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Voluntary Protection Program (VPP): Are Construction Companies Eligible?

By: Karl Weisser

July 10, 2014

In 1982, OSHA created the Voluntary Protection Program (VPP) to establish a partnership with businesses and the Occupational Safety and Health Administration (OSHA). Originally, general industry businesses covered under 29 CFR 1910 were only available to participate in VPP until May 9th, 2009 when OSHA made the decision to allow construction companies the opportunity to participate and achieve VPP.  Construction companies are included in 29 CFR 1926 and eligibility is open to all general and sub-contractor companies regardless of size and duration of the projects they work on. Participants are required to develop and implement effective safety management systems to identify, evaluate, prevent and control occupational hazards in the workplace. In return for successful participation, OSHA removes the facility and/or the contractor from the planned or programmed inspection list, which is typically aimed at highly-hazardous trades or workplaces that have experienced high rates of injuries and illnesses. 


There is a two-phase onsite evaluation that takes place after the review and acceptance of the VPP application for a company.  In the initial steps for achieving VPP, the company has to submit their application into their regional VPP office for revision and ultimately, acceptance. There are four major steps in the application process: general information, employee support for VPP participation, assurances, and VPP safety and health management system. The first part, general information, consists of the companies’ information, the number of employees (including contractor and subcontractor), the type of work being performed, and the injury and illness rates. The second step is employee support and commitment in the participation in VPP. This is crucial because it is a constant team effort and requires employees to describe and demonstrate their knowledge and experience of VPP through multiple questions and activities.


The third step is assurances. The company must comply with the Occupational Safety and Health Act (OSH Act) and will correct all hazards discovered through inspections, employee notifications, investigations, job hazard analysis, evaluations and any other means of discovering hazards. Employees need to have VPP thoroughly explained to them, everyone needs to be protected from discrimination, and they need to have access to the results of inspections, investigations and other safety and health system data upon request to minimize the risk of future injuries. Documentation is essential when companies are in the process of achieving VPP, if it isn’t documented, it cannot be verified that it happened. A few things that require documentation includes training, management leadership and employee involvement, worksite analysis, hazard prevention and control, and the companies’ written safety and health management system. The biggest aspect of assurances is the annual submission of the companies’ injury and illness rates along with the submission of the companies’ safety and health self-evaluation which includes current goals they are striving for.

Finally, the fourth step in the application process is VPP safety and health management system. This management system includes the safety and health policies, procedures, systems and programs. It is essential to include procedures such as Lockout/Tagout (LOTO), Confined Space and other similar highly hazardous operations.


As soon as the application process is over, a two- phased onsite evaluation occurs to check and see if the safety and health management system are working at all parts of the company. According to OSHA, “ In the first phase, OSHA's onsite evaluation team will review the applicant's corporate, division or business unit policies and procedures which include a review of safety and health management programs, document review and assessment of the management commitment to safety and health, and to VPP. The second phase is dedicated to review one or more worksites to verify the safety and health management programs are actually working outside the home office where employees may work unsupervised at sites that are not owned or controlled by the applicant.”1


When a construction company achieves VPP, there are many incentives that come along with it.  There is a belief that fewer injuries and illness occur which ultimately means workers’ compensation costs and premiums are significantly lower, it creates a welcoming partnership between the company and OSHA, and the company evolves into role models of excellence in the industry. Currently 99 construction companies have achieved VPP status, and several more are striving for the same level of excellence. 

 

 

 

1. United States Department of Labor. (2014). Voluntary Protection Program: Mobile Workforce.  Retrieved from https://www.osha.gov/dcsp/vpp/mobile_workforce.html. 

 


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