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What follows are instructions for applying to the VPP mobile workforce way to
participate. We encourage you to involve employees and managers in completing
your application. After OSHA reviews and accepts your written submission, we
will schedule an onsite evaluation.
If you are in a state that operates its own OSHA-approved program, check with
your state agency to learn specifics regarding its VPP application process.
There is some paperwork required in the application process, but we encourage
you to use as much existing material as possible. Please provide a list/index of
all materials you choose to attach to your application. Most worksites have
found that, in the process of applying, they gain a greater understanding of
worker protection and discover ways to improve their safety and health
VPP reviewers don’t look for a single correct way to meet VPP requirements. They
want to see a system that works for you. Some successful safety and health
management systems involve substantial written documentation, and others do not.
Small businesses, in particular, often are able to implement excellent safety
and health processes with relatively little documentation.
If you need more information, you can contact your nearest OSHA VPP Manager or
Coordinator through OSHA’s Regional and Area Offices. In addition to answering
your questions, your Regional VPP Manager or Coordinator can refer you to VPP
participants in your area. We encourage you to contact participants. They are
happy to share their experience.
c) Mailing Address (if different from above)
c) Phone Number
d) E-mail Address
VPP Contact for OSHA correspondence (if different from Manager)
c) Phone Number
d) E-Mail Address
Designated Geographic Area (DGA)
Identify the Designated Geographic Area (DGA) you are proposing.
a) A DGA cannot be smaller than an OSHA Area Office boundary and cannot exceed
an OSHA Regional Office boundary.
b) OSHA, after consulting with an applicant and considering the applicant’s
preference, will define a geographic area for VPP participation.
c) The successful mobile workforce applicant will achieve VPP participation and
receive OSHA recognition for all its temporary work projects and resident
contractor work projects in the DGA.
Provide a list of current work projects, including addresses, within the
proposed DGA, plus a list of work projects expected to be active or scheduled
within the next 12 months.
Name (if different from above)
VPP Contact (if applicable)
c) Phone Number
d) E-mail Address
Provide information for each union separately, in accordance with established
guidelines (See Appendix E Union Support for Participation)
Full Name of Union and Local #
Authorized Bargaining Unit Representative’s Name
Number of Employees and Contractor/Subcontractor Employees within the
Proposed Designated Geographic Area (DGA)
Total estimated number of employees working at your sites within the proposed DGA. This total must include regular hires, temporary employees, and
Number of temporary employees that you supervise within the DGA.
Estimated number of contractor/subcontractor employees within the DGA.
Type of Work Performed, Products Produced, and Typical Hazards
Provide a comprehensive description of the work performed at your sites
within the DGA and the type of products produced.
Provide a description of the types of hazards typically associated with your
industry and your work projects/sites within the proposed DGA.
Applicant’s Industrial Classification Codes
Provide what you believe to be the 6-digit North American Industry
Classification System (NAICS) code and the 4-digit Standard Industrial
Classification (SIC) code that best represents the work you perform at your
sites within the proposed DGA. OSHA will verify and ultimately will assign you a
NAICS code for purposes of VPP.
Contact your Regional VPP Manager or Coordinator if you are having difficulty
identifying an appropriate code. You can also find NAICS and SIC information on
Injury and Illness Performance
See Appendix A Definitions for explanation of terms; Appendix B for instructions
on calculating injury and illness rates; Appendix C for an alternative
calculation for qualifying small employers; and Appendix D for VPP’s policy on
phasing in contractor rates.
Using information from your OSHA injury and illness logs (OSHA-300), complete
and submit Table 1 in section V. below.
- Provide your DGA’s 3-year recordable nonfatal Total Case Incidence Rate (TCIR)
for your combined workforce, that is, all employees, including regular hires,
temporary employees, and contractor/subcontractor employees.
- Provide your DGA’s 3-year recordable nonfatal Days Away from Work, Restricted
Activity, or Job Transfer (DART) incidence rate for your combined workforce.
Each applicant will develop a unique Participation Plan that includes a
discussion of safety and health management system elements that differ in
substance or emphasis from the basic VPP safety and health management system
requirements. See Appendix G for an example of a Participation Plan.
Employee Support for VPP Participation
Your application for VPP participation must reflect the support of your
If, at the time of application, a majority of your employees, including
temporary employees and contractor/subcontractor employees, are represented by
unions, you must provide to OSHA signed documentation that the unions either
support VPP participation or are not opposed to participation. See Appendix E
for more information about this requirement.
At non-union sites, OSHA will verify employee support during onsite evaluations
when the OSHA VPP team interviews employees.
VPP applications must include a signed statement affirming the following:
You will comply with the Occupational Safety and Health Act (OSH Act) and will
correct in a timely manner all hazards discovered through self-inspections,
employee notification, accident investigations, OSHA onsite reviews or
enforcement inspections, process hazard reviews, annual evaluations, or any
other means. You will provide effective interim protection as necessary to keep
employees safe while corrections are being made. Federal applicants also agree
to comply with Title 29 of the Code of Federal Regulations (CFR), Part
1960—Basic Program Elements for Federal Employees.
Correction of Deficiencies
You will correct any work project/site deficiencies related to compliance with
OSHA requirements and identified during any OSHA onsite review. The correction
deadline will depend on the nature of the deficiency, will be determined by the
OSHA VPP Team Leader, and in no instance will exceed 30 days.
System Implementation and Oversight
The systems and procedures of the VPP safety and health management system are in
place and effectively maintained at all your work projects/sites, and management
provides effective oversight to assure VPP-quality safety and health protection
throughout the DGA.
Following approval, you will continue to meet and maintain the requirements of
All employees, including newly hired employees, temporary employees, and
contract/subcontractor employees, will have the VPP explained to them before
they perform any work. This explanation will include employee rights under VPP
and under the OSH Act or 29 CFR 1960.
Protection from Discrimination
You will protect employees engaged in safety and health activities, including
those specifically given safety and health duties as part of your safety and
health management system, from discriminatory actions resulting from their
activities/duties, just as Section 11(c) of the OSH Act and 29 CFR 1960.46(a)
protect employees who exercise their rights.
Employee Access to Information
Employees will have access to the results of self-inspections, accident
investigations, and other safety and health management system data upon request.
For a unionized workforce, this requirement may be met through employee
representative access to these results.
To enable OSHA to determine initial and continued VPP approval, you will
maintain and make available for OSHA review the following information:
The written safety and health management system.
- All documentation enumerated under Section VI.C.6.e-f of the January 9, 2009
Federal Register Notice.
- Any agreements between management and authorized collective bargaining agent(s) concerning safety and health.
- Any data necessary to evaluate the achievement of individual Merit or
One-Year Conditional goals, if applicable.
Each year by February 15, you will submit to your designated OSHA VPP Contact
the following information: Mobile Workforce Participants Injury and Illness
Injury and Illness Rates. These rates will include all employees over whom
the applicant has responsibility and authority for safety and health, including
regular hires, plus temporary employees and contractor/subcontractor employees.
The DGA’s total recordable case incidence rate (TCIR) for injuries and
illnesses for the previous calendar year.
- The DGA’s incidence rate for cases involving days away from work, restricted
work activity, and job transfer (DART rate) for the previous calendar year.
- If you do not maintain rate information for your contractors/subcontractors,
you may still apply using the phase-in policy. See Appendix D for more
information on the phase-in policy if relevant to your application.
- The total number of cases for each of the above two rates.
- Total hours worked.
- Estimated average employment for the past full calendar year.
- Annual Self-Evaluation. A copy of the most recent annual self-evaluation of
your safety and health management system, in the format and including the
information specified by OSHA. Indicate any changes in the percentage of
employees represented by unions that would have the effect of changing your
union support requirement.
- A description of any success stories, such as reductions in workers’
compensation rates or increases in employee involvement.
Whenever a significant organizational or ownership change occurs, you will
provide OSHA within 60 days a new Statement of Commitment signed by both
management and, when applicable, any authorized collective bargaining agents.
Collective Bargaining Unit Changes
Because the percentage of employees represented by unions within the DGA may
change, you will report to OSHA, as part of your annual self-evaluation, any
change in this percentage that may have the effect of changing your union
support requirement. Whenever a change occurs in the authorized collective
bargaining unit representative, you will provide OSHA within 60 days a new
signed statement indicating that the new representative supports VPP
Whenever OSHA needs to visit a particular work project that you do not control,
you will inform and gain written permission from the host/controlling employer
for OSHA to enter. You understand that OSHA, prior to its visit, will give
reasonable notice to the host/controlling employer.
You will provide OSHA by February 15 of each year a list including addresses
of all active work projects/sites plus all work projects/sites scheduled or
expected to commence within the next 12 months within the DGA.
- The site list must identify sites where written permission has been obtained
authorizing OSHA to send a VPP team to conduct an onsite evaluation.
- At the time of application there must be at least one active site and one
additional site scheduled within the DGA. These may be mobile work
projects/sites, resident contract sites, or a combination of both.
VPP Safety and Health Management System
Describe your written safety and health management system, including safety and
health policies, procedures, systems, and programs. See Appendix A Definitions
for an explanation of how the term safety and health management system is used
Program descriptions must contain pertinent information that clearly explains
the management and administration of the program, such as responsibilities and
types of documentation maintained. Include those systems applicable to
operations considered highly hazardous (e.g., Lockout/Tagout, Confined Space,
Process Safety Management) and those considered non-routine.
Please provide a list/index for any supporting documentation you choose to
attach to the written description of the program.
Management Leadership and Employee Involvement
Management must clearly demonstrate its commitment to meeting and maintaining
the requirements of the VPP and taking ultimate responsibility for worker safety
and health. Attach a copy of your top-level safety policy specific to your
operations within the DGA.
a) Briefly describe how your company’s safety and health function fits into your
overall management organization.
b) Attach a copy of your organization chart.
Authority and Responsibility
a) Describe what authority and responsibility you give managers, supervisors,
and regular employees regarding safety and health and hazard mitigation.
b) Include authority and responsibility for safety and health at sites where
employees work with little or no supervision.
a) Briefly describe your accountability system used to hold managers, line
supervisors, and employees responsible for safety and health. Examples are job
performance evaluations, disciplinary policies, and contract language.
b) Describe system documentation.
a) Identify the available safety and health resources. Describe the safety and
health professional staff available, including appropriate use of certified
safety professionals (CSP), certified industrial hygienists (CIH), other
licensed health care professionals, and other experts as needed, based on the
risks at your work projects/sites.
b) Identify any external resources (including corporate office and private
consultants) used to help with your safety and health management system.
Goals and Planning
a) Identify your annual plans that set specific safety and health goals and
b) Describe how planning for safety and health fits into your overall management
a) Provide a copy of the most recent annual self-evaluation of your safety and
health management system within the proposed DGA. Include assessments of the
effectiveness of the VPP elements listed in these application guidelines,
documentation of action items completed, and recommendations for improvement.
b) Describe how you prepare and use the self-evaluation.
a) List at least three meaningful ways employees/subcontractors are involved in
your safety and health management system. These must be in addition to
employees/subcontractors reporting hazards and attending training.
b) Provide specific information about decision processes in which
employees/subcontractors participate, for example, hazard assessment,
inspections, safety and health training, and/or evaluation of the safety and
health management system.
Describe how you notify employees about site participation in the VPP, their
right to register a complaint with OSHA, and their right to obtain reports of
inspections and accident investigations upon request. Methods may include new
employee orientation, intranet or email if all employees have access, bulletin
boards, toolbox talks, or group meetings.
Contractor/Subcontractor Safety and Health
a) If applicable, describe the process used for selecting
contractors/subcontractors to perform jobs at your work projects/sites.
b) Describe your documented oversight and management system for ensuring that
all contract workers who do work for you within the DGA enjoy the same safe and
healthful working conditions and the same quality protection as your regular
Attach any project/site maps you believe may be helpful to the application
Pre-screening and Oversight
Describe the process used at the corporate level to ensure and verify that
projects/sites within the DGA are effectively implementing and maintaining your
safety and health management system policies and procedures.
Baseline Hazard Analysis
a) Describe the methods you use for baseline hazard analysis to identify hazards
associated with your specific or typical work environments at projects/sites
within the DGA. For example, air contaminants, noise, or lead.
b) Identify the safety and health professionals involved in the baseline
assessment and subsequent needed surveys.
c) Explain any sampling rationale and strategies for industrial hygiene surveys
Hazard Analysis of Routine Jobs, Tasks, and Processes
a) Describe the system you use (when, how, who) for examination and analysis of
safety and health hazards associated with routine tasks, jobs, processes, and/or
(1) You should base priorities for hazard analysis on historical evidence,
perceived risks, complexity, and the frequency of jobs/tasks completed at your
b) Provide specific examples of some analyses you have performed and any forms
(2) In construction, the emphasis must be on special safety and health hazards
of each craft and phase of work.
Hazard Analysis of Significant Changes
Explain how, prior to activity or use, you analyze significant changes to
identify uncontrolled safety and health hazards and the actions needed to
eliminate or control these hazards. Significant changes may include non-routine
tasks and new processes, materials, equipment, and work projects/sites.
a) Describe the safety and health routine general inspection procedures you use
at your work projects/sites. Indicate how often you conduct self-inspections.
b) Indicate who performs inspections, and their level of hazard recognition
training and safety and health competency.
c) Describe how you track any hazards through to elimination or control.
d) For routine health inspections, summarize the testing and analysis procedures
used and qualifications of personnel who conduct them.
e) Include some completed forms used for self-inspections.
Employee Reports of Hazards
a) Describe the different ways employees/subcontractors notify management of
uncontrolled safety or health hazards. NOTE: An opportunity to use a written
form to notify management about safety and health hazards must be part of your
b) Explain procedures for follow up and tracking corrections and reporting back
c) If you do not always serve as the controlling employer, describe how you
handle hazards affecting your employees/subcontractors that may be created by a
controlling employer or other subcontractor at a work project/site.
Accident and Incident Investigations
a) Describe your written procedures for investigation of employee/subcontractor
accidents, near misses, first-aid cases, and other incidents.
b) What training do investigators receive?
c) How do you determine which accidents or incidents warrant investigation?
d) Describe how you use investigation results.
a) Describe the system you use for safety and health data analysis.
b) Indicate how you collect and analyze data from all sources, including
injuries, illnesses, near-misses, first-aid cases, work order forms, incident
investigations, inspections, and self-audits.
c) Describe how you use analysis results.
Hazard Prevention and Control
Applicants and participants must be in compliance with any hazard control
program required by an OSHA standard, such as PPE, Respiratory Protection,
Lockout/Tagout, Confined Space Entry, Process Safety Management (PSM),
Bloodborne Pathogens, etc. VPP applicants and participants must periodically
review these programs (most OSHA standards require an annual review) to ensure
they are up-to-date.
Applicants and participants who are covered by the PSM standard must
additionally submit answers to all applicable questions found in the VPP PSM
Application Supplement A. (Other Supplements will be used during annual
self-evaluations and OSHA onsite approval/reapproval visits. See PSM Supplements
in Appendix A Definitions)
Hierarchy of Controls
a) Engineering Controls
(1) Describe and provide specific examples of engineering controls you have
implemented that either eliminated or limited hazards by reducing their
severity, their likelihood of occurrence, or both. Engineering controls include,
for example, reduction in pressure or amount of hazardous material, substitution
of less hazardous material, reduction of noise produced, fail-safe design, leak
before burst, fault tolerance/redundancy, and ergonomic design changes.
b) Administrative Controls
(2) Although not as reliable as true engineering controls, this category also
includes protective safety devices such as guards, barriers, interlocks,
grounding and bonding systems, and pressure relief valves to keep pressure
within a safe limit.
(1) Briefly describe the ways you limit daily exposure to hazards by adjusting
work schedules or work tasks, for example, job rotation.
c) Work Practice Controls
(1) Describe and provide examples of your work practice controls. These include,
for example, workplace rules, safe and healthful work practices, specific
programs to address OSHA standards, and procedures for specific operations that
require permits, labeling, and documentation.
d) Personal Protective Equipment
(2) Identify major technical programs and regulations that pertain to your work
projects/sites, such as lockout/tagout, process safety management, hazard
communication, machine guarding, and fall protection.
Describe and provide examples of required personal protective equipment your
employees/subcontractors use and what PPE the OSHA team members will need to
bring to your work projects/sites.
Enforcement of Safety and Health Rules
Describe the procedures you use for disciplinary action or reorientation of
managers, supervisors, and other employees/subcontractors who break or disregard
safety and health rules.
a) Summarize your written system for monitoring and maintaining workplace
equipment to predict and prevent equipment breakdowns that may cause hazards.
b) Provide a brief summary of the type of equipment covered.
Occupational Health Care Program
a) Describe your onsite and offsite medical service and physician availability.
b) Explain how you utilize the services of licensed occupational health care
c) Indicate the coverage provided by employees trained in first aid, CPR, and
other paramedical skills, their training, and available equipment.
a) Describe your employee/subcontractor emergency planning and preparedness
system. Provide information on emergency drills and training, including
evacuations. Describe how emergency procedures are communicated to all new
employees, subcontractor employees, and visitors upon their initial arrival at a
b) As applicable, address how you ensure VPP-quality emergency preparedness in
light of the mobile nature of your workforce.
Safety and Health Training
Describe the formal and informal safety and health training provided for
managers, supervisors, and employees/subcontractors.
Identify training protocols, schedules, and information provided to
supervisors and employees/subcontractors on programs such as hazard
communication, personal protective equipment, and handling of emergency
Describe how you verify the effectiveness of the training you provide.
Injury and Illness Performance
See Appendix A for definitions of terms; Appendix B for instructions on
calculating injury and illness rates; Appendix C for an alternative calculation
for qualifying small employers; and Appendix D for VPP’s policy on phasing in
Mobile Workforce Injury and Illness Rate Requirements
To qualify for VPP Star, both your DGA 3-year Total Case Incidence Rate (TCIR)
and your DGA 3-year Days Away, Restricted Activity, Job Transfer (DART) rate
must be below at least 1 of the 3 most recent years of specific industry
national averages for nonfatal injuries and illnesses at the most precise level
published by the U.S. Department of Labor’s Bureau of Labor Statistics (BLS).
OSHA will compare all submitted rates against the most advantageous single
year that would qualify the applicant out of the last 3 published years.
If, after completing Table 1 (see V.B. below), you determine that either your
3-year TCIR, DART rate, or both are at or above your industry’s average in all 3
comparison years, you still may qualify for VPP participation at the Merit
level. If this is the case, specify your short- and long-term goals for reducing
your rates to a level below the industry average, thereby achieving Star rate
requirements. Include specific methods you will use to address this problem. It
must be feasible to reduce rates sufficiently to meet Star rate requirements
within 2 years.
TABLE 1: Mobile Workforce Injury and Illness Rate Calculations for All Work
Projects/Sites within the DGA
Table 1 tracks the “combined workforce injury and illness rates” of all
employees over whom the applicant has responsibility and authority for safety
and health. These rates must be calculated from data that combine the
applicant’s regular workforce employees, temporary employees, and all
contractor/ subcontractor employees within the DGA.
OSHA considers the most recent 3-year recordable injury and illness
experience for all work conducted within the DGA (including work conducted by
contractors and subcontractors for the applicant) and compares the combined
workforce experience with industry averages published by the Bureau of Labor
Calculate the 3-year recordable Total Case Incidence Rate (TCIR) for your
combined workforce within the DGA.
Calculate the 3-year recordable incidence rate for cases involving days away
from work, restricted work activity, and job transfer (DART rate).
Alternative Rate Calculation. Some applicants, usually smaller employers with
a limited number of employees/contractors/subcontractors and/or hours worked,
may use an alternative method for calculating incidence rates. Review Appendix C
for more information about the alternative rate calculation.
Phase-in of combined workforce injury and illness rate requirement. OSHA
expects to receive a 3-year combined workforce TCIR and DART rate from each
mobile workforce applicant. However, for a limited time period, a phase-in of
this combined workforce rate requirement is available for applicants who do not
maintain sufficient contractor/subcontractor data. Review Appendix D for more
information about the phase-in policy if relevant to your application.
TABLE 1: Mobile Workforce Applicant/Participant Recordable Nonfatal Injury and
Illness Case Incidence Rates for All Work within the Designated Geographic Area
Total Work Hours
Total Number of Injuries
Total Number of Illnesses
Sum of Injuries and Illnesses
TCIR for Injuries and Illnesses
Total # of Injuries Involving DART
Total # of Illnesses Involving DART
Sum of Injury & Illness Cases Involving DART
3 Years Ago
2 Years Ago
3 Year Totals
BLS Rates for NAICS code_________
Year 1 (3 years ago)
Year 2 (2 years ago)
Year 3 (last year)
Percent above or below BLS year ______ National Average (compare both your
3-year rates with the single most advantageous year)
Appendix A: Definitions
The following definitions apply to use of these terms within OSHA’s Voluntary
Protection Programs (VPP).
1-Year Conditional Goal. A target for correcting deficiencies in safety and
health management system elements or sub-elements identified by OSHA during the
onsite evaluation of a Star participant. Such deficiencies, which indicate that
a site no longer fully meets Star requirements, must be corrected within 90
days, and the participant must then operate at the Star level for 1 year for the
participant’s conditional status to be lifted. Failure to meet this requirement
will result in termination from VPP.
2-Year Rate Reduction Plan. A strategy employed whenever a Star participant’s
3-year rates rise above the national average and call into question the
participant’s continuing VPP qualification. The plan is developed jointly by the
participant and OSHA and must be approved by the Regional Administrator. It must
identify and address any safety and health management system deficiencies
related to the high rates, correction methods, and timeframes, and must include
quarterly participant progress reports.
90-Day Items. Compliance-related issues that must be corrected within a maximum
of 90 days, with effective protection provided to employees in the interim.
Annual Self-Evaluation. A participant’s yearly self-assessment to gauge the
effectiveness of all required VPP elements and any other elements of the
participant’s safety and health management system.
A document written by a participant and submitted to OSHA by February 15th
each year, consisting of the following information: Updated names and addresses;
the participant’s and applicable contractors’ injury and illness case numbers
and rates, average annual employment and hours worked for the previous calendar
year; a copy of the most recent annual self-evaluation of the participant’s
safety and health management system; descriptions of significant changes or
events; progress made on the previous year’s recommendations; Merit or 1-Year
Conditional goals (if applicable); any success stories; and any other
information required by OSHA.
In addition, participants covered by the Process Safety Management Standard (PSM)
are required to respond to applicable questions from the annual VPP PSM
In addition, participants who have been approved within a Designated
Geographic Area (DGA) must submit a list, including addresses, of all active
worksites plus a second list of any work projects scheduled or projected to
begin during the upcoming year.
Applicable Contractor. An employer who has contracted with a General Industry,
Maritime, or Federal Agency (non-construction) site-based applicant/participant
to provide specified services and whose employees:
Worked at least 1,000 hours at the VPP site-based applicant/participant’s
worksite in any calendar quarter within the last 12 months.
Are not directly supervised in day-to-day activities by
The concept of applicable contractor does not include temporary employees or
other contractor employees who are regularly intermingled with a site-based
applicant/participant’s employees and under direct supervision by management.
Moreover, construction applicants/participants do not break out this category of
employee. Therefore, applicable contractor reporting requirements do not apply
to applicants/participants whose main activity is construction, regardless of
the chosen way to participate.
Accepted Application. An application that has been reviewed by the Regional
Office -- or the National Office for certain corporate and Demonstration Program
applications -- and found to be complete. Also referred to as a completed
Backup Team Leader. A member of an onsite evaluation team who provides
assistance to the team leader and can assume his/her duties when necessary.
Combined Workforce. An applicant/participant’s regular workforce employees,
including temporary employees, plus all contractor/subcontractor employees.
Mobile workforce applicants/participants and all construction
applicants/participants must use combined workforce data when calculating and
reporting injury and illness rates.
Compliance Officer. A Federal compliance safety and health officer (CSHO).
Compressed Approved Process. A VPP onsite evaluation procedure that OSHA may
choose to employ for site-based Star participants seeking reapproval and meeting
specified criteria. A CAP evaluation examines all the VPP elements assessed
during a standard onsite evaluation but places particular attention on changes
since the last evaluation and the most recent annual self-evaluation.
Contract Employees. Those individuals who are employed by a company that
provides services under contract to the VPP applicant/participant, usually at
the VPP applicant/participant’s worksite.
Corporate Participation. See Way to Participate, below. A category of
participation available to large corporations that provides streamlined
application and approval procedures. To qualify, the corporation must (1) commit
to bringing into VPP multiple site-based facilities and/or worksites within
Designated Geographic Areas (DGAs); (2) utilize a standardized safety and health
management system organization-wide; and (3) employ pre-screening processes at
all applicant facilities/DGAs before applying for VPP approval and ongoing
oversight once approved.
Days Away, Restricted, and/or Transfer Case Incidence Rate (DART rate). The rate
of all injuries and illnesses resulting in days away from work, restricted work
activity, and/or job transfer. This rate is calculated for an individual
worksite, all worksites within an applicant/participant’s Designated Geographic
Area (DGA), or all worksites of an employer for a specified period of time
(usually 1 or 3 years).
Directorate of Cooperative and State Programs (DCSP). The OSHA Directorate
responsible for coordinating and overseeing OSHA’s VPP and other cooperative
programs, located in OSHA’s National Office.
DCSP Regional Coordinator. A DCSP VPP staff member who is assigned to coordinate
VPP-related regional activities, including the review and processing of reports
and resolution of policy issues.
Demonstration Program. The program within VPP that enables employers with VPP-quality
safety and health protection to test alternatives to current VPP eligibility and
performance requirements. If a Demonstration Program is judged successful, its
alternative ways to achieve safety and health excellence may lead to changes in
Federal Register. The official Federal government publication, issued by the
Government Printing Office (GPO), in which OSHA announces the philosophy and
criteria for VPP approval and participation in a public notice commonly referred
to as the VPP Federal Register Notice or the Federal Register Notice.
General Contractor. A construction site owner or site manager who controls
construction operations and has contractual responsibility for assuring safe and
healthful working conditions at a worksite.
Injury/Illness Rates. Numerical rates that:
Represent an applicant/participant’s nonfatal recordable injuries and
illnesses at an individual worksite or within a Designated Geographic Area.
Are an important factor when OSHA assesses an applicant/participant’s
qualification for VPP.
Mentoring. The assistance that a VPP participant provides to another employer to
prepare that employer for VPP application and/or to improve that employer’s
safety and health management system.
Merit Goal. A target for improving one or more deficient safety and health
management system elements for a participant approved to the Merit program. A
Merit goal must be met in order for a participant to achieve Star status.
Merit Program. The program within VPP designed for employers that have
demonstrated the potential and commitment to achieve Star quality, but that need
to further improve their safety and health management system and/or injury and
illness performance. OSHA gives a Merit Program participant specified Merit
goals that it must meet in order to achieve Star status and continue within VPP.
Mobile Workforce Participation. See Way to Participate, below. A category of
participation available to employers whose work is characterized by short-term
operations and employees who move physically from one work project to another;
or resident contractor operations performed at two or more fixed worksites.
Distinguishing features of mobile workforce participation include a
Participation Plan unique to the applicant/participant and a Designated
Geographic Area (DGA).
Onsite Assistance Visit. A visit to an applicant/participant by an OSHA VPP
Manager, Compliance Assistance Specialist, or other non-enforcement personnel,
to offer assistance including, for example, help with the VPP application, a
records review, and/or general observations about the employer’s safety and
health management system.
Onsite Evaluation. A visit to an applicant/participant worksite or headquarters
by an OSHA onsite evaluation team to determine whether the applicant/participant
qualifies for initial approval, continued participation, or advancement within VPP.
Onsite Evaluation Report. A document written by the OSHA onsite evaluation team
and consisting of the site report and site worksheet. This document contains the
team’s assessment of an applicant/participant’s safety and health management
system and its implementation, a review of injury and illness rates, and the
team’s recommendation regarding approval of the applicant or reapproval of the
participant to VPP.
Onsite Evaluation Team. An interdisciplinary group of OSHA professionals and
sometimes other government employees who conduct onsite evaluations. The team
normally consists of a team leader, a backup team leader, safety and health
specialists, and other specialists as appropriate.
Outreach. Assistance and information a VPP participant provides to prospective
VPP applicants, other employers, employer and employee organizations, and the
general public, for the purpose of promoting safety and health principles and
practices and VPP. Outreach activities include, but are not limited to:
Conducting VPP workshops at conferences.
- Conducting safety and health training workshops.
- Holding community safety days.
- Serving as an advocate for VPP within the business community.
- Participation in OSHA Strategic Partnerships, OSHA Challenge, and Alliances.
- Making presentations on safety and health topics at conferences and other
Participation Plan. A unique, written strategy submitted to OSHA by a mobile
workforce applicant as part of its VPP application. A participation plan:
Explains how the applicant’s safety and health management system protects
employees who move from one worksite/project to another.
May include a discussion of safety and health management system elements that
differ in substance or emphasis from the basic VPP system requirements.
Must include a proposed Designated Geographic Area (DGA) for VPP
A Sample Participation Plan is included in the Mobile Workforce Application
Pre-screening. An internal process, applicable to the mobile workforce and
corporate ways to participate, to ensure and verify that sites/DGAs:
Are effectively implementing the applicant/participant’s safety and health
management system policies and procedures.
Meet all applicable VPP requirements, including, following approval, the
requirement to continuously improve. For the corporate way to participate,
applicant sites are expected to meet VPP Star requirements.
For the corporate way to participate, that sites/DGAs have completed the VPP
application before submitting it to OSHA
Often used in conjunction with the term “oversight,”, as in “pre-screening and
oversight,” to indicate the continuing need, following VPP approval, for
corporate/DGA monitoring of participating sites to ensure they maintain and
improve their safety and health management systems.
Process Hazard Analysis (PHA). For the purpose of VPP, a PHA is an organized and
systemic effort to identify and analyze the significance of potential hazards
associated with the processing or handling of highly hazardous chemicals.
Process Safety Management (PSM). A reference to OSHA standard 29 CFR 1910.119
and 1926.64, which covers all employers who either use or produce highly
hazardous chemicals exceeding specified limits.
PSM Level 1 Auditor.
Special Government Employees may alternatively serve in the capacity of a PSM
Level 1 Auditor upon demonstrating training and experience equivalent to the
An OSHA employee with experience in the chemical processing or refining
industries. A PSM Level 1 Auditor is responsible for evaluating employer PSM
operations during OSHA VPP visits (or inspecting PSM operations during OSHA
Specific requirements for a PSM Level 1 Auditor include:
OSHA Training Institute (OTI) Course 3300, Safety and Health in the Chemical
OTI Course 3400, Hazard Analysis in the Chemical Processing Industries.
Advanced training such as OTI Course 3410, Advanced Process Safety
Management, or other equivalent specialized seminars in PSM.
- Prior experience with chemical industry safety. This should include
experience obtained in any one of the following ways:
- Through accident investigations in chemical, petrochemical, or refinery plants
involving fires, explosions, and/or toxic chemical releases;
- Through previous chemical inspections involving process safety management
- Through previous chemical industry employment.
PSM Supplement A. Also known as the PSM Application Supplement or the static
list. A series of questions designed to establish a basic understanding of a VPP
applicant’s PSM policies and procedures. Applicants covered by the PSM Standard
must submit responses to all questions on the PSM Application Supplement when
they submit their written VPP application.
PSM Supplement B. Also known as the PSM Annual Questionnaire. A document
compiled annually by OSHA that uses selected questions from OSHA’s Dynamic
Inspection Priority Lists, also known as the dynamic question lists. The
selected questions change from year to year. The PSM Questionnaire must be
completed and submitted each year by VPP participants covered under the PSM
standard as part of their annual submission to OSHA.
PSM Supplement C. Also known as the PSM Onsite Evaluation Questionnaire.
Questions selected by the VPP Onsite Evaluation Team Leader and PSM Level 1 or
equivalent team members from OSHA's dormant PSM Inspection Priority Lists, also
known as the dynamic question lists. The questions are selected just prior to
commencing a VPP onsite evaluation and presented to the VPP
applicant/participant during the evaluation. Normally, each
applicant/participant covered by the PSM standard will receive a different set
of questions at the time of the preapproval onsite evaluation and then during
each subsequent onsite reevaluation.
Recommendations. Suggested improvements noted by the onsite evaluation team that
are not requirements for VPP participation but that would enhance the
effectiveness of the applicant/participant’s safety and health management
system. (Compliance with OSHA standards is a requirement, not a recommendation.)
Resident Contractor. For the purpose of VPP, resident contractor refers to a
Provides ongoing, long term onsite services to a host employer.
Normally will occupy a recognizable, delineated work area within the host
Safety and Health Management System. For the purposes of VPP, a method of
preventing employee fatalities, injuries and illnesses through the ongoing
planning, implementation, integration, and control of four interdependent
elements: Management Leadership and Employee Involvement; Worksite Analysis;
Hazard Prevention and Control; and Safety and Health Training.
Site-Based Participation. See Way to Participate, below. A category of VPP
participation characterized by fixed, ongoing or long-term work operations at a
single facility. It is available to employers of private-sector fixed worksites
in general industry and the maritime industry; Federal-sector fixed worksites;
and certain long-term construction worksites. These employers must control site
operations and have ultimate responsibility for assuring safe and healthful
working conditions. Site-based participation also is available to resident
contractors at site-based VPP participants; and to resident contractors who are
part of a larger organization approved under the corporate way to participate
and who operate at a non-participating fixed worksite.
Small Business. A company having no more than 250 employees at any one facility,
and no more than 500 employees nationwide.
Special Government Employee (SGE). An employee volunteer from a VPP participant
or corporation who is knowledgeable in safety and health management system
assessment, formally trained by OSHA in the policies and procedures of the VPP,
and determined by OSHA to be qualified to perform VPP onsite evaluations. An SGE
may participate as a team member on VPP onsite evaluations. The OSHA directive
governing the VPP Special Government Employee Program is CSP 03-01-001, Policies
and Procedures Manual for Special Government Employee (SGE) activity conducted
under the auspices of the Occupational Safety and Health Administration's (OSHA)
Voluntary Protection Program, Jan. 4, 2002.
Star Program. The program within VPP designed for participants whose safety and
health management systems operate in a highly effective, self-sufficient manner
and meet all VPP requirements. Star is the highest level of VPP participation.
State Plan. A state-operated occupational safety and health program that has
received approval and partial funding from Federal OSHA. The states that operate
approved State Plans are commonly referred to as State Plan states.
Team Leader. The OSHA staff person who coordinates the OSHA onsite evaluation
team and ensures the performance of all evaluation activities.
Temporary Employees. Employees hired on a non-permanent basis by the
applicant/participant. Temporary employees are grouped with regular hires for
purposes of calculating employer injury and illness rates.
Termination. OSHA’s formal removal of a VPP participant from the program.
Alternatively, the act of ending a Demonstration Program.
Total Case Incidence Rate (TCIR). A number that represents the total nonfatal
recordable injuries and illnesses per 100 full-time employees. This rate is
calculated for an individual worksite, all worksites within an
applicant/participant’s Designated Geographic Area (DGA), or all worksites of an
employer for a specified period of time (usually 1 or 3 years).
VPP Activity Log. The monthly log of VPP activity that is submitted to DCSP by
the Regional Offices.
VPP Annual Data Spreadsheet. The yearly report prepared by the Regional VPP
Manager and submitted electronically to DCSP that provides information on the
annual TCIR and DART rates of participants.
VPP Application Status Report. A monthly report prepared by the Regional VPP
Manager and submitted to DCSP that provides information on VPP applications,
including the number of applications pending in the Region and the number of
applicants whose onsite evaluation has not yet begun.
VPP Approval Ceremony. An event planned by the approved participant and normally
held at the participant’s approved work location or headquarters, where a
representative from OSHA recognizes the participant’s achievement and, for
initial program approvals, presents the VPP plaque and VPP flag.
VPP Automated Data System (VADS). A database that includes information on
approved VPP participants (under Federal or State Plan jurisdiction) and VPP
applicants (under Federal jurisdiction).
VPP Manager. The OSHA employee directly responsible for the day-to-day
operations of the VPP in a particular OSHA Region.
VPP Participant Representative. The applicant/participant employee designated as
the primary contact with OSHA for matters concerning VPP.
Way to Participate. One of three primary ways an employer may seek VPP approval.
These are: site-based, mobile workforce, and corporate. The principles and
features of VPP-quality safety and health management systems are generally
consistent for all three ways to participate. There are some differences,
however, in the VPP requirements for system details and implementation and the
manner in which OSHA evaluates applicants/participants.
Withdrawal. Decision by an applicant/participant to discontinue its VPP
application process or its approved participation.
Worksite. For VPP purposes, a worksite is a location where work is performed by
employees of an employer.
Appendix B: Injury and Illness Rate Calculations and Table Instructions
Follow these steps to complete Table 1 above. Submit Table 1 with your application.
Estimate total hours worked annually by all of your employees for each of the
last 3 years within the DGA. Applicants may follow the phase-in guidelines. See
the example table in Appendix D. Include temporary and contract/subcontractor
employees for whom you provide oversight. Include all overtime hours and
management staff’s hours. Enter in the appropriate places in Column A. Enter the
3-year total at the bottom of Column A.
Enter the total number of recordable nonfatal injuries for each of the last 3
years in Column B. Enter the 3-year total.
Enter the total number of recordable nonfatal illnesses for each of the last
3 years in Column C. Enter the 3-year total.
For each of the past 3 years, combine the injuries and illnesses and enter in
Column D. Combine the injury and illness 3-year totals and enter.
Calculate your DGA Total Case Incidence Rate (TCIR) for each of the past 3
years and for the 3 years combined. Enter in Column E.
a. To calculate your TCIR, use the formula (N/EH) x 200,000 where
N = Sum of the number of recordable non-fatal injuries plus illnesses in a given
time frame (either 1 year for an annual rate or 3 years for 3-year combined rate). b. For example, to calculate your 3-year combined TCIR:
EH = Total number of hours worked by all employees in a given time frame
(either1 year for an annual rate or 3 years for a 3-year combined rate).
200,000 = Equivalent of 100 full-time workers working 40-hours per week, 50
weeks per year.
3-Year TCIR = [(#inj + #ill) + (#inj + #ill) + (#inj + #ill)] ÷ [Hours + Hours +
Hours] x 200,000
Repeat steps 2 to 4, except substitute injuries and illnesses that resulted
in days away from work, restricted work activity, and/or job transfer. Enter in
Columns F, G, and H.
Calculate your DGA incidence rate for days away from work, restricted work
activity, and/or job transfer (the DART rate) for each of the past 3 years and
for the 3 years combined. Enter in Column I.
To calculate your DART rate, use the same formula as in 5 above, except N = Sum
of the number of all recordable injuries plus illnesses resulting in days away
from work, restricted work activity, and/or job transfer in a given time frame.
Compare your DGA 3-year rates with your industry’s average rates for the 3
calendar years published most recently by the Bureau of Labor Statistics (BLS).
(The BLS publishes rates by NAICS code each year in its Occupational Injuries
and Illnesses Bulletin and at its website.) To qualify for VPP
Star, both of your DGA 3-year rates must be below the same 1 year of the 3 most
recent published years of specific industry national averages for nonfatal
injuries and illnesses, at the most precise level available.
If, after completing Table 1, you determine that your DGA 3-year TCIR, DART
rate, or both are at or above your industry’s average for the 3 years published
most recently, you still may qualify for VPP participation at the Merit level.
If this is the case, specify your short- and long-term goals for reducing your
rates. Within 2 years, both of your rates must meet Star requirements; that is,
at a minimum, both rates must be below the industry average for the same 1 year
of the 3 years published most recently. It must be feasible to reduce your rates
to Star level within 2 years. Include specific strategies and actions you intend
to take to reduce your rates.
Appendix C: Alternative Rate Calculations for Qualifying Small Employers
Some applicants, usually small companies with limited numbers of
employees/contractors/ subcontractors and/or hours worked, may use an
alternative method for calculating their 3-year incidence rates. The alternative
method allows the employer to use the best 3 out of the most recent 4 years’
injury and illness experience. To determine whether you qualify for the
alternative rate calculation method, do the following:
Using your company’s actual employment statistics, determine hours worked
during the most recent calendar year by your regular employees/temporary
Then calculate a hypothetical TCIR assuming two recordable cases during the
Compare this hypothetical rate to the 3 most recently published years of BLS
combined injury/illness total recordable case incidence rates for your industry.
If the hypothetical rate (based on two cases) is equal to or higher than the
national average for your industry in at least 1 of the 3 years, you qualify for
the alternative calculation method. You may use the best 3 of the last 4
calendar years of employee injury/illness experience when calculating both the
3-year TCIR and the 3-year DART rate.
If you qualify for the alternative rate calculation and the temporary
phase-in of contractor data (see Appendix D), you still must submit at least 1
year of combined workforce data. At least 1 of the best 3 years that you submit
must include both regular employees (including temporary employees) plus any
Appendix D: Temporary Phase-In of Mobile Workforce Injury and Illness Rate
OSHA expects to receive a 3-year combined workforce rate from each applicant.
However, if you do not maintain rate information for your
contractors/subcontractors, you may still apply using the following temporary
For the year 2010, for new applicants and also for participants who applied
and were approved in 2009 using the phase-in rate requirement, OSHA expects to
Combined workforce TCIR and DART rates that reflect the experience of the
company’s regular workforce (including temporary employees) and
contractors/subcontractors for calendar years 2008 and 2009, plus
Company-only TCIR and DART rates (which include temporary employees) for
calendar year 2007.
Beginning January 1, 2011, all applicants and participants must provide to
OSHA combined workforce TCIR and DART rates for the 3 most recent calendar years
in the DGA. The data for each of these 3 calendar years must reflect the
experience of the company’s regular workforce (which includes temporary
employees) combined with its contractors/subcontractors at projects DGA-wide.
Appendix E: Union Support for Participation
OSHA expects each applicant to determine whether the requirement for union
support applies. Calculate the percentage of your employees (including temporary
employees) and contractor/subcontractor employees throughout the proposed DGA
who are represented by unions at the time of your application. Then use the
Mobile Workforce – Union Support for VPP Participation
Majority of employees are represented by unions
Signed statement(s) required.
Must be obtained from enough unions to represent a majority of employees.
Some employees but less than a majority are represented by unions
No statement of union support required.
No employees are represented by unions
Requirement not applicable.
When, at the time of application, a majority of an applicant’s employees and
contractor/ subcontractor employees are represented by unions, the applicant
must provide to OSHA written documentation of either union support for VPP
participation or union non-opposition to participation.
The percentage of employees represented by unions may change. Therefore, an
approved participant must report to OSHA, as part of its annual evaluation, any
change in this percentage that would have the effect of changing the
participant’s union support requirement.
Appendix F: Example of the Phase-in Policy for a Mobile Workforce Employer Who
Applies to VPP in 2010
An applicant is a framing contractor (specialty trade contractor) who works
within the DGA in the capacity of subcontractor. The applicant worked on
numerous projects over the past 3 years (2007 through 2009).
For some of these jobs the applicant used only employees regularly employed and
paid directly by the company. At other jobs it used company employees and also
contracted with other carpenter contractors (tiered subcontractors) who
performed tasks directed by the applicant.
Under the terms of the mobile workforce phase-in policy, for projects worked
during 2008 and 2009, the applicant must submit combined workforce estimated
rates that combine the hours and recordable injuries and illnesses of regular
employees plus subcontractor employees in the DGA.
For the projects worked during 2007, the applicant did not maintain sufficient
contractor/ subcontractor injury and illness data required by VPP. Therefore,
the phase-in policy allows the applicant to submit only the rates that reflect
the experience of its regular employees, including temporary employees
(highlighted in Sample Table below) in the DGA. (However, if the applicant had
maintained sufficient contractor/subcontractor data for 2007, he would have been
required to submit combined workforce data for all 3 years.)
SAMPLE TABLE for a 2010 VPP Mobile Workforce Applicant Using the Phase-In Policy
for Reporting Injuries and Illnesses
Total # of Cases
# of Cases Involving Days Away from Work, Restricted Activity or Job
3-Year Rates (2007-2009)
BLS National Average for 2007 (NAICS: 238130)
The applicant achieves VPP approval during 2010. The phase-in policy expires in
January 2011. Therefore, for the annual submission to OSHA due by February 15,
2011, the participant will be required to accurately report 3 years of injury
and illness data and rates (2008 through 2010) for its combined workforce of
regular employees and contractor/subcontractor employees.
Appendix G: Sample Applicant Participation Plan
PARTICIPANT PLAN for XYZ BUILDING CONSTRUCTION, INC.
XYZ Building Construction, Inc. is very pleased to have this opportunity to
apply for participation in OSHA’s Voluntary Protection Programs under the Mobile
Workforce way to participate. In the following pages we provide a snapshot of
our company. We have attempted to highlight aspects of our operation that differ
– in substance or emphasis -- from the basic requirements of the VPP safety and
health management system as we understand it. We also discuss features of our
safety and health efforts that we think are particularly important because of
the substantial hazards our employees encounter at construction sites.
Designated Geographic Area (DGA)
We are applying for participation at the division level. We understand that our
designated geographic area (DGA) can be a single OSHA Area Office, multiple OSHA
Area Offices within a Region, an entire State, or an entire Region. While XYZ
operates primarily within Region V, we prefer to limit our initial
participation. Therefore, we request that our DGA be two Area Offices, the
Milwaukee and Madison areas. XYZ Building Construction anticipates petitioning
Region V’s Regional Administrator at a future time to expand our DGA beyond the
two Area Office boundaries initially requested.
Unique Aspects of XYZ’s Mobile Workforce Safety and Health Management System
Subcontractor Oversight. XYZ generally operates as a general contractor, and we
utilize many subcontractors on our projects. As such, XYZ’s role in the
pre-bidding and pre-construction phase is more important than in a work
environment where most employees are regular hires and not temporary or
subcontracted employees. In addition, the company’s role in overseeing the
safety of subcontractors -- and also the safety of our own employees working
alongside subcontractors -- is more critical than in a setting where few or no
subcontractors may be used. Therefore, we expect the OSHA team’s VPP review will
place special emphasis on how XYZ emphasizes safety in the planning phase of
each project. Additionally, we expect the team will place special emphasis on
XYZ’s hazard analysis prior to initiating construction jobs and subsequent
phases of these projects. We anticipate a review that will carefully examine our
subcontractor pre selection process; safety performance criteria; and role in
monitoring and tracking hazards, injuries, and illnesses to ensure that
subcontractors are working safely at the worksites and following our required
Hazard Recognition and Control as a Non-controlling Employer. We also work as a
subcontractor at some large sites and must have policies and implemented
procedures to ensure the safety of our employees in those situations where we do
not control the site. Where XYZ performs work as a subcontractor, it sometimes
discovers hazards created by others not under XYZ’s control. Therefore, we
expect the OSHA team will focus on how well trained our unsupervised employees
are in hazard recognition and company policies and procedures that ensure
interim protections under such circumstances. These policies and procedures
include XYZ’s policy that employees have a right to refuse work if they observe
serious hazards and, if necessary to ensure their protection, have a right to
leave the worksite. A communication procedure also is in place to notify the
appropriate company officials of any uncontrolled hazards that our employees
discover, regardless of who controls the project or who created the hazard.
Whether XYZ employees are working at a site controlled by XYZ or controlled by
another employer, we require them to conduct daily inspections of their
workplace/area and of equipment to be used that day. We expect that this, too,
the OSHA team will assess.
Employee Involvement. XYZ and OSHA acknowledge that there may be some
differences in the way a mobile workforce implements strong employee
participation in safety and health. XYZ’s emphasis will be to build strong
labor-management communication in the form of supervisor and employee
participation in toolbox meetings and training, safety audits, and incident
investigations. XYZ agrees to operate an effective safety and health orientation
program for all employees including new hires and subcontractor employees when
Baseline Hazard Analysis. XYZ and OSHA acknowledge the need for an alternative
method for the VPP requirement of industrial hygiene and safety baseline
surveys, that is, baseline hazard analysis to identify hazards associated with
specific work environments. In our typical work environments, these hazards may
include air contaminants, noise, and lead. XYZ’s employees work in environments
where conditions change from phase-to-phase of a project and from one job to the
next. Construction work conditions are very different from the relatively static
work environment of manufacturing settings. Therefore, we will be employing
alternative, more appropriate methods for analyzing hazards associated with each
project. These will include preconstruction environmental studies, phase
analyses, and task analyses (JSAs).
XYZ anticipates employing subcontractors for jobs that may require specialized
expertise and equipment, for example, lead removal, asbestos removal, etc. In
these projects, XYZ’s role will be to screen, monitor, and review the
subcontractors’ work. XYZ has established historical databases with baseline
information for common environment, equipment, materials, and practices. This
baseline information enables XYZ to implement hazard controls as necessary. If
the operations, equipment, or materials used on a job vary significantly from
one of our databases of historical information, we agree to conduct a new hazard
analysis prior to beginning that task to ensure that appropriate hazard controls
are in place and that any required sampling or monitoring is performed.
Emergency Response. Because of the frequent change in construction personnel and
ever-changing site logistics, XYZ will place strong emphasis on employee site
orientation and training for emergency response and evacuation. In addition, XYX
will endeavor to hold annual emergency response evacuation drills at all sites.
Normally, XYZ will try to maintain a muster point, but this may change as
conditions warrant. On small sites, our method of notification utilizes the
buddy system, that is, simple verbal communication as a means to evacuate. The
senior person on the worksite normally will be responsible for a head count.
This person also will be responsible for submitting a completed drill evaluation
form to the safety committee. On larger sites, supervisors carry small
disposable air horns, and we instruct them to issue three small blasts several
times, when feasible, as the signal to evacuate. Subcontractors are required to
participate in all XYZ evacuations. Site personnel complete and share with the
safety committee an evaluation form following all drills and any true emergency
When XYZ employees work as subcontractors, they often must follow the emergency
response and evacuation procedures of the host employer. XYZ agrees to maintain
communication with the host employer in all matters relating to safety and
health, including emergency response. XYZ will ensure that its employees are
kept informed of any host employer procedures that differ from XYZ’s own