VPP Stakeholder Meetings – Day After Reports
VPP Stakeholder Meeting
On August 28, 2017, the second Stakeholder Meeting took place immediately prior to the Voluntary Protection Programs Participants Association (VPPPA) National Conference, in New Orleans, Louisiana. A total of 29 attendees preregistered and approximately 60 people attended. This was the second Stakeholder Meeting on the recalibration of OSHA's Voluntary Protection Programs (VPP) so that it continues to represent safety and health excellence, leverages partner resources, further recognizes the successes of long-term participants, and supports smart program growth.
Doug Kalinowski, Director of the Directorate of Cooperative and State Programs (DCSP), welcomed the attendees, highlighted the objective of these gatherings, and provided a summary of what OSHA had learned from the first Stakeholder Meeting. While attendees actively shared ideas with OSHA during the first Stakeholder event on July 17 in Washington, DC, because of the proximity in time (and location) to the VPPPA conference, there was a greater diversity of attendees and a greater breadth of ideas proposed at this second event. OSHA posed four questions:
- What changes can the Agency make to the VPP process and flow?
- What changes should the Agency make to Corporate/Long term Participants?
- What changes should the Agency make to the Special Government Employee (SGE) program?
- What other ideas are there to enhance and improve VPP moving forward?
For this second Stakeholder event, DCSP requested that participants not repeat ideas that had been previously mentioned and instead focus on new recommendations. Common themes from participants included comments mirroring some areas already being considered by OSHA:
- Looking at different levels of recognition. For example, Platinum statuses (with attendant additional expectations) for long-term participants with mature safety and health management systems who are committed to VPP safety culture.
- Reconsidering the requirement that a Safety and Health professional has to be employed by the company for two years before he/she can apply to be an SGE.
- Scheduling reapproval cycles for longer than three to five years - Process Safety Management (PSM) sites could go through reapprovals more frequently, while a smaller site would have fewer complex issues, so could wait longer for reapproval.
- Reviewing the requirement that every VPP participant, as a part of their active engagement in the program, must designate at least one SGE.
Specific new recommendations included both procedural and policy changes (some recommendations include exact language from participants):
- Exploring Changes to the Program to Facilitate Applications and Audits
- Recommendation for OSHA to adopt the Modified Application Process (MAP) from Region VI. An SGE would go into an applicant site, do the evaluation and then hand over the paperwork to the OSHA audit team. This would shorten the audit time.
- New applicants should have an SGE mentor who not only provides advice and support for the applicant, but may perform a pre-visit before the initial audit. OSHA should not have to go to the site if the applicant is not ready.
- Do a follow-up survey six months after an audit to get some feedback.
- Remove the requirement to get an Medical Access Order (MAO).
- Use of SGEs
- Use an SGE-only team for short audits (smaller companies, non-complicated processes).
- Create an SGE clearing house –Is there a place for SGEs to share information with each other, maybe a newsletter or a web page?
- Provide SGEs with a longer time before start of audit to put them in a schedule and clear with their companies.
- Revise the frequency of reapprovals and use of SGEs. Combine annual self-evaluation with one OSHA person and the company's SGEs.
- Technology and Communications
- Recommendation for OSHA pilot using web-based system and sync with OIS for report and audit submissions. (Note: DCSP is updating our internal data base, and we are currently in update testing mode. We are also looking at Regional databases)
- Create a process to share Best Practices and the knowledge gained. How to sell VPP? How do you market the program?
- Mechanisms to share SGE information and Best Practices, like a newsletter. Something that corporations can share up through their ranks.
- Out-of-the-Box Ideas
- The current trend is for risk-based programs. OSHA needs to change the criteria and requirements to be more risk-based. Maybe focus on the smaller companies for Safety and Health Management Systems (SHMS) and VPP.
- Move to a business plan model so that VPP is incorporated into part of a business process.
- Insurance companies should add a line item to their audit and underwriting to take into account that a site has VPP status.
As a part of the Stakeholder meeting, one participant shared their VPP story:
- Our company has been in VPP for 22 years. We have had these conversations with our CEOs. Why we should be in VPP for long term? VPP is a brand. We used it 22 years ago to drive a conversation around safety excellence. We went from Merit to Star…Our performance has improved and have sustained it to world class level. We want to give back - we have 15 SGEs, we help other companies and IOSHA, and the State Governor. When you think about the bottom line…VPP pays off…Look at all of the models and certifications…our people like the integrity, transparency and the partnership.
In addition, the docket is still open for comments until October 20, 2017. After that, we anticipate working to synthesize all of the ideas and proposals to reflect the full scope of stakeholder input.
VPP Stakeholder Meeting
On July 17, 2017 in the DOL Frances Perkins Building Great Hall, Directorate of Cooperative and State Programs (DCSP) hosted a successful Stakeholder meeting on the recalibration of OSHA's Voluntary Protection Programs (VPP). Prior to the event there were a more than a half-a-dozen write-ups from industry press highlighting interest in the Stakeholder meeting. These included Safety and Health Magazine, Safety Law Matters, and Industrial Safety and Hygiene News. A total of 145 attendees preregistered and 125 people attended.
Acting Deputy Assistant Secretary Thomas Galassi welcomed the attendees, including members of the Voluntary Protection Programs Participant Association (VPPPA) Board, and recognized VPP's 35-year anniversary along with the newly framed VPP STAR Flag. This flag was flown on Space Shuttle STS 93 in July of 1999.
A diverse group of attendees actively shared with OSHA ideas to help OSHA reshape VPP so that it continues to represent safety and health excellence, leverages partner resources, further recognizes the successes of long-term participants, and supports smart program growth.
Some common themes included comments relating to areas already being discussed by OSHA. These include reshaping processes or policies relating to:
- Long-term participants with mature safety and health management systems who are committed to the VPP safety culture;
- Increasing participation in the VPP Corporate Option;
- The use of Special Government Employees (SGEs) and their expertise to supplement safety and health efforts and to help reduce the burden on OSHA staff.
Additional recommendations included procedural changes for greater efficiency and to take advantage of existing structures:
- Improving communication and better publicizing of VPP (both inside and outside DOL)
- One attendee shared an elevator discussion with a DOL (ETA) staff member on the way to lunch. The DOL staffer replied: "What's VPP?"
- From just the publicity around the Stakeholder meeting, DCSP received inquiries from companies requesting information on how to participate in VPP.
- Shorten the time for New Approvals and Reapprovals
- Alter/Simplify the Reapproval form/process
- Increasing OSHA's use of technology to work smarter
- Using technology to automate annual self-evaluation reports for sites and financial disclosure reports for SGEs.
Stakeholders also indicated that improvements to VPP should not come at the expense of enforcement.
DCSP is still pulling together detailed information from the transcript and planning has already begun for the follow-up stakeholder event that will take place immediately prior to the VPPPA National Conference the week of August 28, 2017 in New Orleans, Louisiana.