, etc.

19. Criteria II: Worksite Analysis (cont’d) u Accident/Incident Investigation System The system must: u Include written procedures/guidance. u Include written reports of findings. u Include hazard elimination or control tracking to completion. u Procedures should also be included for investigation of near misses. u The investigations should seek out root causes for the accident/incident, fix the cause, not the blame.

20. Criteria II: Worksite Analysis (cont’d) u Trend Analysis u The program must include analysis of data and information for trending and pattern analysis. u Information that might be used in trending includes, injury/illness history, hazards identified during inspections, employee reports of hazards, accident/near miss investigations, body parts, departments, business cycles, etc.

21. Criteria III: Hazard Prevention and Control u Certified professionals as a resource u Hazard Elimination and Control including: u Engineering Controls u Administrative Controls u Safety and Health Rules u Hazard Control Programs u Personal Protective Equipment (PPE)

22. Criteria III: Hazard Prevention and Control (cont’d) u Process Safety Management u Occupational Health Care Program u Preventive Maintenance u Hazard Correction Tracking u Disciplinary System u Emergency Preparedness

23. Criteria III: Hazard Prevention and Control (cont’d) u Hazard Controls u Site hazards identified during and through the hazard analysis process must be eliminated or controlled by developing and implementing the systems discussed in this section. The Hierarchy of Controls. u The hazard control methods a site chooses to implement must be understood and followed by affected parties, and appropriate to the hazard and size of the worksite.

24. Criteria III: Hazard Prevention and Control (cont’d) u Certified Professional Resources u The site must have adequate access to certified safety professionals (CSP), certified industrial hygienists (CIH), other certified professionals. u Hazard Elimination or Control u The following hierarchy should be used in selecting actions to eliminate or control hazards:

25. Criteria III: Hazard Prevention and Control (cont’d) u Engineering Controls - Most reliable and effective, best practices. u Administrative Controls - Significantly limit daily exposure to hazards by controlling or manipulating the work schedule or manner in which work is performed, e.g., job rotation, change shift duration, etc. u Work Practice Controls - Includes workplace rules, safe and healthful work practices, and procedures for specific operations. u Personal Protective Equipment u Hazard Control Programs - Includes, but is not limited to, control of hazardous energy (lock out/tag out), confined space entry, hazard communication, respiratory protection, hearing conservation, blood borne pathogens, fall protection, etc.

26. Criteria III: Hazard Prevention and Control (cont’d) u Process Safety Management- as applicable u For sites meeting the threshold requirements for coverage outlined in 29 CFR 1910.119, appendix A, of OSHA’s Process Safety Management Standard. u Preventive Maintenance System u System must be written, and document the monitoring and maintenance of workplace equipment such as: u Preventive and predictive maintenance, to prevent equipment from becoming hazardous.

27. Criteria III: Hazard Prevention and Control (cont’d) u Hazard Correction Tracking u The site must have a formal system for initiating and tracking hazard identified through the various safety and health programs, in a timely manner. u Occupational Health Care Program u The program must include Licensed health care professionals to assess employee health status for prevention of and early recognition and treatment of injury and illness. This in conjunction with the IH program, Health care professionals should be involved with site self-audits and inspections.

28. Criteria III: Hazard Prevention and Control (cont’d) u Occupational Health Care Program (cont’d) u Access to certified first aid and CPR providers on all shifts, u Access to physician care, and emergency medical care. u Disciplinary System u Must be written and must be clearly communicated and equitably enforced.

29. Criteria III: Hazard Prevention and Control (cont’d) u Disciplinary System (cont’d) u Include procedures for disciplinary action or reorientation of: u Managers, supervisors, non-supervisory employees who: u Break or disregard safety and health rules, safety work practices, proper material handling, or emergency procedures. Must be documented.

30. Criteria III: Hazard Prevention and Control (cont’d) u Emergency Response Program and Procedures u Emergency procedures must be developed for all shifts worked. u Must be written and communicated to all, including outside contractor and temporary employees. u Must list requirements for PPE, first aid, medical care, emergency egress. u Must include provisions for emergency telephone numbers, exit routes. u Must include training drills including, at a minimum, annual evacuation drills.

31. Criteria IV: Safety and Health Training u Emergency Procedures u Supervisors/Managers u Employees u Emergencies u PPE

32. Criteria IV: Safety and Health Training (cont’d) u Managers and Supervisors u Understand their safety and health responsibilities as discussed in Criteria I: Management Leadership and Employee Involvement, and are able to carry them out effectively. u Managers, Supervisors, and non-supervisory employees including contractors u Are made aware of and taught how to recognize hazards, unsafe conditions, and the signs and symptoms of workplace-related illness.

33. Criteria IV: Safety and Health Training (cont’d) u Managers, Supervisors, and non-Supervisory employees including contractors u Must learn safe work procedures to follow in order to protect themselves from hazards. u Training includes reinforcement and includes reviews of procedures to notify supervision of hazards. u Emergencies u Managers, Supervisors, and non-supervisory employees including contractors, and Visitors must understand what to do in emergency situations.

34. Criteria IV: Safety and Health Training (cont’d) u Personal Protective Equipment u Where PPE is required, employees understand that it IS required, why it is required, its limitations, how to use it, and how to maintain it. u Managers, supervision, employees, outside contractors, and visitors use PPE properly.

35. The End and the Beginning This presentation may be copied, and distributed by anyone. This document creates no new OSHA requirements. Region III is Pennsylvania, West Virginia, Virginia, Delaware, Maryland, and the District of Columbia. Peter Brown brown.peter@dol.gov The Philadelphia Regional Office