In early spring of this year, OSHA announced that it was “seek(ing) input from all perspectives to assist the agency as it modernizes and enhances the Voluntary Protection Program (VPP) and continues to promote the use of workplace safety and health management systems (SHMS).”
In particular, OSHA is seeking input to improve the program’s functionality, reduce barriers for entry into the VPP and identify opportunities to expand the program’s use beyond the current crop of participants.
On the surface, it appears that OSHA is seeking to engage stakeholders in a major reimagining of how VPP — one of the most successful cooperative programs in the agency’s 50-plus year history — is structured and administered.
But why? When VPP was established in 1982, the concept of a “total” SHMS that included management commitment guided by employee involvement in crafting a company’s safety program and culture, was still in its infancy. OSHA was viewed as an enforcement agency — VPP was the first real cooperative program created by the agency, with its compliance assistance efforts only ramping up towards the end of the decade.
While VPP has been tweaked over the past 40 years, it remains rooted in the core principles of its creation. Modern safety and health practices, and resources, have evolved to help companies and sites as they seek to achieve safety excellence. Consensus standards like ISO45001 and ANSI Z10, and evaluation tools such as ABC’s Safety Training Evaluation Process, are now widely used. The pool of talented Environmental Health Safety and Sustainability (EHS&S) professionals, and the training they receive, has grown exponentially thanks to the efforts of groups like the Board of Certified Safety Professionals and the Health and Safety Council.
OSHA recognizes the opportunity to shape the future of VPP — and modern safety and health management systems — is now.
VPPPA has prepared a comprehensive background document on OSHA’s website that examines the organization’s VPP Modernization Survey questions. OSHA’s focus is on:
- Measuring SHMS effectiveness
- The role of SHMS consensus standards and evaluation tools in VPP qualification
- Using third-party organizations and safety professionals in VPP reviews.
High-performing companies and sites have long held that lagging indicator performance is not necessarily indicative of an exceptional EHS&S program; to that end, pivoting VPP to deemphasize those indicators and focus more on leading indicator use and performance to evaluate applicants must be considered.
SHMS consensus standards and SHMS evaluation tools, like those mentioned earlier, contribute significantly to raising the bar for a safe and healthy workplace. VPPPA is partnering with OSHA and other EHS&S organizations to develop a comprehensive crosswalk to identify areas in these SHMS tools that correspond to VPP’s key elements and sub-elements. This, in turn, will streamline the entry process into VPP for sites or companies using these tools.
It’s widely accepted that, in order to grow VPP, we must find a way to ease the administrative burden of the program’s application and review process. However, the solution to this issue already exists in the form of the Special Government Employee (SGE) program. At present, the more than 1,000 active SGEs aid OSHA personnel for the onsite audits conducted every three years. These audits are led by OSHA and should continue in this regard but SGEs should be afforded the opportunity to play larger roles in the application review process, annual self-evaluation reviews and recertification processes.
OSHA’s VPP continues to set the standard for total safety and health management systems, and as a result the contributions that VPP sites and companies make to the evolution of safety and health in the workplace raise the standard for everyone. It’s time to do our part to help OSHA shape this critical cooperative program’s next 40 years.
After all, continuous improvement is what it’s all about.
For more information, visit vpppa.org.
