Attachment 2 - OSHA National Office Improvements to the Administration of VPP

OSHA Voluntary Protection Program

The following actions are the responsibility of the Directorate of Cooperative and State Programs, Office of Partnerships and Recognition (OPR) and other Directorates as specified herein.

  1. Nationwide consistency in OSHA’s administration of VPP.

  2. Follow policies and procedures outlined in the VPP Policies and Procedures Manual, CSP 03-01-003, April 18, 2008 and the VPP Federal Register Notice, 74 FR 927, January 9, 2009.

  3. Documentation of OSHA actions following a fatality at a VPP-approved site. VPP Policies and Procedures Manual: Chapter 2, Responsibilities; Chapter 8, Enforcement Activity at VPP Worksites

  4. Modify procedures following fatalities, catastrophes, serious injuries, or other significant events at VPP sites as follows:

    • Update the national VPP Fatality/Event Tracking Log to reflect information provided by the Regions following a fatality, catastrophe, serious injury, or other significant event.

    • Implement the following procedures to improve National Office (NO) oversight of Regional actions and documentation following a fatality or other significant event at a VPP site:

      • Annually review a sampling of Regionally-maintained VPP files of participants who have experienced a fatality or other significant event, and

      • Provide results and recommendations to the Regions.

  5. Documentation of Regions’ actions in response to VPP participant deficiencies. VPP Policies and Procedures Manual: Chapter 6, Onsite Evaluations

  6. Improve tracking and oversight of Regions’ actions in response to VPP participant deficiencies:

    • Update the VPP Annual Summary Log to include instances of 3-year rates above the national average, 2-year rate reduction plans, and 1-year conditional status.

    • Work with the Directorate of Information Technology (DIT) to:

      • Modify the VPP Automated Data System (VADS) to record when a VPP participant is put on a 2-year-rate reduction plan and/or 1-year conditional status and final disposition of the action, and

      • Produce a new tracking report for 2-year rate reduction plans and 1-year conditional status.

    • Develop and implement procedures for NO to examine a sampling of VPP participant files maintained in the Regions, for the purpose of verifying appropriate Regional actions and documentation when a participant’s performance falls below required level, e.g., injury and illness rates rise above the national BLS averages and/or the safety and health management system no longer meets VPP criteria.

  7. Ensuring the quality of VPP participant self-evaluations, Regional processing, and NO tracking. VPP Policies and Procedures Manual: Chapter 2, Responsibilities

  8. Review requirements for annual participant self-evaluations. Make improvements in submission requirements, Regional processing, and NO tracking.

    • Work with DIT to modify VADS to capture participant’s injury and illness rates and to create a report to identify sites that exceed rate requirements.

    • Develop and implement procedures for NO to examine a sampling of VPP participant self-evaluations submitted to the Regions. Purpose of this review:

      • Verify quality of self-evaluations and compliance with VPP requirements, and

      • Verify appropriate Regional review, subsequent needed response/actions, and Regional documentation.

  9. Adherence to Medical Access Order (MAO) requirements. VPP Policies and Procedures Manual: Chapter 6, Onsite Evaluations

  10. Review current procedures related to MAO requirements. Make needed improvements to ensure consistent compliance across the Regions and documentation.

    • Revise the VPP documentation to indicate whether the MAO was requested and also if the MAO was: 1) received prior to the onsite evaluation; 2) received during the onsite evaluation; or 3) not received in time for the onsite evaluation.

    • Work with the Directorate of Technical Support and Emergency Management (DTSEM) to revise procedures and tracking mechanisms related to MAOs needed for VPP onsite evaluations.

    • DTSEM will generate a quarterly report on MAO compliance by Region. This report will be produced within 15 days of the end of each fiscal year quarter and submitted to the Deputy Assistant Secretary with cc to Director DCSP.

  11. Timeliness of VPP onsite evaluations. VPP Policies and Procedures Manual: Chapter 6, Onsite Evaluations

  12. Implement ways to ensure greater Regional adherence to evaluation timeframes as follows:

    • OPR Regional VPP Liaison will:

      • Run quarterly reports from VADS to track the timely conduct of onsite evaluations in the Regions, and

      • Report any overdue onsite evaluations to the Director OPR.

    • The Director OPR will inform the Director DCSP, who will in turn notify the Regions of any onsite evaluations that are overdue and have not been flagged as delayed.

    • Work with the DIT to revise VADS reports to record and track delays in VPP onsite evaluations.

  13. Ensuring proper documentation of VPP activities.

  14. To ensure proper documentation:

    • Revise the VPP File Retention Plan to include new documentation requirements.

    • Coordinate with the OSHA Information Systems (OIS) team on all changes to VPP data applications.

    • Coordinate with the Directorate of Evaluation and Analysis to update VPP-related entries on the National Audit Template, as needed.

  15. VPP Worksheets

    • Complete VPP worksheet revisions and, when final, make available on the "O" drive.