Voluntary Protection Program Can Help You
 

* STAR *

Designed for worksites with comprehensive, successful safety and health programs. Open to any company with injury/illness incidence and days away/restricted work incident rates below the industry's national average. STAR participants are evaluated onsite every three years, and with annual injury/illness rate and self-evaluation report reviews.

MERIT

This program is offered after a STAR application has been determined as not meeting the program requirements, but WISHA determines the employer has demonstrated the commitment and potential to achieve the STAR requirement within two years. MERIT is used to set goals, that when achieved, will qualify the site for STAR participation.

"When we started working to get all our sites into VPP, the company had a 57% reduction in workers compensation costs and a 29% reduction in injuries. These reductions have been sustained over the years (since 1983) of our participation in the VPP"

Robert J. Brant
Manager, Safety, Health, and Environmental
Mobil Chemical Company, Princeton, NJ

 

THE VOLUNTARY PROTECTION PROGRAMS CONCEPT

AN OVERVIEW OF VPP

What is VPP?
The Voluntary Protection Programs (VPP) are designed to recognize and promote effective safety and health program management. In the VPP, management, labor and WISHA establish cooperative relationships at workplaces that have implemented strong programs.

The VPP concept recognizes that the objectives of the Washington Industrial Safety and Health Act can never be fully achieved by enforcement alone. Safety and health management programs that go beyond WISHA standards can protect workers more effectively.

VPP participants are a select group of facilities that have designed and implemented outstanding safety and health programs. STAR participants meet all VPP requirements. MERIT participants have demonstrated the potential and willingness to achieve STAR status and are implementing planned steps to fully meet STAR requirements.

What are the benefits?
The following benefits have been cited by current VPP participants:

Won't this just make me do a lot of paperwork without making my program better?
The VPP application process is designed to identify worksites with exemplary safety and health programs. 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 programs involve substantial written documentation, while others may not. Small businesses may obtain waivers from certain written documentation requirements.

There is some paperwork required in the application process, but we encourage you to use as much existing material as possible. Most worksites have found that the application process improves their program by creating more comprehensive understanding of interrelationships among all program elements.

Will my program qualify?
A Self-Assessment Checklist is included in this package. Use the checklist to see if your program meets VPP criteria.
Mobile worksites are not eligible for the WISHA's VPP.  Contractors at VPP sites are eligible for VPP.

How do I join?
You must submit a written application to WISHA.

Application guidelines are included in this package. After your application has been reviewed by WISHA, an onsite review will be scheduled. "What Happens When WISHA Comes Onsite," found in this package, describes the onsite review.

Where can I get more information?
Information on VPP Benefits, VPP Highlights, Elements for Becoming a VPP Site, and information on WISHA's VPP sites can be found at http://www.lni.wa.gov/Safety/Topics/AtoZ/VPP/.   Additional information on current list of VPP site nationally and program guidelines can be found at the OSHA web site http://www.osha.gov/oshprogs/vpp/

Address:   Phone Numbers:
Voluntary Protection Plan
Division of Occupational Safety & Health
Department of Labor and Industries
Post Office Box 44649
Olympia, Washington 98504-4649		   VPP Manager
(360) 902-5431
  VPP Specialist
(360) 902-4792
   

For more information or assistance, contact a Labor & Industries' consultant in your area.

Self-Assessment Check List

The Self-Assessment is for your private use only.

The items listed below will help you determine your eligibility for the VPP. Check each item you currently have or are willing to implement. Outstanding performance in all areas addressed in this self-assessment may qualify you for recognition as a WISHA approved STAR Program participant.

Call the VPP Manager, VPP Specialist or your Regional Consultation Representative when you are ready to submit your application or have questions.

Rates

*Injury/illness incidence Rates are calculated (N/EH) x 200,000 where:
N = number of recordable injuries and illness in one year.
EH = total number of hours worked by all employees in one year.
200,000 = equivalent of 100 full-time workers working 40 hour weeks 50 weeks per year.
Days away and restricted work activity incident rates are calculated with the same equation where:
N = number of injuries and illness resulting in lost workdays or restricted work activity.

Management Leadership and Employee Involvement

Worksite Analysis

Hazard Prevention and Control

Safety and Health Training

Review

Concurrence

What Happens When WISHA Comes Onsite for VPP?

Why does WISHA need to come to my site?

WISHA must verify that the safety and health program described in your VPP application is fully operational and addresses all potential hazards at the site.

Who comes on a VPP onsite review?

The onsite team usually consists of a team leader, a safety specialist, an industrial hygienist and a back-up leader. All of these team members are acting in a non-enforcement mode.

When will they come?

A WISHA VPP representative will call you to arrange a mutually convenient time.

How long will WISHA stay?

Usually about two to four days, depending on the size of your facility and/or the complexity of your operations. Administrative support may be requested by the team.

Do I have to wait until the end of the review to find out my chances of being approved?

The team leader will discuss the day's accomplishments with your designated representatives at the end of each day. What remains to be done will also be discussed to give you an idea of how the review is going.

The recommendation of the team regarding approval of your site will be based on its comprehensive assessment of your operations in relation to the VPP requirements. This cannot be done until the review is complete. The team makes a recommendation based on the information.

What will the team be doing while it is onsite?

The team performs a review that includes several steps:

Initial Meeting

The team will hold a brief introductory meeting with you and your key people (1/2 to 1 hour). Anyone who may be called upon to assist the team should attend. Employees who are accountable for meeting or maintaining VPP requirements also should attend. The team leader will describe the VPP approach, and what the team expects to accomplish. You will have the opportunity to point out special accomplishments that may not be part of your application.

Document Review

Records are examined to verify implementation of your safety and health program. This typically takes one or two days. A private area such as a conference room will be needed for the document review.

Prior to the onsite visit, the team leader will confer with you about materials the team will want to see. Collection of these materials beforehand will greatly facilitate the review.

Documents and programs typically requested during a VPP onsite review include:

Any additional information that shows the quality of the site's safety and health program is also requested.

The OSHA log and first reports of injury should be separated from other materials. This will help the review and recalculation of the injury rates.

While the site representative(s) will have primary responsibility for presenting and answering questions, corporate safety and health staff and other site personnel may assist in liaison with the WISHA team.

The onsite team leader will investigate the site's compliance relationship with other regulatory identities to determine if the site is presently in good standing with other regulatory agencies.

Walkthrough

The review team specialists will walkthrough the pertinent areas of the facility to assure that the program is fully operational. They also will assess the adequacy of the program to handle potential hazards. This typically takes 1 to 2 days.

The walkthrough is not an enforcement inspection, but if the team notes any hazards, you will be expected to correct the problems.

The team will have brief, informal interviews with randomly selected employees. The talks will be held near employee work stations to minimize any work interruption.

What will happen if the team sees an apparent violation of WISHA standards?

WISHA's safety and health professionals will be looking for evidence that your program is creating and maintaining safe and healthful working conditions. Any hazards they may observe will serve as indicators that some aspect of your program may need improvement.

While they won't issue citations, safety and health professionals will not ignore hazards. They will work with you to determine how and when to correct any hazards they see. If corrections require more time than the onsite review allows, you will be asked to notify your WISHA VPP Program Manager when corrections are completed. Should all attempts at cooperative resolution fail, the VPP team has the responsibility to recommend to the Assistant Director of Consultation and Compliance Services that enforcement action be taken.

Formal Interviews

Formal confidential interviews will be requested with a small number of your employees and, where applicable, contractor employees. These interviews will help to validate employee awareness of and participation in the overall safety and health program.

Each formal interview will last about 25 minutes and will be scheduled with the consent of management. A private space will be requested for these interview. All questions asked will relate to the safety and health program.

Why does WISHA need to talk to employees?

WISHA talks with randomly selected workers (with management's permission) to gauge overall employee awareness of and involvement in the program, and to determine their understanding of what VPP approval would mean. Your program will succeed only if everyone becomes involved and exercises responsibility. Talking to workers is the best way to determine their commitment. The impact of any negative comments by an employee will depend on the extent to which they are corroborated by other team findings and on the gravity of the problem they reflect.

In small businesses, where a safety and health program may be too informal for adequate documentation, interviews with workers, supervisors and managers are crucial evidence in establishing the program's effectiveness.

Making workers a part of the onsite review emphasizes their importance in making the safety and health program work.

Draft Report

The team may develop a rough draft report of the pre-approval review before it leaves. This may require a room to work in and other assistance as needed. Writing the draft report usually takes about one day. You will have an opportunity to review and discuss the written report before it is made final.

Closing Meeting

Before leaving, the team will have a closing meeting to discuss its findings and recommendations. If prepared, the draft report also will be presented. The draft report is not a final determination of approval. The final approval is made by the Director of Labor and Industries.

If the team finds you do not meet the requirements of the program you applied for, it may suggest another program.

If the team thinks that additional work needs to be done before approval into any VPP, it may make recommendations and allow a reasonable period of time, up to 90 days, for the work to be completed.

What if I choose not to do what the team deems necessary to meet VPP requirements?

WISHA knows that because you volunteered for this program, you have a great deal of faith in what the Voluntary Protection Programs stand for. We try to make the review process as convenient as possible, but should you decide against what is necessary to meet the VPP requirements, you have the option of withdrawing you application rather that having it denied. WISHA knows that because you volunteered for this program, you have a great deal of faith in what the Voluntary Protection Programs stand for. We try to make the review process as convenient as possible, but should you decide against what is necessary to meet the VPP requirements, you have the option of withdrawing you application rather that having it denied.

If you choose to withdraw or you are not recommended for approval, you still must correct any hazards the team identifies. Also, WISHA will return your application and discard all notes except for one complete set. This set is retained for a year, in case you have further questions. After one year it is discarded in its entirety. While these documents are in our possession, they are only internal working documents with confidentiality protected.

We've been recommended! What happens next?

The report is sent to the Director of Labor and Industries for approval.

The Director sends a copy of the final report and a letter to the site manager (or other appropriate official) announcing WISHA's approval of your site for participation in the VPP.

WISHA encourages approved worksites to hold a ceremony where a certificate and flag will be presented. When available, a WISHA official can make the presentation.

Application Instructions

This application covers the main elements of all good safety and health programs

The following guidelines are provided to assist you in filling out the application

Please read each question and provide all information requested. For answers to your questions, or assistance in completing your application, call or write to the address below.  Additional guidelines on preparing your application can be found at the OSHA web site http//www.osha.gov/oshprogs/vpp/.

Voluntary Protection Program
WISHA Services
Department of Labor and Industries
PO Box 44649
Olympia, Washington 98504-4649
(360) 902-5515

After your completed application has been reviewed and found acceptable, you will be contacted to choose a convenient time for your pre-approval onsite review. During the onsite review, you will be evaluated on how effectively your safety and health program meets the specific needs of your site. How well your program has been planned, communicated, and implemented are all criteria used in the evaluation.

Note: No information from the VPP application will be used for enforcement purposes. Applicants wishing to withdraw their application may do so at any time.

Application Guideline

For efficient processing, your application should follow the format below. It should address each item. In section B - E, you should describe how each program element is implemented at your worksite. If provided in an Appendix, or if available onsite, appropriate documentation should be referenced after the narrative description. Use of the numbering system below helps speed the review of your application. Where existing policies, guidelines, forms, etc., describe your programs, we encourage you to enclose them rather that to write new material for this application.

A. General Information

  1. Site / Company Name

    2. Site Address
    Site Manager
    Title
    Site VPP Contact
    Title
    Phone Number

  2. Company / Corporate Name

    3. (if difference than 1. above)
    Corporate VPP Contact (if applicable)
    Title
    Address
    Phone Number

  3. Collective Bargaining Agent(s)

    4. (list information on each separately)
    Union Name and Local #
    Name of Agent
    Address
    Phone Number

  4. Number of Employees

    5. Site Employees
    Routinely used Temporary Employees
    Routinely used Contract Employees

  5. Type of Work Performed and Products Produced
  6. Site's Standard Industrial Code (SIC)

    7. (3 - 4 digit number)

  7. Total Recordable Incident Rate (TRIR)

    8. a. For regular site employees, including temporary employees you supervise, provide rates for each of the last 3 complete calendar years plus the average for all 3 years combined.

    b. For contractors whose employees worked 1000 or more hours in any quarter at your site, provide one combined rate as described in 7.a. above for all contractors' employees who qualify. *

  8. Day Away/Restricted Work Incident Rate (DARWIR)

    9. a. For regular site employees, including temporary employees you supervise, provide rates for each of the last 3 complete calendar years plus the average for all 3 years combined.

    b. For contractors whose employees worked 1000 or more hours in any quarter at your site, provide one combined rate as described in 7.a. above for all contractors' employees who qualify. *

    *

    Injury incidence Rates are calculated

    (N/EH) x 200,000 where:

    N = number of recordable injuries/illness in one year.  (OSHA 200 LOG Columns 2+6+9+13)

    EH = total number of hours worked by all employees in one year.

    200,000 = equivalent of 100 full-time workers working 40 hour weeks 50 weeks per year.

    Days Away/Restricted Work Incident Rate are calculated with the same equation where:

    N = number of injuries/illness resulting in days away from work and restricted work activity days.  (OSHA 200 LOG Columns 2 and 9)

    VPP Visit:  Describe your site's visit by key personnel t a WISHA VPP site.  When?  Scope of visit.

    **

    Section F contains a sample statement regarding management commitment to safety and health and to participation in a Voluntary Protection Program. Submission of such a statement is required for VPP application.

     

B. Management Leadership and Employee Involvement **

  1. Commitment: Attach a copy of your site's established occupational safety and health policy, goal and objectives.
  2. Organization: Describe how the site's safety and health function fits into your overall management organization. An organization chart is preferred but not required.
  3. Responsibility: Describe how your site assigns line and staff safety and health responsibility.
  4. Accountability: Describe the accountability system you use for line managers, supervisors and employees. Appropriate examples include forms, job performance evaluations, etc. Explain how the system is documented.
  5. Resources: Describe personnel, equipment and other resources devoted to your safety and health program.
  6. Planning: Describe how planning for safety and health fits into your overall management planning process.
  7. Contract Workers: Describe your program for ensuring that all contract workers who do work at your site are provided the same safe and healthful working conditions and the same quality protection as your regular employees.  Contractors on VPP sites are eligible to apply for VPP.
  8. Employee Involvement: List the ways employees are involved in your safety and health program. Provide specific information about decision processes that employee's impact such as hazard assessment, work analysis, safety and health training and/or evaluation of the safety and health program.

    9. If you have a safety and health committee, complete the following information where applicable.

    a. Date of committee inception
    b. Method of selecting employee members
    c. Name, job and length of service of each member
    d. Average length of service of employee members
    e. Description of committee meeting requirements

      • frequency
      • quorum rules
      • minutes (you may attach samples)

    f. Description of committee role

      • frequency and scope of committee inspections
      • procedures for inspecting the entire worksite
      • role in incident investigation
      • role in employee hazard notification
      • other

    g. Describe the hazard recognition training provided to committee members or any non-managerial employees with duties involving hazard recognition.

    h. List the safety and health information available to and used by the committee.

  9. Annual Evaluation of Your Safety and Health Program: Provide a copy of the most recent evaluation of your safety and health program. Include assessments of the effectiveness of the elements listed in these application guidelines and documentation of recommendations completed.
  10. Employee Notification: Describe how you notified employees about site participation in the VPP, their right to register a complaint with WISHA, their right to obtain self-inspection and incident investigation results upon request, etc. (Various methods may include one or more of the following: new employee orientation, bulletin boards, or tool box or work group meetings.)
  11. Site Plan: Please attach a site map or general plant lay-out.

C. Worksite Analysis

  1. Pre-Use Analysis: Explain how new facilities, equipment, materials and processes are analyzed for potential hazards prior to use.
  2. Comprehensive Surveys: Indicate how you search the site for potential safety and health hazards. Examples are industrial hygiene surveys, comprehensive safety reviews, and project safety reviews at the time of design.
  3. Self-Inspections: Describe your worksite safety and health routine general inspection procedures. Include information about inspection schedules and industrial hygiene sampling and monitoring. Indicate who performs inspections and how any hazards discovered are tracked until they are eliminated or controlled. (You may attach sample forms and internal time frames for elimination or control.) For health hazards, summarize the testing and analysis procedures used and qualifications of personnel who conduct them.
  4. Routine Hazard Analysis: Describe how your site routinely examines and analyzes hazards associated with individual jobs, processes or phases. How are the results incorporated in your training and hazard control programs? How are the results incorporated in your training and hazard control programs? How are the results used in your hazard prevention and control program? Include procedures or guidance techniques used in conducting, relate phase planning, and describe how results are used in training employees to do their jobs safely. For those worksites with complex processes and/or highly hazardous chemicals, describe your process safety program and provide a simple process flow of your operations.
  5. Employee Reports of Hazards: Describe how employees notify management of potential safety or health hazards. What is management's procedure for follow-up and tracking corrections? (An option providing for written notification must be part of your program.)
  6. Incident Investigation: Explain your site's incident investigation procedures. What training/guidance is given to investigators? How do you determine which incidents warrant investigation? Are near-miss incidents investigated?
  7. Pattern Analysis: Describe the system you use to analyze trends in injury/illness experience and hazards identified at your site.

D. Hazard Prevention and Control

  1. Professional Expertise: Provide information about your access to and the frequency of your use of certified industrial hygienists and safety professionals.
  2. Safety and Health Rules: List your site's rules, and describe or attach a copy of the disciplinary system you use for enforcing them.
  3. Personal Protective Equipment: Describe your site's personal protective equipment requirements. If respirators are used, attach a copy of your written respirator program.
  4. Emergency Preparedness: Describe your site's emergency planning and preparedness program. Include information on emergency or evacuation drills.
  5. Preventive Maintenance: Provide a summary of your equipment and a description of your procedures for the preventive maintenance of the equipment.
  6. Medical Program: Describe both your onsite and off-site medical service and physician availability. Explain how your site utilizes the services of occupational health professionals. Indicate the coverage provided by employees trained in first aid, CPR and other paramedical skills, and indicate which training they have received. Give a detailed description of how you address specific programs such as hearing conservation, ergonomics, blood borne pathogens, etc.

E. Safety and Health Training

    Describe the formal and informal safety and health training programs provided for managers, supervisors and employees. Include supervisors' training schedules and information on hazard communication, personal protective equipment and handling of emergency situations. Describe how you verify the effectiveness of the training given. (Sample attendance lists and tracking methods, if any, also may be attached if desired.)

    Other Information

    Include any other information you believe is crucial to the application.

F. Statement of Commitment

  1. Union Statement: If your site is unionized, the authorized collective bargaining agent(s) must sign a statement that supports the site's participation in the VPP. The statement should be submitted with your application and must be on file before WISHA will schedule an onsite visit. Expressions of the commitment of non-union employees are welcome but not required.
  2. Management Statement: Please read the following statement carefully and either sign on the line below or attach a letter that provides the same assurances.

    We agree that:

    • All employees, including newly hired employees and contract employees when they reach the site, will have the VPP explained to them, including employee rights under the program and under the Act;
    • All hazards discovered through employee notification, self-inspections, WISHA onsite reviews, incident investigations, process hazard reviews, annual evaluations, or any other means or report, investigation, or analysis will be corrected in a timely manner, with interim protection provided as necessary;
    • If employees are given health and safety duties as part of our safety and health program, we will ensure that those employees will be protected from discriminatory actions resulting from their carrying out such duties, just as the WISHA Act of 1973 protects employees for the exercise of rights under the Act;
    • Employees will have access to the results of self-inspections and incident investigations upon request.

    We agree to provide the following information for WISHA to review onsite:

    • Written safety and health programs;
    • All documentation enumerated under Section III, of the current VPP requirements; and
    • Any agreements between management and collective bargaining agent(s) concerning the functions of any joint labor-management safety and health committee and its organization and any other employee involvement in the safety and health program.
    • We will retain these records until WISHA communicates its decision regarding initial VPP participation.
    • We will likewise retain comparable records for the period of VPP participation to be covered by each subsequent evaluation until WISHA communicates its decision regarding continued approval.
    • We agree to make available for evaluation purposes any data necessary to evaluate the achievement of goals not listed above.
    • We will provide WISHA each year, by February 15th, our injury/illness incidence and days away/restricted work activity case numbers and rates, hours worked, estimated average employment for the post full calendar year, and a copy of the most recent annual evaluation of the site's safety and health program following the Region X report format.
    • In addition, we will send our combined injury/illness incidence and days away/restricted work activity case numbers and rates, hours worked, and estimated average employment for the past full calendar year for all contracted employees who worked at least 1000 hours in any one quarter on our site during the year.
    • We understand that we may withdraw our participation at any time or for any reason should we so desire.

      ________________________________________________

      Signature
      Manager of the applicant worksite

      (You may add the signatures of any others you wish)