OSHA has made significant changes to Chapter 4, The VPP Safety and Health Management System. Chapter 4 now requires VPP participants’ SHMS to consist of the seven (7) core elements described in OSHA publication 3885, Recommended Practices for Safety and Health Programs, October 2016, and in OSHA publication 3886, Recommended Practices for Safety and Health Programs in Construction, December 2016. These elements are:
- Management Leadership;
- Worker Participation;
- Hazard Identification and Assessment;
- Hazard Prevention and Control;
- Education and Training;
- Program Evaluation and Improvement; and
- Communication and Coordination for Host Employers, Contractors, and Staffing Agencies.
OSHA revised the language throughout to ensure consistency with changes to Chapter 4.
OSHA has also:
- Modified language in Chapter 10 on how to request Medical Access Orders.
- Adds Chapter 14, VPP Elite, as a new level of distinction for sites that achieved VPP Star recognition for 15 or more consecutive years and meet other criteria.
- Adds Chapter 15, VPP Emeritus, as a new level of distinction for sites that have achieved VPP Star for 25 or more consecutive years and meet other criteria.
Just as a reminder for those interested in becoming a VPP STAR facility.
Management provides the leadership, vision, and resources needed to implement an effective safety and health program. In a VPP-quality organization, management regards worker safety and health as a fundamental value and applies its leadership to safety and
health protection with as much commitment, planning, and visibility as it does to other organizational purposes.
Management leadership means that all levels of management are fully committed to mitigating safety and health hazards, protecting workers, and improving their employees’ workplace safety and health. This support requires the employer to provide adequate resources to implement and maintain the SHMS. They must actively demonstrate their commitment and provide information and training to employees about the SHMS and their commitment to VPP. There are many ways an employer can demonstrate their commitment to providing a high level of safety and health to workers
and others.
Authority and responsibility for worker safety and health must be integrated with the overall management system of the organization and must involve workers. Management demonstrates its commitment to safety and health protection and VPP participation by establishing, documenting, and communicating to workers and contractors clear goals that are attainable and measurable; objectives that are relevant to workplace hazards and trends of injury and illness; policies and procedures that indicate how to accomplish the objectives and meet the goals; and resources necessary to accomplish the communicated goals and objectives in a timely manner. Management leadership actions include:
A. Signing a statement of commitment as part of their assurances to maintain compliance with OSHA standards, to continuously improve safety and health, and to consistently meet VPP requirements.
B. Maintaining a written SHMS documenting the elements and sub-elements, procedures for implementing the elements, and other safety and health
programs, including those required by OSHA standards applicable to their industry. For example, federal agencies’ written programs must meet the
requirements of 29 CFR part 1960 and referenced OSHA standards; and construction companies’ written programs must meet the requirements of 29 CFR 1926.20(b).
C. Providing visible leadership in implementing the SHMS.
D. Ensuring all workers at a participant’s site (including any contractor’s workers) are provided equal, high-quality safety and health protection.
E. Establishing clear communication with workers and creating an environment that allows for reasonable worker access to site management and senior management.
F. Responding to workers in a timely and appropriate manner following workers’ reports of hazardous conditions and ensuring that the responses are tracked from initial report through control or completion of corrective actions.
G. Setting an example by following the rules, such as, but not limited to, wearing any required personal protective equipment, reporting hazards, reporting injuries and illnesses, following the same safety and health procedures expected for all workers at the workplace, and subjecting managers and workers to the same disciplinary system for infractions.
H. Defining, in writing and communicating, the responsibility and authority in all areas for SHMS performance to all workers. Each worker, at any level, must be able to describe his/her responsibility for safety and health.
I. Assigning adequate authority to those people who are responsible for safety and health, ensuring they can carry out their responsibilities.
J. Providing and directing adequate resources to those who have responsibility and authority. This includes resources, such as time, training, personnel, equipment, budget, and access to information and experts, including appropriate use of certified safety professionals (CSP), certified industrial hygienists (CIH), licensed health care professionals, and other experts as needed.
K. Holding managers, supervisors, and non-supervisory workers accountable for meeting their safety and health responsibilities.
L. At least annually, evaluate managers’ and supervisors’ safety and health performance by operating a documented performance standards and appraisal system that addresses correcting deficient safety and health performance.
M. Planning for safety and health expenditures in the budget, including funding for prompt correction of uncontrolled hazards.
N. Integrating safety and health into other aspects of planning, such as planning for new equipment, processes, and buildings.
O. Conducting and submitting an annual SHMS self-evaluation to:
- Maintain knowledge of the hazards to which workers are exposed.
- Maintain knowledge of the effectiveness of SHMS elements.
- Ensure completion of recommendations from previous years.
- Modify goals, policies, and procedures as appropriate.