Participant Xerox Oklahoma City Supplies Manufacturing Plant Utilizes Four Key Elements of VPP to Achieve Excellence in Workplace Safety and Health

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Participant Xerox Oklahoma City Supplies Manufacturing Plant Utilizes Four Key Elements of VPP to Achieve Excellence in Workplace Safety and Health


Xerox Corporation is a $22 billion leading global enterprise for business process and document management. Through its broad portfolio of technology and services, Xerox provides the essential back-office support that clears the way for clients to focus on what they do best: their real business. Headquartered in Norwalk, Conn., Xerox provides leading-edge document technology, services, software and genuine Xerox supplies for graphic communication and office printing environments of any size. Through ACS, A Xerox Company, which Xerox acquired in February 2010, Xerox also offers extensive business process outsourcing and IT outsourcing services, including data processing, HR benefits management, finance support, and customer relationship management services for commercial and government organizations worldwide. The 130,000 people of Xerox serve clients in more than 160 countries. One of these facilities, located in Oklahoma City, is the Xerox Supplies manufacturing plant. This plant is a leading manufacturer and supplier of resin materials, binder tape, and charging components (corotron wire assemblies). A corotron is a device used in printers and copiers to create an electric field that attracts toner particles.

Over the past decade, the Xerox Oklahoma City Supplies manufacturing plant has been recognized for various achievements in workplace safety and health, as well as for protecting the environment. For example, in 2004, this plant was the first of all Xerox facilities to be recognized and approved by OSHA as a Merit-level status Voluntary Protection Programs (VPP) participant. After setting goals to reduce the expected lifetime waste of its products, in 2005, the plant earned membership in the U.S. Environmental Protection Agency's (EPA) National Environmental Performance Track Program. Participants must have a record of sustained compliance with environmental requirements to be eligible. Then in 2006, the facility received VPP New Star status from OSHA, the highest level of VPP recognition; and in 2009, the facility received VPP Star status recertification.

Success Impact:
Key Element #1: Management Commitment and Worker Involvement

Effective leadership is a critical ingredient in the success of any organization. At the Xerox Oklahoma City Supplies manufacturing plant, effective leadership starts with a strong dedication and commitment to workplace safety and health. While working towards obtaining VPP approval and recognition, the facility adopted a continuous improvement safety and health management system model based on the four key elements of VPP:

  1. Management Commitment and Worker Involvement
  2. Worksite Analysis
  3. Hazard Prevention and Control
  4. Safety and Health Training

The initiative began by focusing on the first key element of management commitment. To demonstrate the commitment to safety and health excellence, management and WORKERS UNITED, the plant's organized labor union, collaborated to develop and publish a new Environmental Safety and Health policy. This new policy enforced the commitment of continuous improvement by: complying with all environmental health and safety requirements; minimizing risks onsite as well as to the environment; promoting and encouraging a healthy lifestyle; and reducing waste, reusing materials, and recycling. Awareness about this new policy was communicated throughout the facility during monthly meetings, stated in the Environmental Health and Safety (EH&S) handbook, posted on bulletin boards, and discussed during orientation trainings for new workers, contractors, and visitors.

Quarterly reviews are conducted by senior management to ensure the continuation, suitability, adequacy, and effectiveness of the facility's safety and health management system. This review includes the following: a needs assessment, internal and external audit results, industrial hygiene recommendations and findings, EH&S training, self-inspections and incident reporting, recommendations for improvement, and any upcoming changes related to current regulations. At the conclusion of the review, senior management determines whether the system is effective or if changes are needed. Meeting notes are recorded and disseminated and include decisions and action items needed, as well as any changes to physical, human, and financial resources. These notes also reflect if any actions related to changes to policy, objectives, targets, and other elements of the system are necessary.

"The benefit of VPP is that it creates an open culture between employees and management to address safety issues, the entire process is transparent, inclusive and recorded. Everyone contributes to health and safety solutions without fear of retribution." Gabriel John, VPP Coordinator, Xerox Corporation

The facility's workers are actively involved in all workplace safety and health initiatives. For example, the facility currently has three Special Government Employees (SGEs) who participate on the OSHA VPP Review Teams during onsite audits throughout Oklahoma. To demonstrate the facility's commitment, understanding, and belief in the principles of VPP, workers have also been involved in assisting and mentoring outside companies, such as Cameron Valve and Nabors Well Service, to help them achieve VPP status. WORKERS UNITED, Steward Dennis Mathis, serves as a volunteer and trained member of the facility's SGE Team.

"I am a bilingual SGE that has been involved in OSHA VPP site audits, mentoring other companies and internal self evaluation audits since 2006. I have translated our contractor orientation quiz into Spanish language to enhance a safe and healthy work environment. As an employee of 25 years at the same site, I have had the opportunity to experience and see changes first hand in co-workers, management, work environment and most importantly our work culture (overall attitudes of both salaried and Industrial Work Force (IWF) employees towards safety and health). The success of ever achieving 100 percent consensus on the importance of safety is influenced by the existing work culture on both sides of the workforce (salaried and IWF employees). I sincerely believe that our work force has experienced a culture change as we matured and aged. We realized that going home safely to our families depends on us being safe at home and at work. Participation in VPP has helped us bring our EH&S program up to the nationally recognized standard. I personally feel that management and employee involvement is the most critical element out of the four VPP elements. Without full implementation of this element, integrity of the worksite analysis, hazard prevention and control and the proper use of safety and health training will be minimized. This element builds a common level of trust and respect between salaried and IWF employees that are necessary for achieving our safety and health goals and objectives. Xerox's commitment to higher standards is shared by our working culture. We understand that without self accountability, the proper culture and the desire to make VPP a success, the end result is an unsafe or unhealthy work environment." Ramiro Cavazos, WORKERS UNITED, SGE, Xerox Corporation

All workers are urged to report hazards and participate in self-inspections. Workers have access to the facility's top leadership through the implementation of an "Open Door Policy" and "Ethics Hotline" without fear of negative repercussions or reprisals. Once an incident report is made, management enters the report into an electronic tracking system which generates an e-mail notification to everyone onsite as well as within the corporate office. The Incident Review Team (IRT), made-up of both salaried and hourly workers, meets weekly or on an as-needed basis to review each preliminary incident report. The IRT assigns a lead investigator from a pool of investigators that consists of representatives from labor and management, or the IRT has the option of conducting the investigation themselves. The lead investigator is responsible for conducting the investigation, assuring appropriateness with regards to worker involvement, developing corrective actions, assigning and discussing corrective actions with responsible persons, and documenting all necessary actions and items into the electronic tracking system. To minimize potential conflicts of interest, only personnel who were not involved in the incident or who do not directly supervise the operation or the injured worker may lead the investigation.

"I have worked at several manufacturing facilities including one other VPP site. This is the safest place I have ever worked so far." James Rudy, Temporary Assembler worker, Xerox Corporation

Workers have also dedicated their time and efforts to promote a safe workplace by delivering various presentations on VPP to local companies to expand outreach and awareness about VPP. These efforts have resulted in the plant receiving the Region VI Voluntary Protection Programs Participants' Association (VPPPA) Education and Outreach Company of the Year award for three consecutive years (2007-2009) in a row. Between 2005 and 2010, workers have also been individually recognized by the VPPPA Chapter Region VI for their sincerity, dedication, and leadership towards expanding education and awareness about VPP and striving to achieve workplace safety and health excellence. This involvement results in personal investment and a developed sense of ownership in the success of the facility's safety programs and other safety initiatives which results in improved worker morale and productivity.

"I thought we had a great safety program before, but since we started VPP, safety program has improved drastically." Mike McClellon, WORKERS UNITED, Machine Operator Worker, Xerox Corporation

All health and health safety-related documents are readily accessible and available. To ensure that consistent safety and health standards, guidelines, and procedures are implemented, the facility has developed an integrated and standardized control process for maintaining all documents. An electronic filing system has been developed and implemented and document control has been decentralized. Controlled documents (containing information that affects product quality or environmental and/or safety and health components) are maintained as electronic files and backed-up according to record retention procedure.

Safety Requirements for Onsite Contractors

A safety program for contractors has been developed to ensure that contractors are also provided quality safety and health protection. As part of this program, the contractor's project manager must first develop a general job plan including potential hazards and risks involved, as well as abatement controls. If the level of risk associated with the type of work warrants pre-qualification, the prospective contractor is provided with a thorough and comprehensive questionnaire which asks for information regarding the contractor's insurance carriers; loss experience (Experience Modification Rate); safety compliance history; workers' compensation assessment rates; Total Case Incident Rate (TCIR) and Days Away, Restricted, and Transferred (DART) rate for the previous three years; and finally, information on their safety and health programs. During the selection process, a risk assessment of the potential contractor is conducted which includes the following criteria: inherent level of risk for the required activity, access and/or interaction with major exposures, prior experience working in the industry, and loss experience.

Once a contractor is approved to work on the site, prior to commencing work, they are required to attend a safety and health orientation which includes the following components: review of the commitment to safety statement; covering safety responsibilities and applicable rules, procedures, work permits; safety equipment and personal protective equipment requirements; site orientation and hazard awareness; hazard identification and reporting; emergency plans (including medical, fire, tornado, security and other contingencies); and incident and hazard reporting requirements. The orientation accommodates workers who require special needs and resources (language or hearing). Following the orientation, a quiz is administered to participants to ensure they understand and are knowledgeable about the material presented. All contractors are required to receive the orientation on an annual basis and those who do not meet this requirement are denied access to the worksite.

Key Element #2: Worksite Analysis
"VPP is about visualizing potential problems." WORKERS UNITED, Worker, Xerox Corporation

The Management of Change (MOC) process is initiated whenever changes in operations or procedures regarding chemicals, equipment, facilities, or work practices occur. The MOC process is integrated in the procurement/design phase which maximizes the opportunity for proactive hazard controls and is managed by a MOC Board. Members of the MOC Board include the: health and safety manager, process safety manager, operations manager, plant manager, quality assurance manager, and engineering manager who review the change request and assess the impact. The MOC board identifies any processes and tools needed to implement the change. The MOC requestor is notified as to whether the request has been approved or denied. After the change is completed but prior to being released for production, a pre-use inspection is conducted which confirms that the following criteria have been met:

  • Manufacturer recommendations and instructions have been reviewed and incorporated as necessary.
  • Construction and equipment is in accordance with design specifications.
  • Hazard evaluation has been performed and recommendations resolved or implemented.
  • Safety, operating, maintenance and emergency procedures are in place.
  • Safety critical equipment has been properly installed and is functional.
  • Training for affected workers has been completed (if necessary).
  • Safe work practices have been reviewed and updated as necessary.

After all corrective actions have been completed the quality assurance manager will close the MOC.

A web-based system is in place to ensure that hazards identified during incident investigations, self-inspections and audits, worker hazard reports, and any change in injury/illness rates are assigned to a responsible party and addressed in a timely fashion. For the purpose of detecting trends, the information is analyzed and the results shared with workers and management to ensure that resources are directed towards corrective actions.

Key Element #3: Hazard Prevention and Control

The Xerox Oklahoma City Supplies manufacturing plant has contracted with a licensed occupational health care physician who is responsible for assessing worker health annually to provide prevention, early recognition, and treatment of workplace-related injuries and illnesses. This assessment also includes pre-placement physicals, audiograms, and lung function tests. Medical Emergency Response Team (MERT) members consist of workers trained and certified in First Aid, cardiopulmonary resuscitation (CPR), and the use of Automated External Defibrillators (AEDs) and provide medical emergency care for all workers onsite as well as contractors. Workers are also provided the opportunity to visit a clinic offsite to receive medical care.

The plant has specific written emergency procedures regarding response to all types of emergencies (fire, chemical, severe weather, incidents, terrorist threat, power outage, natural disaster, etc.) on all shifts. These procedures are communicated to all plant workers, contractors and visitors and practiced at least annually. If a worker is absent during the unannounced drill, once they return to work, their supervisor accompanies them through the drill to ensure this important procedure is conducted.

Industrial Hygiene Program

The facility also implements the Industrial Hygiene Program which establishes procedures and methods for identification, analysis, and control of health hazards to prevent occupational health diseases. On a consistent basis, an outside contractor administers a survey throughout the facility to collect data. Once the data is collected and analyzed, a written report of key findings and recommendations is completed. Samples of some of the key results are maintained in a web-based system which is accessible to workers and management. The industrial hygiene monitoring frequency is broken down into the following three priority levels and frequency:

  • Priority Level 1 – Utilizes the quarterly monitoring frequency to evaluate and document potential exposure to any carcinogen as defined in 29 CFR 1910.12000 Appendix A and all toxic and hazardous substance regulated by a specific OSHA performance standard. (The only application where Priority Level 1 monitoring is used for noise is during testing of emergency generators.)
  • Priority Level 2 – Utilizes a semi-annual monitoring frequency to evaluate and document potential exposure to all other toxic and hazardous substances regulated by OSHA in Subpart Z of 29 CFR 1910.1000; which, due to specific chemical properties (e.g. vapor pressure), present an increased potential for exposure and/or require the use of respirators during non-routine procedures. Priority Level 2 is also used for those areas where the Baseline Noise Survey indicated that some noise levels exceeded the Xerox Exposure Limit (85-dBA) and OSHA PEL (90-dBA).
  • Priority Level 3 – Utilizes an annual monitoring frequency for common air contaminants that are of low toxicity or which have properties that are routinely controlled by Xerox engineering controls (for example, certain dusts). Priority Level 3 monitoring is also used for representative personnel that work in areas that are covered by the OSHA Hearing Conservation Program Action Level (85-dBA) and Xerox exposure standard, XEL (85-dBA).
Key Element #4: Safety and Health Training

The plant has established a method for systematic safety and health training to ensure that all workers have the education, awareness, and skills needed to ensure their safe return home after work. This includes training needed to perform their tasks in an environmentally responsible and safe manner and providing information about the potential impact in how these activities are carried can have on their health and safety. A needs assessment to determine what specific types of safety and health training should be offered is performed annually by reviewing: legal and other requirements, training exam scores from the previous year, internal and external inspection results, documented incidents, and comments obtained related to previous trainings. Appropriate levels of safety and health training are specified for different groups through classroom instruction, posting of instructions, or other communications. Training specific to job functions and specific operating procedures for industrial work force personnel is the responsibility of the individual's engineer.

Facility's Exemplary Safety and Health Management System Leads to Injury and Illness Rates OVER 50% below National Average

Incorporating the above four key elements into the facility's safety and health management system has resulted in many impressive results – one of these being significantly low injury and illness results. The plant's three-year average the Total Case Incident Rate (TCIR) and Days Away, Restricted and Transfer (DART) rates between 2007 and 2009 were 60 percent and 48 percent below the 2008 BLS national average for this industry. The below graphical representations present the plant's injury and illness rates between 2007 and 2009:

Year 1: 2007 1.2 2.4
Year 2: 2008 0 1.7
Year 3: 2009 0 0
Three-Year Rate (2007-2009) .5 1.7
BLS Industry National Average (2008) 2.0 2.9
Percentage Below BLS National Average (2008) -78% -60%
Bar Graph depicting the table above. OKC DART Incident Rate Cases vs. BLS Average

Bar Graph depicting the table above.
(Click for text version)

Bar Graph depicting the table above. OKC TCIR Incident Rate Cases vs. BLS Average

Bar Graph depicting the table above.
(Click for text version)


The Xerox Oklahoma City Supplies manufacturing plant has demonstrated how incorporating the four key elements of VPP into their safety and health management system can result in many safety successes at the workplace. In 2010, due to its exemplary health and safety record, the plant received the VPP Star Site award from the Region VI OSHA VPP Manager. During the 2010 Oklahoma Safety Council Conference, the plant's safety and health management system was nominated as the being best among VPP member companies and received a VPP award from the Oklahoma Safety Council. Safety and health is also linked to the facility's business performance as a direct performance objective for the facility. Profit-sharing is based on several objectives, such as meeting the financial plan, environmental non-conformities, total net yield, customer complaints, individual absences and leave, and injury and illness rates.

Xerox Oklahoma City Supplies Manufacturing Plant 2010

Xerox Oklahoma City Supplies Manufacturing Plant 2010

Location of VPP Participant: Oklahoma City, Oklahoma
Date Received VPP Recognition: 2004 (Merit); 2006 (New Star); 2009 (Star recertification)
US NAICS Title (NAICS Code): Photographic Film, Paper, Plate, and Chemical Manufacturing (325992)
Number of Workers: 70 at plant in Oklahoma City; 130,000 corporate-wide
Source (Date): Gabriel John, EH&S Engineer and VPP Coordinator, Xerox Corporation; Danielle Gibbs, OSHA's National Office (September 2010)
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