DEPARTMENT OF LABOR
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
HARRISBURG AREA OFFICE
AND
PRATT & WHITNEY AMERCON
MIDDLETOWN, PENNSYLVANIA
Opening Statement
In a cooperative effort to foster safe and healthful worksites and meet the
Occupational Safety and Health Administration’s (OSHA) strategic goal of
improving the safety, health, and well-being of the nation’s workforce, OSHA
and Pratt & Whitney, Middletown, Pennsylvania (Pratt & Whitney Amercon) have
agreed to the joint implementation of this Safety Partnership.
The primary goal of this partnership is to develop a cooperative
relationship with Pratt & Whitney Amercon to assist it in creating safety
and health management systems at the worksite that will insure its employees
are protected from injuries and illnesses and will encourage the company’s
application to VPP. The partnership is to be established with Pratt &
Whitney Amercon for up to a two-year period.
I. Identification of Partners
Harrisburg OSHA Area Office
Pratt & Whitney Amercon, Middletown, Pennsylvania
II. Background, Purpose and Scope
By entering into this agreement, OSHA and Pratt & Whitney Amercon agree to
work cooperatively to improve the safety and health program at ¬Pratt &
Whitney Amercon and to eliminate the hazards at the site that are cause of
injuries and illnesses to its workers.
Employee rights which are guaranteed under the OSH Act shall not be
infringed upon as a result of this partnership. This partnership does not
preclude employees and/or employers from exercising any right provided under
the OSH Act, nor does it abrogate any responsibility to comply with rules
and regulations adopted pursuant to the Act.
It is anticipated that routine worker involvement in the day to day
implementation of worksite safety and health programs will be assured,
including worker participation in team meetings, job hazard analyses, safety
and health program reviews and accident investigations.
III. Goals, Strategies, Measures (See Appendix B for full statement).
Pratt & Whitney Amercon and OSHA will work in partnership to achieve the
following goals:
Promote, institute and maintain a safety and health management system based
on OSHA’s 1989 Guidelines which incorporates these four basic program
elements: Management Leadership and Employee Involvement; Worksite Analysis;
Hazard Prevention and Control; Training.
Reduce or maintain injury and illness rates to/at levels that would meet
eligibility requirements for VPP (3 year average TCIR and DART Rates (or
equivalent rates) are below at least 1 of the most recent 3 years BLS rates
for the established NAICS code).
Encourage Pratt & Whitney Amercon’s participation in OSHA’s Voluntary
Protection Program (VPP).
IV. Partnership Management
The Partnership Management Team (PMT) will facilitate the direction of the
Partnership. The PMT will consist initially of one representative from
management and one representative from the hourly workforce. Based upon gaps
identified, additional team members will be recruited as necessary and added
to Appendix A. OSHA’s representative will serve in an advisory capacity to
the PMT and will perform duties as outlined in Section VI.
The PMT will perform a variety of activities to facilitate the success of
the Partnership, including:
Using the OSHA Challenge Program Stages for General Industry (Appendix C) as
a guide, select and assign the steps and duties needed to carry out Pratt &
Whitney Amercon’s commitments under the partnership agreement.
Encourage Pratt & Whitney Amercon’s participation in VPP.(1)
Meet at least quarterly to track Pratt & Whitney Amercon’s progress under
the agreement and to make adjustments as needed. Pratt and Whitney's
Partnership Management Team will establish and/or adjust written timelines
and task assignments to close gaps in their safety and health management
system in order to meet eligibility requirements to apply to VPP.
Communicate partnership activities, including best practices and successes,
throughout Pratt & Whitney Amercon.
Prepare an annual evaluation with final approval by OSHA. The evaluation
will be due each year on the effective date of the partnership, and will
follow the written format shown in Appendix D.
V. Pratt & Whitney Amercon agrees to:
Visibly lead in the design, implementation, and continuous improvement of
the site’s safety and health policies and activities.
Implement safety and health programs with a commitment that routinely
extends beyond what is required by OSHA regulation.
Provide the necessary resources of staff, time and money to ensure that all
persons on the worksite are protected from injury and illness hazards.
Ensure that all employees, from the top-level management down, have clearly
written and defined safety and health responsibilities.
Ensure that written safety and health management systems are implemented
that effectively address worksite hazards by identifying and tracking them
to guarantee their correction and control.
Ensure training programs are implemented that help employees clearly
understand their occupational hazards and how to control them.
Conduct baseline safety, health and employee surveys and share results with
OSHA.
Share ongoing measurement data with OSHA needed to evaluate the
partnership’s effectiveness.
VI. OSHA agrees to:
Work cooperatively with Pratt & Whitney Amercon to provide safety and health
information, technical assistance and training (as resources allow), to
facilitate safety and health management system improvements.
Conduct an initial evaluation (Gap Analysis) of the Pratt & Whitney
Amercon’s safety and health management system and report the findings to the
PMT to help it determine the best steps to take to carry out the partnership
agreement and work toward VPP application. (Note: OSHA’s onsite
non-enforcement policy for partnerships will apply during any site walk
around by an OSHA Compliance Assistance Specialist. See Section VII.)
Meet at least quarterly with the PMT to track Pratt & Whitney’s progress
under the agreement, review its injury and illness experience and to make
adjustments as needed.
VII. Onsite Non-enforcement Verification:
During any onsite non-enforcement verification, OSHA conducts a review of
the partner’s worksite in a non-enforcement capacity to assess the
implementation of the partnership agreement. During such visits, if OSHA
personnel identify serious hazards, OSHA and site management will agree upon
a date for correction. If OSHA identifies serious hazards that the site
management refuses to correct, the OSHA Compliance Assistance Specialist
will make a referral to the Area Office for an enforcement inspection.
Annually, OSHA will conduct at least one onsite non-enforcement verification
visit at Pratt & Whitney Amercon. The purpose of the visit is to continue to
support the company’s efforts to improve its safety and health management
system and to prepare the required annual evaluation to gauge the
effectiveness of the partnership.
In addition to the on-site assessments conducted by an OSHA Compliance
Assistance Specialist (CAS), documentation will be selected for review that
relates to the agreement’s goals, objectives and stated measures and will
include a review of injury and illness data and survey results.
VIII. Benefits:
Pratt & Whitney Amercon at the Middletown, Pennsylvania facility is granted
a six month deferral from programmed inspections upon entry into the
partnership.
OSHA will designate an experienced safety and health staff person to serve
as a resource and liaison to Pratt & Whitney Amercon to provide training and
technical assistance as outlined in the agreement, and to serve as an
advisor to the Partnership Management Team.
OSHA will not issue penalties for other-than-serious violations, provided
the violations are abated during the inspection.
When calculating initial penalty reductions, OSHA may provide an additional
10% penalty reduction for good faith over and above what is allowed by the
FIRM. This additional reduction will not apply to high gravity serious,
willful, failure to abate or repeat citations. In cases where Pratt &
Whitney Amercon’s total penalty reduction is 100 percent or more, the
minimum penalty provisions of OSHA’s FIRM will apply.
IX. Formal Complaints and OSHA Investigations:
OSHA personnel will continue to conduct investigations resulting from formal
complaints, referrals, fatalities, catastrophes, other accidents or
significant events at this partnering worksite. These investigations will be
conducted outside of this partnership agreement in accordance with
established OSHA enforcement policy. Violations identified during such
investigations may result in the issuance of citations and penalties.
X. Evaluation:
An annual evaluation will be prepared by the PMT and OSHA with final
approval by OSHA. The evaluation will be due each year on the effective date
of the partnership, and will follow the written format shown in Appendix D.
XI. Termination:
This agreement will terminate two years from the date of the signing. If
either OSHA or Pratt & Whitney Amercon wishes to withdraw its participation
prior to the established termination date, the agreement will terminate upon
receiving a written notice of the intent to withdraw from either signatory.
OSHA will terminate the partnership if Pratt & Whitney Amercon is issued a
citation related to workplace hazards which resulted in a fatality.
XII. Paperwork Reduction Act Notice:
Paperwork Reduction Act Notice Form Approved OMB# 1218-0244 Expires
01-31-2009. Public reporting burden for the time needed to develop the
Partnership requirements, craft agreement language, and conduct an internal
review process is estimated to be an average of 11 burden hours per
respondent.
Bryan Seal
Area Director
Harrisburg Area Office
Occupational Safety and Health Administration
Date
Ron Chandler
General Manager
Pratt & Whitney Amercon
Date
(1) VPP is administered separately from
OSHA’s Strategic Partnership Program. Participation in the partnership is not a
guarantee of acceptance into VPP.
Appendix A – Partnership Management Team
Management Employees – Richard McCurdy – Manager, EHS
Hourly Employees – to be determined.
Appendix B – Goals, Strategies, Measures
Goals
Strategies
Measures
Promote, institute and
maintain a safety and health management system based on OSHA’s 1989
Guidelines which incorporates these four basic program elements:
Management Leadership and Employee Involvement; Worksite Analysis; Hazard
Prevention and Control; Training.
Reduce or maintain injury and illness rates to/at levels that would meet
eligibility requirements for VPP (3 year average TCIR and DART Rates (or
equivalent rates) are below at least 1 of the most recent 3 years BLS
rates for the established NAICS code).
Encourage Pratt & Whitney Amercon’s participation in OSHA’s Voluntary
Protection Program (VPP).
1st Year of Agreement:
As soon as the agreement is signed, OSHA will conduct an initial
evaluation of Pratt & Whitney Amercon’s safety and health management
system. The evaluation will include a walk around of the facility to
become familiar with the manufacturing processes and their associated
health and safety risks and a review of the programs and management
systems that are in place to ensure that control over these risks is
maintained. The findings of this initial assessment will be reported to
the Partnership Management Team in the form of a Management System Gap
Analysis which will include references to the appropriate Challenge
Elements and Stages to be used as a starting point to close identified
gaps. OSHA’s onsite non-enforcement partnership policy will apply during
this evaluation.
Quarterly, OSHA will meet with the PMT to review their progression through
the Challenge Stages with particular emphasis placed on those VPP
Challenge elements where significant gaps were identified. During these
visits, any concerns, questions, or other issues can be addressed
regarding gap closure or the VPP application process. Specific training
can also be conducted to ensure that the team has the necessary knowledge
and understanding of VPP/VPP Challenge Elements that will lead to
successful implementation of the components.
1st Year of Agreement:
Gap Analysis
Completed Challenge Stages
TCIR and DART rates
2nd Year of Agreement:
PMT meets at least quarterly with OSHA to track progress in completing ALL
Challenge Stages, review injury and illness experience and make
adjustments as needed to meet partnership goals.
OSHA representative and VPPPA mentor conduct mock VPP audit.
Pratt & Whitney Amercon completes VPP application with assistance from
VPPPA Mentor and OSHA as needed.
2nd Year of Agreement:
Completed Challenge Stages
TCIR and DART rates
Mock VPP inspection with results reported to company by 3rd quarter of the
2nd year of partnership.
Completed VPP application by end of agreement.
Appendix C – Challenge Stages
Challenge Stages at a Glance
1. Management
Leadership
Element
Stage I
Stage II
Stage III
1.1 Management Commitment
Mission and Policy Statements
Develop S&H
Mission Statement, with input from
employees, and a S&H Policy Statement.
Communicate
statements; incorporate into new employee/contractor orientation.
Take proactive
steps to ensure understanding by all employees and contract workers and
that they become a routine part of regular communication.
Leadership by Example
Begins to
participate in S&H activities and follow S&H rules.
Continue;
increase frequency of manager participation in S&H activities.
Continue; ensure
total involvement of all executives, managers, & supervisors
Resources
Commit initial
resources to control identified hazards. Begin integrating S&H into other
aspects of management planning.
Provide
additional resources for S&H activities, including access to certified S&H
and licensed health care professionals, and improve integration of S&H
into other planning processes.
Continue
committing and ensuring the utilization of adequate resources. Ensure
integration of S&H into all planning processes in the site.
Goals and Objectives
Establish &
communicate annual S&H goals & objectives based on findings from baseline
hazard and trend analyses; and assessment of the site’s safety and health
practices.
Review the
site’s progress towards achievement of S&H goals & objectives; establish &
communicate new goals, as appropriate.
Review, revise,
and continue communicating S&H goals and objectives. Ensure S&H goals and
objectives are routinely considered in site’s activities and programs.
Responsibility, Authority, and Accountability
Develop a
safety and health accountability plan for managers, supervisors, and
non-supervisory employees.
Enforce
accountability plan.
Fully implement
accountability system for all workers, including incorporation of S&H
responsibilities into job descriptions and performance plans. Assign
additional responsibilities to non-supervisory employees as appropriate.
Communication
Establish clear
lines of communication with employees & provide reasonable access to top
management re: S&H issues.
Maintain clear
lines of communication with employees re: S&H issues
Encourage open
dialogue between management staff and employees.
Disciplinary Plan
No action
required
Develop & begin
implementing disciplinary plan for managers and employees.
Ensure
discipline is equability enforced, ensure higher levels of compliance.
Annual Self-Evaluation
No action
required .
No action
required
Develop system
and written procedures to annually evaluate the total site’s S&H
management system. Complete at least one annual self-evaluation of the
site’s safety and health management system
Conduct
follow-up employee S& H perception survey.
S&H Practices Change
Plan
Develop an action plan to
address findings from the baseline employee S&H practices perception
survey.
Implement steps defined in
the site’s action plan to improve S&H culture.
Continue; ensure significant
improvement in S&H culture
Employee Notification
Notify all
employees of their S&H rights, the site’s participation in Challenge, &
VPP principles.
Notify new
employees of their S&H rights, site participation in Challenge, & VPP
principles. Incorporate into new employee/contractor orientation.
Continue for
new employees. At least annually, reenforce for all employees. Encourage
freely reporting workplace hazards without reprisal.
Meaningful Employee Involvement
Establish a few
key S&H teams; begin involving employees in S&H activities.
Increase
participation on teams, and/or form additional teams. Involve employees in
safety and health activities (e.g., accident/near-miss investigations).
All needed
teams are functioning and meaningfully contributing to S&H. Ensure regular
teams are routinely conducting audits, accident/incident investigations,
self-inspections, and job hazard analyses. Improve and continue the site’s
hazard reporting system.
1.3 Contract Worker Coverage
Adherence to Rules
Require
contractors and their employees to comply with OSHA and site S&H rules.
Improve and
continue to enforce policy for S&H violations.
Improve and
continue- enforce policy for safety and health violations.
Contractor Selection
No action
required
Consider
contractors’ safety and health performance in the bidding process,
including a review of injury/illness rates.
Fully establish
and use selection criteria. Encourage contractors to develop their own S&H
management systems & decrease high rates.
Contractor Hazards
Contractor
ensures correction of any hazards in their work areas.
Develop &
implement a formalized method including assignment of responsibility to
identify, correct, & track hazards in contractors’ work areas.
Include
responsibility for hazard correction in writing, in the contracts.
Removal Policy
No action
required .
Develop &
implement contractor policy for S&H violations, including removal and
other penalties.
Penalty policy
is understood by all contractors, described in their contracts, and
adhered to
2. Worksite Analysis
Element
Stage I
Stage II
Stage III
Baseline Safety and IH Hazard Analysis
Conduct the baseline analysis (may use outside sources), including a chemical
inventory and evaluation of typical safety and health hazards.
No action required
Re-do baseline survey, if warranted by significant changes in tasks, equipment,
or processes.
Hazard Analysis of Routine Jobs, Tasks, And Processes
No action required
Conduct hazard analysis and recommend controls for routine jobs, tasks, &
processes that have had associated injuries/illnesses or significant incidents
or near-misses; are perceived as high-hazard; or are required by a regulation or
standard; observe guidelines.
Conduct hazard analysis and recommend controls for routine jobs, tasks, and
processes that have written procedures, have been recommended for more indepth
analysis, or are determined by the Challenge participant to warrant hazard
analysis
Hazard Analysis of Significant Changes
No action required
No action required
Conduct hazard analysis for significant changes (e.g., non-routine tasks or new
processes, materials, equipment and facilities) and recommend controls prior to
the activity or use.
Pre-use Analysis
No action required
No action required
Conduct pre-use hazard analysis of new equipment, chemicals, facilities, or
significantly different operations or procedures. and recommend controls prior
to the activity or use.
IH Program
No action required (See Baseline Hazard Analysis).
Follow up on results of baseline IH study. Conduct more in-depth analysis if
warranted to determine actual employee exposures. Establish, document, &
implement future sampling schedule, strategy, and rationale.
Continue to follow the written IH program; take proactive steps to improve
control of health hazards to prevent occupational disease.
Routine Self-inspections
No action required
Develop a documented system for routinely scheduled self-inspections of the
workplace; conduct inspections with S&H staff; covering entire worksite, at
least semi-annually.
Continue to conduct routine self-inspections. Increase frequency to at least
monthly, with the entire worksite covered at least quarterly.
Employee Hazard Reporting System
No action required
Develop & begin implementing hazard-reporting system for employees (maybe
anonymous).
Encourage more active reporting; ensure regular feedback, using different media,
to all employees on status of hazards reported.
Investigation of Accidents and Near-Misses
Develop and implement system to report and investigate accidents. Determine root
causes and track correction to completion.
Expand system to include reporting and investigation of near misses. Continue
investigating accidents, begin investigating near-misses, and making corrective
actions.
Thoroughly report and investigate all accidents and near-misses.
Trend Analysis
Conduct trend analysis of injury & illness history (previous 3 years of OSHA
200/300 logs) and begin developing a plan for conducting analysis of other
S&H-related information
Conduct trend analysis of other S&H information not yet studied; conduct one of
injury & illness history if a year has gone by since initial analysis.
Trend analysis takes place regularly (at least annually) for all types of S&H
information, and is utilized in setting future goals to address identified
trends.
3. Hazard Prevention & Control
Element
Stage I
Stage II
Stage III
Certified Professional
Resources
(see Management Commitment)
(see Management Commitment)
(see Management Commitment)
Hazard Elimination & Control Methods
Develop an action plan to prioritize and implement controls for hazards
identified, through the baseline S&IH study, trend analysis of OSHA logs and
accident investigations.
Implement controls or (interim protection if long-term abatement) for top
priority hazards before moving onto Stage II.
Complete long term abatement projects from Stage I.
Develop an action plan to prioritize and implement controls for hazards
identified through self-inspections,
employee reports of hazards, and nearmiss investigations.
Implement hazard controls (or interim protection) for top priority hazards
before moving onto Stage III.
Complete long term abatement projects from Stage II. Continue to pro-actively
identify, prioritize, and implement controls for hazards identified through all
means (hazard analysis, trend analysis, accident and near miss investigation,
self-inspections, employee reports of hazards, pre-use analysis, etc) so that
there is a continuous loop of hazard id and control.
Hazard Control Programs
Inventory existing hazard control programs required by OSHA standards. Develop
missing programs or modify existing programs.
Implement hazard control programs developed or modified in Stage I and train all
workers on these programs.
Review hazard control programs annually and updated as new processes, jobs, and
tasks are begun.
Documented System for Hazard Correction
Tracking
Develop and begin implementing a hazard tracking system for hazards identified
through the baseline hazard analysis, trend analysis of OSHA logs, and accident
investigations.
Expand tracking system to include hazards identified through hazard analysis of
routine jobs; self-inspections; employee reports of hazards; and near miss
investigations.
Tracking system is fully functioning and includes hazards identified through all
methods.
Preventive Maintenance
Conduct an inventory of equipment and machinery requiring preventive
maintenance.
Review equipment inventory. Establish and implement preventive maintenance
schedule.
Ensure schedule is routinely observed and preventive maintenance is regularly
conducted.
Occupational Health Care Program
Conduct records review of previous three years OSHA 200/300 logs. Compare with
insurance claims forms and ensure records are in order. Provide physician
services for emergencies (see below).
Continue to provide access to licensed health care providers, health services,
physician care, and emergency medical care. Arrange for services based on the
outcomes of the baseline safety and health analysis.
Continue providing services listed in Stage I and II. In addition- Health Care
providers visit the site, and assist in identifying causes and symptoms of
injury/illness. Care provided in within the scope of licensure.
Emergency Preparedness and Response
Establish & communicate written procedures for responding to all types of
emergencies; Make emergency services available on all shifts including:
ambulances, EMT’s, emergency clinics, or hospital emergency rooms.
Provide at least one employee trained in first aid & CPR for each shift or an
equally effective alternative.
Conduct at least one evacuation drill & assess its effectiveness.
Continue providing emergency medical services.
Establish an Emergency Response Team including first aid and CPR trained
employees. Conduct at least one drill and assess it’s effectiveness and
follow-up on recommendations to improve emergency evacuation drills.
Continue providing emergency medical services.
Establish a Haz. Mat. Team if necessary.
Consult with local fire department to ensure adequate coverage for fire,
explosion, or chemical release.
Conduct evacuation drills at least annually and assess their effectiveness.
Provide AED and training on its use for those on the Emergency Response Team.
4. Safety and Health Training
Element
Stage I
Stage II
Stage III
General guidelines
Observe OSHA guidelines in providing training for required programs.
Continue observing OSHA VPP guidelines in providing training.
Continue observing OSHA VPP guidelines in providing training.
Training for all workers
Provide training to all workers on their S&H rights, Challenge, VPP fundamental
principles, hazards in the workplace, PPE, emergency evacuation procedures, and
individual emergency responsibilities.
Continue providing training to all workers, including new workers, on their S&H
rights, Challenge, VPP fundamental principles, hazards in the workplace, PPE,
emergency evacuation procedures, and individual emergency responsibilities.
Take proactive steps to improve & continue providing
training to all workers, including new workers, on their S&H rights, Challenge,
VPP fundamental principles, hazards in the workplace, PPE, emergency evacuation
procedures, and individual emergency responsibilities
Training for specific groups of workers
Provide specific training to managers and supervisors, to designated S&H staff
and others with S&H responsibilities, and to contract workers to equip them with
knowledge & skills needed to perform their S&H responsibilities in Stage I
(i.e., hazard recognition, accident investigation and root cause analysis,
hazard controls, OSHA standards, and VPP requirements).
Provide specific training to managers and supervisors, to designated S&H staff
and others with S&H responsibilities, and to contract workers to equip them with
knowledge & skills needed to perform their S&H responsibilities in Stage II.
Take proactive steps to provide specific training to all employees and contract
workers to equip them with the knowledge & skills they need to perform their S&H
responsibilities in Stage III.
Appendix D
OSHA STRATEGIC PARTNERSHIP PROGRAM
ANNUAL PARTNERSHIP EVALUATION REPORT
Cover Sheet
Partnership Name
Purpose of Partnership
Goals of Partnership
Goal
Strategy
Measure
Anticipated Outcomes
Strategic Management Plan Target
Areas (check one)
Construction
Amputations in Manufacturing
General Industry
Strategic
Management Plan Areas of Emphasis (check all applicable)
Amputations in Construction
Oil and Gas Field Services
Blast Furnaces and Basic Steel Products
Preserve Fruits and Vegetables
Blood Lead Levels
Public Warehousing and Storage
Concrete, Gypsum and Plaster Products
Ship/Boat Building and Repair
Ergo/Musculoskeletal
Silica-Related Disease
Landscaping/Horticultural Services
Section 1
General Partnership Information
Date of Evaluation Report
Evaluation Period
Start Date
End Date
Evaluation Contact Person
Originating Office
Partnership Coverage
# Active Employers
# Active Employees
Industry Coverage (note range or
specific SIC and NAICS for each partner)
Partner
SIC
NAICS
Section 2
Activities Performed
Note whether an activity was provided for by the OSP and whether it was
performed
Required
Performed
a. Training
b. Consultation Visits
c. Safety and Health Management Systems
Reviewed/Developed
d. Technical Assistance
e. VPP-Focused Activities
f. OSHA Enforcement
Inspection
g. Offsite Verifications
h. Onsite Non-Enforcement Interactions
i. Participant Self-Inspections
j. Other Activities
2a. Training (if performed,
provide the following totals)
Training sessions conducted by OSHA staff
Training sessions conducted by non-OSHA staff
Employees trained
Training hours provided to employees
Supervisors/managers trained
Training hours provided to supervisors/managers
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed)
2b.
Consultation Visits (if performed, provide the following total)
Consultation visits to partner sites
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed)
2c. Safety and Health Management
Systems (if performed, provide the following total)
Systems implemented or improved using the
1989 Guidelines as a model
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed)
2d. Technical Assistance (if
performed, note type and by whom)
Provided by OSHA Staff
Provided by Partners
Provided by Other Party
Conference/Seminar Participation
Interpretation/Explanation of Standards or OSHA Policy
Abatement Assistance
Speeches
Other (please specify)
Comments/Explanations (briefly
describe activities, or explain if activity required but not performed)
2e. VPP-Focused Activities (if
performed, provide the following totals)
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