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Further Improvements to VPP - 11/16/09

November, 16 2009

Jordan Barab
Acting Assistant Secretary
Voluntary Protection Programs (VPP) Policy Memorandum #3: Regional Correspondence for VPP Participant Reapprovals and Verification of VPP Injury and Illness Rates

This memorandum which supplements my August 3, 2009 memorandum -- "Improving the Administration of the Voluntary Protection Programs (VPP)" -- clarifies actions OSHA Regions must implement in the Occupational Safety and Health Administration’s (OSHA) continuing efforts to improve its administration of the VPP. The following instructions outline the process that all Regions will use to notify VPP participants and their union representative(s) (when appropriate) of their reapproval to the programs. Included also are procedures to reconcile annual injury and illness rates reported to OSHA in VPP participant annual self-evaluations with OSHA-300 log information reviewed during VPP onsite reevaluations. These procedures must be implemented within 30 days of the date of this memorandum.

  1. Correspondence to Reapprove VPP Participants to the VPP
    1. Non-Union VPP Participants - Upon reapproval of a non-union VPP participant, the Regional Administrator will send the following information to the appropriate management contact:
      1. VPP Management Reapproval Letter
      2. VPP Site Report and Worksheet
      3. VPP Insert Page
    2. Unionized VPP Participants - Upon reapproval of a unionized VPP participant, the Regional Administrator will send the aforementioned documents to the appropriate management contact plus send the following correspondence to the participant’s union representative(s):
      1. VPP Union Reapproval Congratulatory Letter
      2. Copy of VPP Management Reapproval Letter
      3. VPP Site Report and Worksheet
      4. VPP Insert Page
      The VPP Management Reapproval Letter template, the VPP Union Congratulatory Letter template, and the VPP Insert Page can be found on the "O" drive.
  2. Reconciliation of Injury and Illness Data Reviewed During Onsite Evaluations and Reported in the VPP Participant Annual Self-Evaluations
    1. Each VPP participant must submit an annual self-evaluation including annual injury and illness rates to its Regional VPP Manager by the 15th of February.
    2. During the VPP onsite evaluation, the OSHA VPP team leader must verify that a comparison is made of the participant’s injury and illness records and rates (OSHA-300 log) reviewed during the onsite evaluation and the participant’s injury and illness rates reported in its most recent annual self-evaluation. Documentation that the rates have been compared must be recorded in the VPP Site Report, Section VI – Injury and Illness Rates.
    3. If a discrepancy exists between the injury and illness rates reported in a VPP participant’s most recent annual self-evaluation and the records reviewed during the onsite evaluation, the Region must request the participant to send an updated and corrected annual self-evaluation to the Region with an explanation of the discrepancy.
    4. The Region must also notify the Directorate of Cooperative and State Programs (DCSP) on the Participant and Team Information Sheet that a discrepancy was observed. DCSP will make a notation on the consolidated Annual Self-Evaluation Spreadsheet for the corresponding calendar year.
    5. The VPP Manager must maintain the updated participant annual self-evaluation in the participant’s file.

The VPP Policies and Procedures Manual will be revised to reflect all changes included in this memorandum. If you have any comments or questions, please contact the Directorate of Cooperative and State Programs, Office of Partnerships and Recognition.