Benefits and Application of OSHA s Voluntary Protection Program

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Evelyn Mills
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1 Benefits and Application of OSHA s Voluntary Protection Program Thomas S. Rimel, Jr. Executive Vice President Operations & Development Dunmore Corporation 145 Wharton Road Bristol, PA Phone: Fax: trimel@dunmore.com Website: Abstract: The purpose of this presentation is to share some basic information about OSHA s Voluntary Protection Program (VPP), Dunmore decision to pursue this certification, the preparation for the certification, and the benefits from our participation from the program. Basic VPP Program Description from Dunmore Dunmore has long recognized the importance of strong safety performance and a strong safety and environmental management system. Although our investments had been consistent and significant, we were not achieving the results that we needed as our business continues to grow. The organization looked at our performance (in 2008) and decided on VPP for the following reasons: VPP was a recognized certification that would put us among the best companies with regard to safety and health performance Similar to ISO quality standards, the VPP format would allow us to manage or safety and health activities under one umbrella VPP requires excellent metric performance as a pre-requisite, but requires certified companies to have a more preventative and continuous improvement related approaches The internal and external assessments and audits would drive us to better performance, from both a safety and financial performance perspective The VPP framework would help us to extend the involvement of all Dunmore associates into the process Dunmore looked at all of the elements of the VPP framework and we had them all. We also realized that we needed to make improvements to them all if we were to improve our performance and culture in a significant way.

2 Basic VPP Program Description and Intent from OSHA perspective (adapted) THE VOLUNTARY PROTECTION PROGRAMS CONCEPT VPP is one of several OSHA cooperative programs that encourage private and public sector efforts to improve occupational safety and health. Through VPP, OSHA recognizes workplaces with excellent safety and health management systems and promotes them as model workplaces. The Programs place significant reliance on the cooperation and trust inherent in partnership and complement the agency s regulatory and enforcement efforts. To qualify for VPP, applicants must have in place an effective safety and health management system that meets rigorous performance-based criteria. In addition, applicants must meet all relevant OSHA standards. OSHA verifies qualifications through a comprehensive onsite review process. OSHA approves successful applicants as Star, Merit, or Demonstration participants, and as one benefit of approval offers an exemption from programmed or scheduled inspections. For employers, achieving VPP shows your employees, industry, and community that you are a leader in safety and health. As a model workplace, you demonstrate that a voluntary, cooperative, proactive safety and health partnership of management, labor, and OSHA benefits all parties. AN OVERVIEW OF VPP What is VPP? Working with industry and labor, OSHA created the Voluntary Protection Programs (VPP) in 1982 to recognize and partner with worksites that implement exemplary systems to manage worker safety and health. The managers, employees, and any authorized employee representatives at these sites voluntarily implement comprehensive safety and health programs hereinafter referred to as safety and health management systems that go beyond basic compliance with OSHA standards. Using one set of flexible, performance-based criteria, the VPP process emphasizes management accountability for worker safety and health, continual identification and elimination of hazards, and active involvement of employees in their own protection. These criteria work for the full range of industries, union and non-union, and for employers large and small, private and public. The VPP places significant reliance on the cooperation and trust inherent in partnership. Companies and individual sites choosing to apply for VPP recognition show their commitment to effective worker protection by inviting a government regulator into their workplace. In return, OSHA removes them from programmed inspection lists and does not issue them citations for standards violations that are promptly corrected.

3 Sites qualifying for VPP attain Star, Merit, or Demonstration status. Star participants meet all VPP requirements. Merit participants have demonstrated the potential and willingness to achieve Star status, but some aspects of their programs need improvement. Demonstration participants test alternative ways to achieve safety and health excellence that may lead to changes in VPP criteria. Statistical evidence for VPP s success is impressive. Consistently since the Programs began, the average VPP worksite has had a recordable incidence rate for days away from work, restricted work activity, and/or job transfer (DART rate) about 50 percent below the average for its industry! In VPP, Management commits to operating an effective occupational safety and health management system characterized by four basic elements: Management Leadership and Employee Involvement, Worksite Analysis, Hazard Prevention and Control, and Safety and Health Training. Employees agree to participate in the program and work with management to ensure a safe and healthful workplace. The site submits an application to OSHA that describes its system of worker protection. OSHA evaluates the application. If OSHA accepts it, the agency then conducts an onsite review to verify that the safety and health management system meets VPP requirements. With approval comes OSHA s public recognition of the applicant s exemplary safety and health management system. OSHA also periodically reevaluates the participant to confirm its continuing qualification for VPP. Onsite evaluations are every 2 1/2 to 5 years for Star, 12 to 18 months for Demonstration, and 18 to 24 months for Merit. OSHA removes VPP participants from its programmed inspection lists. VPP Elements The verbal presentation will cover the basic elements of the VPP Program which include the following: Management Commitment and Planning Accountability Disciplinary Program Injury Rates Employee Participation Self-Inspections Employee Hazard Reporting System

4 Accident/Incident Investigation Job Safety Analysis (JSA s) Health & Safety Training Program Preventative Maintenance Emergency Program & Drills PPE Program Health & Safety staff involved with changes Contractor Safety Medical Program Resources of the Health & Safety Department Annual Self-Evaluation Preparation for the VPP Application and Audit Process Much like the decision to formalize any business or operational process, it is a major commitment of time and resources. Dunmore invested about 18 months preparing for the application and about $500 per associate (total cost) to achieve the certification. Although each company will follow their own process, Dunmore had good results with the following approach: Work with internal safety leadership and OSHA directly (local region) to understand the process and the program in more detail Perform a GAP analysis of current systems/performance to VPP requirements Decide to Achieve Certification / Management Commitment Plan to Resource People (6-8), Time (24 months), Money Select Cross Function Team Make it a priority official goal/objective for individual and departments Select a champion train the champion Construct a project plan with major milestones. Full team should meet monthly at minimum with sub-teams meeting weekly Activities should be SMART and tied to a responsible person (Specific, Measurable, Attainable, Relevant, Time Stated) Build in Flexibility because in all projects there are unexpected developments, be ready. After preparation is done allow days for final application preparation (use the application template to drive work of the team) Submit the application and prepare for the on-site audit Audit Process The presentation will cover the major components to completing the OSHA on site audit process. Major steps of the process include: Application Review, Finding, Schedule on-site audit Opening Meeting

5 Document Review Plant Tours / Inspections Daily Wrap Ups and Objectives (findings) Individual Interviews Group Interviews Closing Meeting Formal Notification of Certification The audit is similar to a quality or financial audit in duration and intensity. After our initial experience, Dunmore recommends the following specific actions: Entire team ready to participate in the audit For every OSHA or SGE 1 Lead from your team Fix minor findings On the Spot Have Maintenance Ready and some key contractors/vendors Strong Team and Management Attendance to OPEN and CLOSE Meeting End of day wrap up Full team participation Leads to take good notes provide prompt follow-up Interviews (individual and group) likely use judgment to attend select interviews Dunmore Results Credit for Dunmore results go to all Dunmore associates and partners who lead in the area of safety everyday at home and in the workplace. The VPP certification is not solely responsible for our success to date, but has been a good framework to make sure we are aggressively improving both our systems and our performance. Best historical safety performance in 3 year period The culture is slowly improving this is a process Dunmore s PA facility STAR certified, application process underway for NY facility EH&S management is improving VPP program gives the format and the discipline Good recordable rates, low LTA, significantly more employee involvement Reduced WC costs and other costs associated with injuries (award 2 of 3 years) Our associates made the difference during the audit process More than 50% of our resources are now spent on predictive and preventative programs vs. reacting to incidents and injuries Near Miss Program enhanced with more than 80 near misses every month Behavior based observation program yielding more than 300 job based observations every month

6 Incident Rate Corporate OSHA Incident Rate

OSHA s Voluntary Protection Program (VPP) To Journey or Not to Journey, That is the Question

OSHA s Voluntary Protection Program (VPP) To Journey or Not to Journey, That is the Question Autumn (not fall) 2011 Objectives for this Presentation Information about the VPP Certification, Requirements,