If You've Underestimated the Business Benefits of OSHA's VPP Program, Think Again

OSHA celebrated its 40th birthday this year. And to commemorate the milestone, Assistant Secretary of Labor Dr. David Michaels gave some excellent remarks at the Center for American Progress in April.¹ The Occupational Safety and Health Act, created by President Nixon and Congress 40 years ago, recognized that workers deserve workplaces free of hazards and that many workplace injuries, illnesses and fatalities are preventable and not just “acts of God.” President Nixon described the Occupational Safety and Health Act as “…one of the most important pieces of legislation… ever passed…” Dr. Morton Corn, appointed as secretary of labor by President Ford, went even further, stating the OSH Act was “a new right in the Bill of Rights—a right to a safe and healthful workplace.”

The take-away message for us from Dr. Michaels’ remarks: The evidence is in, and OSHA has made significant strides in ensuring that all workers have the basic human right to a safe workplace. Consider these statistics cited by Dr. Michaels:

• Work-related deaths are down from about 14,000 in 1970 to 4,400 in 2009.
• Reported injuries and illnesses are down from 10.9 incidents per 100 workers in 1972 to less than 4 in 2009.
• Worker exposures to asbestos, lead and benzene have been dramatically reduced following enactment of specific OSHA standards in recent years.

Clearly, progress has occurred. But 4,400 work-related deaths are still way too many, more than 12 deaths per day. And in addition to these deaths, more than 3 million workers suffer serious job-related injuries each year and many thousands more develop serious job-related illnesses. We can and must continue to do better, because injuries and illnesses can destroy families financially and in many other ways.

Now the big question: How do we keep moving forward with improving working conditions and workplace safety? First, we have to admit that on-the-job injuries, illnesses and deaths can be prevented by using basic precautions specified by existing OSHA safety standards, such as preventing falls, eliminating hazards and exposures, and guarding equipment and machinery. As Dr. Michaels stated, “OSHA doesn’t kill jobs; it stops jobs from killing people.”

Much more than enforcement–OSHA’s safety management program

We must not think of OSHA as “the enforcer” here to levy hefty fines when we are caught doing things wrong. OSHA is a resource, one that can help in big ways. In fact, one OSHA service provides free information and assistance to small businesses before they are cited for violations, making more than 30,000 on-site visits each year. If you feel you have hit a wall, give them a call.

More than 20 years ago OSHA first issued Voluntary Safety and Health Program Management Guidelines.² Recognizing that a strong correlation exists among sound and effective safety and health management and a low incidence of occupational illnesses and injuries, OSHA released general guidelines to help businesses and employers to develop systematic policies, procedures and practices to protect employees from job-related safety and health hazards. These voluntary safety management guidelines incorporate four general principles:

• Encourage employers to implement and maintain policies and practices that recognize and protect employees from occupational safety and health hazards.
• Effective programs are able to identify, evaluate and prevent or control general workplace hazards, specific job hazards and foreseeable potential hazards.
• Effective programs look beyond specific regulatory requirements and address all hazards whether or not compliance is at issue.
• Effective practice is more important than the extent of written programs, but as the size and complexity of the work site increase so do the hazards, and written guidance is needed to make sure communication of policies is clear and implementation is fair and consistent.

At the heart of the voluntary safety management program are four major elements that define an effective program. Based on the cumulative evidence, systematic policies and practices are fundamental in reducing work-related illnesses and injuries and their associated high economic costs including workers compensation, insurance and medical services. Ensuring that your program incorporates these four elements will strengthen safety and health efforts and aid its success:

• Management commitment and employee involvement. Management commitment is the motivating force for the business or organization and provides the resources necessary to implement the programs. Commitment by management tells workers that their safety and health are valuable and important to the organization. Employee involvement is paramount and provides a way for workers to take responsibility for protection of safety and health for themselves and their fellow workers.
• Workplace and job hazard analysis. An effective management program actively examines the work site and specific jobs to anticipate and prevent unsafe conditions. Regular analysis identifies existing hazards as well as operations that might create new ones.
• Prompt implementation of hazard prevention and controls. Once a hazard or potential hazard is found or recognized, elimination or controls are undertaken in a timely manner. Engineering controls, design or redesign are implemented first where feasible. Where engineering solutions to eliminate the hazard are not feasible, controls are put in place to reduce the exposure hazards and prevent unsafe conditions.
• Health and safety training. Comprehensive training is tailored to the size and complexity of the facility and the nature of the hazards. Safety training addresses responsibilities of all personnel and is best when tied to job practices and performance requirements.

Recognizing and promoting excellence–OSHA’s Voluntary Protection Program

The OSHA Voluntary Protection Program provides official recognition to businesses and work sites that have demonstrated outstanding efforts of both employers and employees in achieving exemplary health and safety. The VPP brings together management, labor and OSHA in cooperative relationships that build comprehensive health and safety management systems and promote effective occupational programs to protect workers.

The impetus for the VPP was actually stated by Congress in the original Occupational Safety and Health Act of 1970. From section (2)(b) of the OSH Act: “The Congress declares it to be its purpose and policy…to assure so far as possible every working man and woman in the Nation safe and healthful working conditions and to preserve our human resources(1) by encouraging employers and employees in their efforts to reduce the number of occupational safety and health hazards at their places of employment, and to stimulate employers and employees to institute new and to perfect existing programs for providing safe and healthful working conditions;”³

However, it was not until 1982 that OSHA began to approve work sites with exemplary safety and health management programs, thus creating the Voluntary Protection Program. The first word, “voluntary,” is the key. Participants willingly enter the VPP by seeking OSHA approval and gaining acceptance into the program. The VPP sets rigorous performancebased criteria for health and safety management systems and then assesses each applicant against these criteria. If the submittals pass OSHA’s review and meet all criteria, an on-site verification evaluation is conducted by a team of OSHA health and safety experts. Facilities that pass the site assessment are approved as having achieved one of the three Voluntary Protection Program status levels. Once qualified for VPP status, work sites must also complete annual self-evaluations and submit to periodic on-site assessments to retain that status.

There are three levels or categories within the VPP. VPP Star is the highest level of recognition, designed for model work sites that have realized comprehensive and successful health and safety management systems while achieving injury and illness rates far below the national averages for their industry. VPP Star participants meet all VPP performance criteria. VPP Merit, the next level, is intended for workplaces that show the potential and commitment to rise to Star status within three years. Merit-level VPP participants express the willingness to reach the highest level, but some aspects of their programs need expansion or enhancement. The last category is Star Demonstration. Participants in this category are testing alternative or new safety and health programs to achieve excellence that might lead to changes in VPP criteria. Once a workplace is approved, the company can begin using the appropriate VPP banners, flags and logos for recognition of superior safety and health performance.

Is it worth the extra effort? Does VPP work?

Is the VPP successful? We all know that programs that are not successful are left to fade away or given the axe. This is definitely not the case for the VPP. Since the program’s inception, the number of VPP participants has increased steadily to more than 2,400 sites at the end of 2010. Figure 1 shows overall growth during the nearly 30-year life of the program. VPP participants are from a diverse array of industries representing more than 180 distinct industry classifications, from petrochemical plants to federal laboratories (Figure 2). And most of the participants are small work sites with fewer than 100 employees (Figure 3).

Everyone wants to know how attaining VPP status benefits your work site. The bottom line is that there are many positives, both tangible and intangible. It is worth the effort because, realistically, if you are in compliance now, attaining VPP status is not going to be that much extra work. VPP participants’ statistics are impressive. VPP work sites generally have lost-workday case rates significantly lower than the rates experienced by average work sites. In fact, the average VPP work site has a Days Away, Restricted or Transferred (DART) case rate 52 percent below its respective industry average. Other tangible benefits in addition to reduced accident, injury and illness rates are decreased workers’ compensation costs and potential rebates from workers’ comp and liability premiums, as many carriers are offering incentives for performance. OSHA reports that VPP work sites have saved more than a billion dollars since the program began in 1982.⁴

On the intangible side, OSHA’s experience from the VPP indicates that effective management of safety and health greatly enhances the work environment. Obviously, the reduced DART rates lead to increased employee productivity and less disruption, especially important in small, tightly knit work teams. But improved employee morale, lower turnover and less absenteeism are also frequently reported by VPP participants. Perhaps the greatest rewards stem from the sense of pride felt by all involved, including management, health and safety directors, supervisors and frontline workers. There is also a sort of community pride both among industry peers and with the general public, knowing that your company has taken steps above and beyond strict regulatory compliance to protect the health and safety of your workers.

Snapshot of a local case study

United Space Alliance, a NASA contractor at the Kennedy Space Center in Florida, achieved VPP Star status nearly nine years ago and has maintained it ever since. It was tough at first; as the company grew and acquired smaller contractors, it discovered that some safety programs needed much work and improvement and others were missing altogether. But by reaching for VPP, the company was able to develop and implement one program and a singular way to assess safety across multiple work sites and different divisions.

Gaining VPP status brought a 15 to 25 percent drop in accident and injury rates for the various divisions in the company. One segment of the company with fewer than 100 employees had its recordable injuries go from 25 per year to zero, earning the segment a $47,000 rebate on its workers’ compensation premiums and another $48,000 from its liability carrier. But the biggest reward was perhaps the fact that the programs instituted as a result of the VPP were directly responsible for saving three lives. That is a statistic that everyone can point to and feel very good about. Isn’t it time you considered participation in OSHA’s VPP?

References

1. OSHA at 40. Michaels, Dr. David. Remarks at Center for American Progress. Washington, D.C. 2011. http://www.osha.gov/pls/oshaweb/owadisp.show_ document?p_table=SPEECHES&p_id=2500
2. Safety and Health Program Management Guidelines. Department of Labor, Occupational Safety and Health Administration. Washington, D.C. 1989. http://www. osha.gov/pls/oshaweb/owadisp.show_document?p_ id=12909&p_table=FEDERAL_REGISTER
3. Occupational Safety and Health Act of 1970. United States Department of Labor, Occupational Safety and Health Administration. Washington, D.C. 1970. http://www. osha.gov/pls/oshaweb/owasrch.search_form?p_doc_ type=oshact
4. Are you ready for VPP? Department of Labor, Occupational Safety and Health Administration. Washington, D.C. 2011. htt

Vince McLeod is an American Board of Industrial Hygiene– certified industrial hygienist and the senior industrial hygienist in the University of Florida’s Environmental Health and Safety Division. He has 22 years of occupational health and safety experience at the University of Florida, and he specializes in conducting exposure assessments and health-hazard evaluations for the university’s 2,200-plus research laboratories.

X