In May, the Government Accountability Office issued a critical report assessing OSHA's program for monitoring itsÂ designated Voluntary Protection Program (VPP) sites.Â Â There are about 2,200Â of these VPP site across the country whichÂ have met theÂ written program andÂ on-site evaluation criteria.Â AÂ VPP designation exempts the worksiteÂ fromÂ programmed OSHA inspections, and ifÂ anÂ inspection is conducted---because of a complaint, referral or fatality/catastrophe----the employer is not cited for violations if theyÂ are promptly corrected.Â This recentÂ GAO report was peppered with phrases like "not sufficient," "lack of policy," does not have controls," and "not met key requirements."Â Most troubling to me, however, was theÂ GAOÂ conclusion:
âOSHA has not developed goals or measures to assess the performance of the VPP, and the agencyâs efforts to evaluate the programâs effectiveness have been inadequate.â
GAO also reminded us that they had already recommended in 2004 that these OSHA compliance assistanceÂ programs beÂ evaluatedÂ for cost-effectiveness,Â andÂ to do so BEFOREÂ they areÂ further expanded.Â Well, that idea was ignored by Mr. Foulke and company.Â The number of OSHA VPP sites doubledÂ in the time since that GAO recommendation was made.
Here we are, 5 years later, and still no data on whether VPP is a good use of OSHA's scarce resources.Â Â MyÂ back-of-the-envelope calculation tells me that the resource demands of VPP are significant: 1,580+ existing sitesÂ (under federal OSHA responsibility), and another 87 new sites addedÂ (Jan-June '09),Â is a lot of annualÂ reporting, on-site assistance, and scheduleÂ evaluationsÂ (every 1, 2, 3 or 5 years, depending on site's status.)Â Â It makes me wonder how OSHA can really justify the diversion of resources.Â Remember, this is the agency known infamously for its underfunding----as the Health and Safety Department of the AFL-CIO reminds us, it would take OSHAÂ 133 yearsÂ toÂ inspect each workplace under its jurisdiction just once.
The other major conclusion of GAO's assessement of OSHA's management of VPP was lack of written documentation in case files and insufficient national office oversight to ensure consistency throughout the country.Â In May, acting asst. secretary Jordan Barab responded to the GAO reportÂ by sayingÂ OSHA would address the problems identified by GAO and would "conduct a comprehensive evaluation of its VPP and Alliance Program."Â Â When I heard this, it told me toÂ get ready for someÂ short-term fixes, but alsoÂ a longer-termÂ effort.
If my interpretation is correct, the short-term fix came last week when the acting asst. secretaryÂ issued "Improving Administration of the VPP."Â Â It's aÂ set of instructions (mostly to)Â OSHA's field offices to address theÂ paperwork and documentation lapses identified by the GAO.Â Â (An undercurrent in theÂ GAO reportÂ seems to be a tension betweenÂ HQÂ who write the procedures, and field staff who have to implement them.)
"Some regional VPP officials told us that they have requested such guidance from OSHA's national office, but the national office has not issued a directive on what information should be documented in the files or on how long it should be retained. The OSHA official responsible for overseeing the program did not agree with regional VPP officials, and stated that the VPP Manual addresses the documentation requirements."
In the new instructions issued last week, OSHA HQÂ tellsÂ field staff, for example, if a worker is fatally injured (or another significant event occurs) at a VPP site, OSHA's HQ Office of Partnership and Recognition be "immediately informed."Â Â As GAO pointed out in their report, it's hard to comprehend how a workplace can haveÂ VPP Star status when the firm had received 7 serious violationsÂ related to a fatality.Â [On this matter, the instruction simply reiterates the existing procedures for putting a site on conditional status--no new policy.]
Obviously, this new instruction to the field is meant to identify and fix paperworkÂ lapses and inconsistencies.Â But what'sÂ missing from the "Improving Administration of the VPP"Â memorandum is the real heart of the matter: measuring effectiveness.Â This is the longer-term project that willÂ take a bit more than six weeks for the new OSHA leadership to untangle.Â Â
I see it as a two part-task:Â
- How should each site's H&S management system be measured for effectiveness?
- How should theÂ cost-effectiveness of VPPÂ be measured?Â Â
As far as measuring a site'sÂ program effectiveness, simple calculations of incident rates are probably not sufficient.Â As IÂ noted in a post Valero's repeated violations and OSHA VPP, for a refinery,Â lost-time or restricted duty injury rates are not likely to be an useful measure of prevention-performance.Â Think about process safety management.Â Data onÂ unintended releases of hazardous substances,Â misplaced storage tanks or dozens of other missteps may be more appropriate indicators of anÂ ineffective process safety management system, than an OSHA recordable.Â Â [InÂ this newÂ instructionÂ from OSHA HQ to theÂ field,Â the primary measure of effectiveness isÂ still theÂ "total case incident rate" (TCIR) andÂ "days away, restricted or transferred rate (DART).Â How wouldÂ current VPP sites respond ifÂ OSHA proposes alternative measures of program effectiveness, such as unintended releases or near misses.]
The second part of the longer-term evaluationÂ question is measuring theÂ overall cost-effectiveness of VPP.Â ButÂ cost-effective for whom?:Â the taxpayer,Â OSHA,Â the company, the workers, OH&S in general?
It seems that when VPP participants are asked if the program is cost-effectiveÂ (seeÂ VPP Success Stories)Â they say "YES."Â Â Â They use measures likeÂ increases in worker productivityÂ andÂ decreases in workers' compensation insurance premiums.Â I believe them, and agree that these areÂ quantifiable benefits to the firm.Â Â Is that, however, what VPP is supposed to be?Â
What I'd like to knowÂ isÂ how the VPPÂ translate into aÂ direct benefit to OSHA?Â For example, in return for the resources expended on VPP sites, is OSHA in a position toÂ conduct more inspections of construction sites? assess hazards more thoroughly (e.g., taking IH samples), respond more promptly or thoroughly to whistleblowers?Â Â Â No.Â As far as I can tell VPP diverts resources from these core activities.Â Again,Â I'd like some examples of the tangible benefits to OSHA of VPP.
It was one thing back in the early 1980's when there were a few dozen VPP sites across the country, and a handful of regional OSHA staff responsible for monitoring and coordinating with the sites.Â It might have even beenÂ collateral duty for some.Â Â Now, serving the VPP sites is aÂ full-time job.Â I wonder if it's time for a new VPP model, one that is self-sufficient, not relying on OSHA resources for sustainability.Â With more than 2,200 sites across the country, and an association of their very own, perhaps its time for the VPP program to leave the OSHA nest and make it on its own.Â Â Besides, is having a comprehensive health and safety management system something that we should consider so extraordinary?Â
It may have been atypipcal in 1982, but today,Â shouldn't we expect allÂ employers in the U.S. to have an effective injury and illness prevention system that involves workers and demands continuous improvement?
I just wanted to say that I really enjoyed the one sided slant to this article about the OSHA Voluntary Protection Program. I cannot see how a program that makes the workplace safer and reduces the number of incidents at their facilities is a bad investment. I have worked for the same manafacturing company for 21 years, and have seen many different safety programs come and go. And the most successful program has been the OSHA Voluntary Protection Program, because it allows the employees to have ownership in their safety programs. You make a valid point that OSHA has limited resources to conduct inspections. But with employees owning the program, many sites are getting hundreds of worksite inspections a year.
You have failed to discuss the positive ways VPP helps companies. The mentoring program, where one site that has already earned their Star, goes to other plants and helps them improve their safety programs. Why do you think this program has grown over of the years. It is not like companies get a huge advantage for trying to earn their VPP Star. As your article quotes from the AFL-CIO it would take OSHA 133 years to inspect each facility under their jurisdiction, well plants that are in VPP go thru a week long inspection every 3 years to ensure that they are performing up to the above and beyond standards VPP has for their plants.
There will always be ways to improve any program, in fact OSHA has gone thru many changes over the years. Just this year alone the focus on combustable dust has been a big issue. And why is this change, because incidents have occured that there were no regulations for in the past. So before you attack a program that is working to make facillites safe for all of their employees, please make sure you include the positive aspects of the program, not just the negative.
Thanks for sharing your thoughts about VPP. I wasn't intentionally trying to be negative about VPP. I set out to suggest that without data on how much it costs OSHA to run the program, we don't know if it is worth the investment. (Kind of the same thing that the GAO said in its report.)
Clearly, you think it is worth it, and I think there are many other VPP participants who believe so too. But given that there are loads of workplaces around this country for which an OSHA inspection might force them to correct dangerous conditons and unsafe practices, should OSHA be devoting a disproportionate amount of resources to VPP sites? With the benefits that you and others get out of VPP, such as the ones you mention, can your programs survive without OSHA's heavy involvement? The bottom line: would companies strive to meet the VPP requirements if they weren't promised the special enforcement treatment by OSHA? If the answer is yes, that would be terrific. It would be a testament to the fundamental principles underlying an effective H&S system with robust worker involvment.
I think their must be some misunderstanding somewhere when you state
"A VPP designation exempts the worksite from programmed OSHA inspections, and if an inspection is conductedâbecause of a complaint, referral or fatality/catastropheâ-the employer is not cited for violations if they are promptly corrected."
In all my time with OSHA serving as an, Area Director, Deputy Regional Administator, Regional Administator, Deputy Assistant Secy and Acting Assistant Secy, it never was a policy to not take OSHA enforcement actions at VPP worksites as a result of unprogramed inspections. I have noted below the OSHA FOM CPL02-00-148(3/26/09) and the FR notice dated
Jan 9th 2009that address the issue.
FOM Chap 2 page 12
unprogrammed Enforcement Activities at VPP Sites.
When an Area Office receives a complaint, or a referral other than from the OSHA VPP onsite team, or is notified of a fatality, catastrophe, or other event requiring an enforcement inspection at a VPP site, the Area Director or designee must initiate the inspection following normal OSHA enforcement procedures.
â¢ The Area Office must immediately notify the Regional VPP Manager of any fatalities, catastrophes or other accidents or incidents occurring at a VPP worksite that require an enforcement inspection; as well as of a referral or complaint that concerns a VPP worksite, including complaint inquiries that would receive a letter response. If the VPP is a national VPP, the National Office should be notified.
â¢ If the Regional VPP Manager is the first person notified by the site of an event requiring an enforcement inspection, the VPP Manager must instruct the site to contact the appropriate Area Office and the National Office if the fatality is on a National VPP site.
â¢ The inspection will be limited to the specific issue of the unprogrammed activity. If citations are issued as a result of the inspection, a copy of the citation will be sent to the Regional VPP Manager. See CSP 03-01-003, Voluntary Protection Programs (VPP): Policies and Procedures Manual, dated March 25, 2003.
â¢ The Area Director will send the VPP Manager a copy of any report resulting from an enforcement case
[Federal Register: January 9, 2009 (Volume 74, Number 6)]
C. OSHA Enforcement
1. Programmed Inspections. VPP applicants and participants, unless
they choose otherwise, will be removed from OSHA's programmed
inspection lists, including any lists of targeted sites.
a. OSHA will remove an individual site applicant or multiple sites
within an applicant DGA from the programmed inspection lists.
(1) This will occur no more than 75 calendar days prior to the
commencement of the scheduled preapproval onsite review.
(2) The applicant will remain off these lists until official denial
of the application, applicant withdrawal of its application, or, if the
applicant is approved to the VPP, subsequent cessation of active participation
in the VPP.
b. Upon approval, VPP participants will continue to be removed from
OSHA inspection lists for the duration of approved participation.
c. Removal from OSHA programmed inspection lists does not apply to
a corporate headquarters or DGA headquarters unless these locations
have applied or been approved for site-based participation.
2. Unprogrammed Inspections
a. Workplace complaints to OSHA, all fatalities and catastrophes,
and other significant events will be handled by enforcement personnel
in accordance with normal OSHA enforcement procedures.
Thanks for the additional info. I based my characterization on information contained in an OSHA information sheet (I link to it in my post, and it is also posted below) which says:
"OSHA removes participants from programmed inspections and does not issue citations for standards violations that are promptly corrected."
If that information is not correct, we should jointly ask OSHA to correct the factsheet.
Celeste, I agree the sentence is poorly worded and needs to be corrected.
How would you like to jointly ask OSHA to correct it?
I'd be happy to send a joint letter with you to OSHA. In the meantime, I'm happy to make a correction on my blog post. Would it be correct to say:
"A VPP designation exempts the worksite from programmed OSHA inspections, but if an inspection is conductedâbecause of a complaint, referral or fatality/catastropheâit is handled exactly like any other OSHA inspection, if violations are identified, they are cited."
Celeste, I am willing to bet you lunch that there is at least one person at OSHA who reads your blog. So I think we should wait and see if a change in the OSHA Fact Sheet is made, if not we can send a letter.
I think the change you will make noted above is correct.
Also did you see my reply to your Your July 6th blog concerning PSM workshops at out National Conference?
"As far as measuring a siteâs program effectiveness, simple calculations of incident rates are probably not sufficient."
What is the purpose of effective safety and health management. Is it not to send everyone home at the end of the day free from workplace related injury and illness. EVERYTHING OSHA does should be a means to that end.
Accordingly, I can think of no more accurate measure of a programs effectiveness than injury and illness rates.
Not only is VPP important here within the United States, we take the same elements of VPP globally to all of our sites. I say this only to let you know that we do not embrace VPP simply to avoid OSHA visiting any of our sites. We find far greater value like; siginificant reductions in worker comp cost, significantly hight employee involvemnt in safety, and the commitment from the top down as well as the bottom up!
Have never heard of a company applying for VPP just to get "special" enforcement treatment. It is doubtful that a company who is concerned about enforcement could ever qualify as a VPP site!
VPP sites have 50% less workplace injuries than other companies - that fact alone says volumes about safe worksites. And is that not what OSHA is all about, protecting the American worker?
In my region, there are just two people in the OSHA office whose sole focus is VPP vs. the number of OSHA personnel who are in compliance - please share where all the "extra" VPP personnel are - our VPP Manager is swamped and could use the help!
It is doubtful that you've ever visited a VPP site. You've never experienced the enthusiasm an employee has when they share what they do to make their worksite safer.
The Voluntary Protection Program is the leading world-wide safety & health program and it's member sites are the leaders in safety - any insinuation (for whatever reason) that this is not an effective program is nonsense.
Our site is not a VPP Star site but is in the process of aquiring it. The advantages that I personally see in the process is the fact that before a site can even start down the road to Star it takes a seriious committment of upper management to support it and is essentially driven from the top down and the bottom up at the same time. The first element of VPP is a letter of committment from the plant manager and the second thing is employee involvement. When the two meet in the middle there is a complete safety program in place and all workers go home at the end of their shift safely to their families. That is the bottom line for our troops out on the floor
VPP is the best tool for employers interested in implementing effective workplace safety program and continuously improving it. If a company wants to get in VPP for enforcement exception we discourage them from applying immediately.
One way OSHA benefits from VPP is by recognizing industrial safety models(sites) and sharing recognized sites' practices & programs with other employers. Also We have trained professional representatives from VPP sites to assist Cal/OSHA staff in VPP process & evaluations. Their participation in the VPP process is an absolute win-win situation for OSHA and VPP sites.
In the past years few VPP sites experienced lack of commitment and continuous improvement to workplace safety due to new senior management staff and their misunderstanding of the concept as result those sites were removed or withdrew from VPP program.
As a VPP site, one of only three in our industry, participants in VPP programs alleviate the burden of programmed inspections for OSHA. In the VPP program, sites help one another to strive toward a time when all employees go home after their shift in the same manner in which they arrived.
There are far fewer OSHA VPP resources dedicated to the program than that of the enforcement side. My site's participation in this program is reducing the inspection burden of OSHA enforcement. That is good business.
I recently spoke to another person in a plant in another industry where the person in charge stated, "why would you let the fox in the hen house?" And my reply was that it makes good business sense to care for employees enough to do more than just the bare minimum that OSHA requires. My site's employees are in the unique situation where the words, "OSHA is here" does not incite panic. Shouldn't that be the goal - when an organization embraces OSHA regulations for the right reasons? The more sites who come in to the program will reduce the need for more enforcement. It really is that simple.
At the end of the day, the health and safety of our workers is of utmost importance and VPP has provided us the framework to continuously improve our safety programs. We don't particpate because of verbiage regarding inspections - we particpate because it's good for employees and good for the bottom line.
Celesten I am disappointed reading your critical comments. I and other workers feel that Blame the Victim approach is going to continue from the sounds of it. We take pride in the ownership of Health & Safety; it fans out covering a number of areas benefiting not only the worker but the company as well. Come to a Shop and take a reality check, see and talk to the workers.
Remembering since its inception by law in 1970, the U.S. Department of Laborâs Occupational Safety and Health Administration (OSHA) has been the principal federal agency issuing regulations governing the well-being of the nationâs workforce. The implementation of OSHAâs procedures for promulgating or revising a regulation is lengthy (often involving years to complete) and costly. Thus OSHA management is highly selective in setting priorities for instituting a new regulation or altering an existing one. This is where the VPPPA association can deliver a timelier and more comprehensive program of prevention, not enforcement by its self.
The VPP program can assist by allow OSHA to deal with the companyâs that donât get it. VPP sites will continue to be audited and improvements will be made, offering true prevention, being recertified on a routine bases far more than companies out side VPPPA. Workers feel ownership of the programs and the awards befitting the them by the improvements made. In addition, the insufficient resources to undertake a review of private sector standards as well as general industry and their relevance and suitability, nor to undertake promulgating a revision of them.
Retain, Create jobâs by cooperate not sure how you see to obtain this with enforcement? The term Medical Avoidance Cost is real and applicable to any company. Data GAO yes where did the date come from? How was it collected and interpreted? Itâs been said improvements are needed; recommendations have been made and accepted. So letâs not forget the victims in the workplace, I believe this is the real issue being impacted.
I have been one of THOSE workers for over 30 years in one manufacturing facility. I suffered from an Occupational Illness. Funny thing took the condition it home at night. I have worked as an elected Health & Safety rep. for a number of years, working closely with people understanding them, then the concern they may have. This is the realities of Safety, feeling it. Engagement of the worker brings information beyond belief leading to the ideas and fixes.
I believe that firm regulations are important but, the legislative process is discouraging by itself. The VPP program is something that can be implemented sooner and offer broader protection by prevention.
VPP is working at my company; please donât discourage the workerâ¦
Celeste--your comments simply astound me. The benefit of VPP is sometimes immeasurable. There are the quantifiable aspects of a reduced injury and illness rate. Then there are the things you cannot put a price on--employee involvement, employee ownership of safety and management commitment to the time employees spend on their own safety program. My own company went from 13 OSHA reportables the year before implementation of VPP principles to zero reportables last year (5 years after implementation)
There are so many more compliance officers than VPP managers, plus VPP managers in almost every state utilize SGEs (Special Government Employees) to assist with VPP audits. These are people who work at VPP sites who have been through the same training as OSHA employees who work on VPP teams as auditors. These people are not compensated in ANY way by OSHA. They are paid by their own employers who support their involvement in VPP. How exactly does that put a strain on OSHA? It seems to me, industry is actually helping them out by providing valuable knowledge and resources of health and safety professionals who work VPP programs every single working day.
The VPP opens up a huge network of resources that would not normally be available to small companies who don't have a massive health and safety budget. We are not here to benefit OSHA--OSHA is the governmental agency tasked to provide guidance and standards for every work site in America to provide a workplace free from recognized hazards. Enforcement doesn't necessarily improve safety at companies that are fined frequently.
There seems to be a lot of noise about incentive programs for safety encouraging non-reporting. That is a culture issue. I work at a company that has never had an incentive program and I can assure you that hazards are reported in a timely manner by all employees. Your article seems to be promoting a lack of accountability by employees, which is the completely wrong approach to take. Our employees take a great deal of pride in the fact they helped develop the VPP at our site and they take ownership of it. Management provides resources of time, training and funding to ensure the success of their employees.
I would suggest you take the time to at least visit some VPP sites and talk to both management and labor representatives to get a real world understanding of VPP and the commitment it takes to participate.
Celeste, Like most of the respondents, I believe you may have a very narrow view of the importance and effectiveness of the VPP Program.
When you say that VPP only benefits the firm due to increases in worker productivity or lower workers compensation costs, you miss the point that this is due to fewer injuries and less lost time. That is a direct benefit to the workers whom OSHA was set up to protect. The program promotes a safer workplace, OSHA's mission in a nutshell.
The focus of VPP is partnerships. Between Management and Employees, and between Industry and OSHA. This isn't a matter of just compliance. It is a program that encourages diverse groups to communicate and work together to improve their facilities so that everyone benefits. Without voluntary participation programs like this, I believe OSHA would be hampered in its efforts to encourage industries to ensure the safety of their employees.
The article discussing measuring the effectiveness of the VPP program has stirred up an incredible reaction from VPP sites. We are one.
Our site has been in VPP for three years (0.0 TRIR during the period) and has experienced nothing but positive effects.
The argument about companies using VPP as a way to avoid programmed inspections seems specious. There are much easier and cheaper ways to avoid being "on the radar". In fact, VPP is about voluntarily putting your facility and programs on the radar, and open to critique.
Unfortunately, it appears the only simple metric that can be used to determine the effectiveness of the program is injury rates. As an earlier post pointed out, VPP sites typically have significantly lower injury rates. One could argue, "well that's just because VPP sites are more focused on preventing injuries...". Precisely! That's the point.
It is hard to prove a negative. Would OSHA have done more good never having embarked upon VPP and just devoting resources to compliance and inspections? For our facility (with no OSHA visits in almost 20 years prior to VPP), we have definitely been able to provide a safer workplace for our employees by partnering with OSHA, submitting to the required inspections, and policing ourselves between VPP recertifications. The program works!
USG Corporation supports the OSHA VPP program because it helps us enhance our safety programs and creates new opportunities that increase employee involvement with safety, and thus, improve their safety at work and home. The real benefit of the OSHA VPP program is in preparing for participation, which helps employees recognize what they are doing well and what can be done to take the next step towards safety excellence. Employees have a tremendous sense of pride and accomplishment when they achieve OSHA VPP Star status. Knowing that they will be re-inspected in the future helps them to maintain the elevated safety emphasis going forward because they do not want to loose the OSHA VPP Star status.
As an employer we do not see any special value to reduced OSHA oversight associate with VPP achievement. However, it may be a way for OSHA to better utilize their resources.
Safety is a âcoreâ value for USG Corporation and the OSHA VPP program helps us to continuously improve in this vitally important area, which is central to our operating philosophy. USG is a leader in workplace safety because we believe that nothing is more important than the safety of our employees.
The OSHA VPP program requires resources from OSHA and employers but this partnership helps employers focus on safety in a pro-active way to avoid injuries, which should be everyoneâs ultimate goal.
As a non-management Safety Director for a VPP site, I as well as all of our employees, have witnessed a safety transformation at our facility since our quest for VPP began. When our plant was finally certified, our TCIR rate was 70.4% below the national average for our industry NAICS code classification. Those performance numbers are what no one may argue against. The bottom line is that VPP sites are an average of 50% below the TCIR for like facilities in the same classification. Just how can the program's overall effectiveness be questioned in light of the statistical evidence?
Since our certification, one of our industrial neighbors (the nation's largest nuclear power plant) saw our article in a local newspaper and is pursuing VPP. We are assisting in mentoring that facility. The program is infectious, and gives front line employees who actually face hazards in the workplace a direct say in the mitigation of those encountered hazards. There are no CSP's or CIH's on site as staff. Our employees earned and indeed own the Star Status they received after years of hard work. VPP employees are far more educated about Safety Regulations and Hazard control/mitigation that non program workforces.
During our onsite review, special attention was paid to our Process Safety Management program. We had to show due diligence in every aspect (14 parts) of our PSM operations. OSHA (ADOSH) required records and documentation, as well as the results of employee interviews to shed a favorable light on our PSM and other safety programs. We have become a beacon for all other Power Plants in our vicinity, and are very eager to share our findings and secrets in order to help all employees at all worksites enjoy the safety record that we are very proud of. So far, there have been two takers.
VPP has made our workplace far safer and even more operationally reliable, as the same scrutiny and assessment we apply to our Safety issues, is being applied to nearly everything we do. OSHA's VPP program has undoubtedly changed our lives for the better; far safer and more educated on Safety than most. Since the program always makes its workers enthusiastic supporters of not only Safety but also promoters of OSHA at other worksites, I must comment that its value is immeasurable in promoting workplace safety. Just ask any certified Star site employee, and they will say the same. This program is actually a blessing to OSHA.
I have to agree with Tim the VPP program has been effective at a number of the sites im responsible for. VPP has caught the ear of leadership and has been a positive in our process for improvement.
Attn: Celeste Monfortan
A few notes regarding your commentary.
The experience our facility had working toward VPP Star recognition and more recently the recertification process was based on a desire to continuously improve the way we operate. VPP offers a "fresh eyes" approach to managing process safety which we readily embrace as a key component of our process safety management activities.
I recognize metrics used to measure the effectiveness of OSHA's VPP activity may not be readily available. However, consider the following examples of program benefits.
As a VPP participant, our Management Team and Team Members participate in ADOSH/OSHA training courses provided on-site, and at state and federal OSHA training facilities. These trained employees participate in the daily, monthly and annual reviews of the work areas.
As a VPP participant, the OSHA Consultation and Training team responds promptly to emails and phone calls from the work team. How many worksites have employees, not safety professionals, with the confidence to email or call OSHA directly for assistance?
Our experience with VPP was began more than seven years ago and it continues to be productive. I believe VPP is money well spent.
The VPP application process, preparation, education, worker involvement and obtaining upper management commitment, in itself, is a true test of a company's safety program. The workers, subcontractors and the General Contractor all walk away from a VPP site much more knowledgeable and competent than before they were involved in the program. We are just a few months into being a Construction VPP Star company/site. The pride in the company for having one of the best safety programs recognized by OSHA, is overwhelming. Worker education, training, consultation and partnering is all about prevention. Prevention and preplanning is a key to success in obtaining a true safety culture. Removal from inspections is not an incentive. We have had much more intense involvement with OSHA than if we worked along waiting for a complaint, referral or to come up on the Dodge Report for a scheduled inspection. I have been on many projects where I never saw OSHA. On the jobsites we have partnered or consulted with OSHA on, everyone takes onwership and responsiblilty for each other. We have made a goal of spreading this program to other projects in different states which is a true task, actually creating more work for ourselves. It will all be worth it for us. We hope OSHA will continue supporting all of its programs equally. To go back to the "old days" would be a step back in time.
Celeste, I wanted to take a few minutes to respond to your comments. As an employee of a state plan program for the last 22 years I can tell you that the VPP program has been for me, one of the most valuable tools at my disposal, in my never ending quest to help employers get better at what they do with regards to safety & health management. I spent 12 years as a compliance officer in both safety and industrial hygiene. In that time I conducted thousands of complaint, planned, and yes, accident / fatality investigations. In many cases I met with the same people, at hearings and informal conferences only to have them pay their fines and walk away going back to business as before. Their was no cultural effect, no change, no continuous improvement.
The last 10 years of my career have been spent working with employers in various capacities such as partnerships, SHARP and VPP program, in fact I am the coordinator for my state VPP program, as well as one of the management, and the results of that program have been tremendous. Employers actually engage in conversations with OSHA personnel. They are not afraid to pick up the phone or stop by the office simply to ask a question. That is in part due to the cooperative nature of the VPP program. Do not get me wrong I am not one of those people who believe that compliance is not necessary. I realize, probably better than most there is a need for it. What I am confused about is why there would be such a negative slant on a program such as the VPP and all the good it does for industry overall, and for OSHA. I would argue that employers who get involved in this program do it because they know itâs the right thing to do, its good for employees, and itâs good for business, not to get out of an inspection. I have never had an employer tell me they wanted the VPP designation because they wanted to avoid an inspection. In fact many of the organizations involved in this program never received any form of compliance inspection, planned or otherwise, until they submitted to OSHA for VPP. They opened themselves up for OSHA to come in and continue to do so. In that respect we had an impact in areas we never would have before because the organization was not listed as one of those in whatever current trend or emphasis program OSHA might be focused on. Moreover I would argue that the employees involved in the VPP program are some of the most informed and empowered employees I have ever encountered in any workplace. Is that not what OSHA wants? Employees who are informed, and empowered to do what is right.
How come no one talks about the $300 million dollars the NSC estimates employers saved on DART injuries as a result of effective safety and health management in those VPP sites for 2007, as quoted in an article on OSHA's own website. This same article discusses $59 million in savings for Federal agencies involved in VPP. Hmmm...$59 million in savings for the Federal government couldn't come at a better time. Doesn't sound like wasting resources to me. Let us remember the fact that these are not just dollars saved, they are lives protected. Again that is what we are trying to accomplish.
In closing I can only make this comparison. When I was a flight medic, I received a lot of training on what to do if someone were injured or hurt, many people in my duty section would sit around each night in the flight duty room saying things like, "I hope there is an accident or some other event so I can do what I am trained to do". To me this made no sense, for me to practice what I was taught, someone had to suffer, they had to be injured, maybe even die. If we could get them to do the right thing, to wear the PPE, to use the proper guarding, to protect themselves before the event, then we would not have to resort to our other methods, we would not have to utilize those other resources and no one had to suffer... Hmmm... Maybe we are onto something.
The VPP process requires management committment, union committment and employee involvement. Our site has all of the above including millions of dollars spent, programs put in place and employee driven, all with a total incident rate way below industry average. Finally our time was here and the audit was underway. We had end of each day summaries with the OSHA guys and the SGE's, we had employee interviews, we had union officials interviews, we had management interviews and at the end of the week we had a final summary. The OSHA Team including the SGE's were very complimentary and were talking of taking our ideas and processes back to use at their sites and were talking of recruiting SGE's from our site. We were all very proud of where we are and how far we had come in just a few years and everyone at our site were looking forward to the results. The letter came and we werent even in the VPP program. The audit results didnt match the verdict. The VPP process has moved us to the top of safety and the political games have the possibility of setting us back years. I would like to speak with the people that ruled on this gross injustice because our lives are at stake.
After reading all the comments from both fellow VPP site personnel and VPP officers I have had the pleasure to work for and with, you can see the VPP sites "get it" about safety. As an employee in industry, VPP is the perfect format to run our companies. When you have large corporations like GE saying they base their whole EHS program off VPP that tells you something. From an industrial side I have and will continue to function as an SGE and STM (California). I gather a wealth of knowledge on every audit I have performed. It is a great opportunity to learn new ways to approach safety issues. I can not tell you how many times I have gained benefical knowledge from a VPP site that further enhanced the safety at my site. I would ask you if you can go to the National VPPPA conference (San Antonio, TX). You will have an opportunity to see the biggest gathering of Safety advocates in the country. Better yet you will see many, many opportunities to see safety presentations on how to address safety and safety cultural issues. The great thing about a majority of these wonderful presentations are that they are put on by non-safety professionals. They are put on by regular floor operation and administrative employees. Talk about impact on your safety culture. I have been fortuneate to qualify two sites in two different regions and two different states. The qualilfications and requirements were the same. There is a lot required of VPP sites. I also act as mentor for sites considering VPP. As stated in previous post, companies and government organizations (OSHA offices, Military establishments, Utilities, etc.) get into the program because of its proven impacts on their safety performance in the organization and on employee ownership and involvement. You commented on people getting into VPP to avoid OSHA inspections. Ironically, in my experience people who have gone through the process generally can't wait for OSHA to come in. At the point they are having their OSHA inspection, their site employee 's have work countless hours in developing their systems and engagement of employees. They can't wait for the OSHA auditors to get their to show off what they accomplished. They welcome OSHA to come in. How many compliance programs can we think of that have generated that kind of enthusiams with safety?
I believe the GAO Report is a little bias. Just look at the committee members who performed the report. The report was going to be leaning one side from the start. They had hoped the report would end VPP.
VPP is an excellent program and those companies in it are watched more than all those that are not. The companies in it go through extensive audits by VPP team which incudes OSHA, but also several SGE which are all VOLUNTEERS with thier OWN COMPANY paying the expenses. Besides this audits every 3-5 years, the sites perform routine inspections and audits of themselves.
The nut cases that performed the GAO, should of got out from behind their desks and went and visited some of this VPP sites for first hand experiences and talk to the people.
I could not agree more with Mr Tim Jones. The "one sided slant" to the description of the OSHA VPP program was very entertaining, but I can speak from experience that VPP has made our site much safer than it was prior to VPP. I am a 37 year employee at the same site. And over the years I have traveled to our other sites in the U.S. and can tell you the VPP has made a major difference at every site. Let me ask one questin: How many accidents/fatalities in the 2200 VPP sites does it take to justify funding the VPP Program? I'd be willing to bet the farm that the justification is there!
I can honestly say that I am proud to be working for an organization that wants to make the workplace safer for the employees to the extent of calling in OSHA to do inspections tocorrect any issues befor employees get hurt.
Having worked with Iraj and his team (Cal/OSHA VPP) they take pride in helping facilites become VPP certified.
In an earlier response you were curious about the amount of time and money OSHA spends to audit these VPP sites. But you need to look at the time and money these companies spend to become VPP star sites. No they are not buying the certification, they are spending money to go "above and beyond" OSHA standards. I know that the facility I worked at where Iraj's team performed the audit, a lot of our findings were best practice improvements that the Special Team Members wanted to see us implement. One of their findings was to create a Management of Change program for a facility that was not a PSM site. The plant spend several thousands of dollars to create the program, conduct training, and improve their pre-start up safety reveiw program. This is something that a Star site investigation does. They make sure these VPP sites use the OSHA standards as the starting point and build from there.
I agree with all of these replies. I beleive that you need to look at the Voluntary Protection Program with a more open eye. You need to go to the VPPPA conference in San Antonio this month. You will get a chance to meet a large group of people that take safety to heart. They are not paid by OSHA to be there, but by their employers because the employer feels this program is the best way to ensure the continuing sucess of their safety programs.
If the goal of OSHA is to create a safe workplace for everyone, then VPP is the best way to go. But now it seems that under this new administration that OSHA is going to become a Self funding enterprise. And if you have companies that are becoming safer and protection the worker, OSHA will not be able to collect fines and citations from them. So when reviewing the GOA report, ask yourself these two questions 1) In the GOA report, are they interested in protecting the worker? 2) Does the GOA want OSHA to become self funding by increasing enforcement inspections to collect fines and citations?
I believe from the comments, several offers have been made inviting you to a VPP site. This would provide a good opportunity to get a better understanding about our programs and practices. This would help dispel the roomers and clear some of the criticism. Meeting the people behind the seen that truly makes it work.
I believe we both care about people, we just need to understand the real issues here.
Celeste, I believe that you have overlooked two important aspects in your commentary. First, the real value of VPP is seen by the companies and people that participate in the program. GAO should collect data on how many millions of dollars have been saved by reducing the direct and indirect costs associated with work-related injuries and illnesses. Second, the GAO's assessment is relative to government effectiveness (which some says is an oxymoron) as opposed to business effectiveness. Many Fortune 500 companies have invested in VPP and continue to do so. The growing number of VPP companies is certainly proof that there is value and effectiveness offered by this OSHA program otherwise why would large businesses continue to invest in this pursuit.
We didn't aspire to be VPP simply to get out of programmed inspections, or to hit a plateau and sit at a higher level and then watch the world go by. VPP doesn't sell our products and certainly doesn't give us a break on worker's comp costs. It take alot of hard work, dedication and commitment with all parties to even begin to want to try to be a VPP site. We at Bobcat wanted to be in VPP to help us get better. Best practice sharing, networking, programatic change, best new practices, cutting edge, all the above. Simply put, VPP is the best of the best! it all about commitment, top down commitment. Getting all employees engaged in the ESH program! Involvement, sipmly put it works for us and we are an organized labor site. Twice a month I have conference calls with our international sites and I preach VPP commitment and all agree it is a program that is second to none.
Be the best at want you do or simply do nothing and watch the world go by. By the way, VPP works and it does save money by reducing work place injuries, pain suffering, lost hours reduced, again, commitment. But, most important to us empowerment to the workers to get better!
Thanks and VPP folks keep up the good work, because it provides worth to the companies and protection for all workers!
I might have a different take on VPP than others from VPP sites. We are currently working toward achieving VPP at our site, and I am leading the cause. I believe VPP is the right way to go because it ensures that we are on the right path to ensuring our employees have the safest place to work.
Our facility has been here for 13 years and never had a full OSHA inspection. I'm also relatively new to the safety world and there is a lot to learn. The OSHA VPP program has provided me a network of professionals to address questions to, and a roadmap of how to go from an average safety program to an excellent program. Realistically, how many people would INVITE OSHA into their facility? Not many. However, by doing this we are offering to fix all compliance items that may be found, thus providing a safer workplace for our employees, and ensuring OSHA that we intent to comply and exceed all the workplace safety and health standards.
I know that all OSHA regions do not have equal acceptance standards. I do agree that some sort of national standard and oversight needs to be accomplished so VPP Star sites in Tennessee are held to the same standards as sites in Colorado (for example). This is a nationwide program that should have a nationwide set of standards.
I believe that the GAO report should be taken into consideration when looking at how to IMPROVE the VPP program. VPP expects continual improvement. Why should we expect anything less of the VPP program? I believe VPP sites present and future would welcome improvements, as long as they continue to strive toward safety excellence and a collaborative effort between OSHA, Employers, and Labor.
I hope you plan on supporting this program. As someone on the outside of VPP looking in, I can tell you that it has already made a difference in my workplace and we aren't even accepted yet.
I read your article and follow-up blog comments to what others have posted on this issue. While I respect your opinion, I do not agree with your overall conclusion. I do agree that there probably can be improvements to measuring VPP effectiveness and I'm sure OSHA will take the GAP report seriously and work towards improvement there. However, to suggest that VPP is not worth OSHA's time is just crazy.
I have worked as an EHS Professional for 20 years including stints in the federal government, for an engineering/construction firm, for county government, for a mid-sized manufacturer, and now as a consultant helping small, mid-sized and large companies with their EHS and loss control programs. Simply put there is no better program out there than VPP for improving employer H&S programs and health and safety conditions for employees. If under the new administration OSHA has to justify the effectiveness of the VPP in order to keep it, then I think they likewise shoud be asked the other question; how effective are compliance programs and inspections overall? Is it assumed that most employers that are inspected and fined by OSHA then have a revelation to provide great safety to their employees? That is not my experience!
In my opinion, OSHA must be able to work it at both ends. Compliance and enforcement are necessary for the bad actors as well as for those who have not taken H&S seriously. Along with that, fines need to increase with serious and willful citations. In addition to this, OSHA needs to continue to promote and push the VPP. It is an OUTSTANDING PROGRAM! Have you ever worked for any length of time as a safety professional at multiple manufacturing or construction sites? If not, I think it is really difficult for you to understand the importance of this program. If OSHA increases the number of compliance officers hitting the streets, they should likewise increase the number of VPP reps doing the same thing. Work it at both ends! Both are necessary!
Craig Snyder, PE, CIH, CSP
Like everyone else I was astounded by your slanted view of VPP. In order to understand VPP you need to talk to the heart and soul of it. It being the people who work at VPP sites. It is no cake walk to go through the application process or through the assessments. I have had the opportunity to do assessments for both OSHA (as an SGE) and for the Department of Energy. I can honestly say both VPP programs are stellar and it is because you have labor and management working together for the safety of everyone.
If you visited any VPP site you would find that those people take their safety mindset home with them to share with family and friends. They also don't need trinkets and doodads to keep them safe.
I feel if more people would ask questions of the people and stop relying on what they read and interpret in print there would be a better understanding of the process.
Sometimes it is better to start at the bottom instead of the top.
First off, I want to thank you for posting this topic to your blog. It gives many of us, who support VPP, an opportunity to discuss all of the positive aspects that come with a site striving for and eventually obtaining VPP Star Status. As I think you will see from all of the responses posted to this blog, VPP and its supporters, both in the manufacturing and governmental sectors, hold this program in high esteem.
In your comments you state that the real heart of the matter is measuring effectiveness and that simple calculations of incident rate are probably not sufficient. I would agree with you on this statement if this was where the process stopped. However, nothing could be further from the truth. The review of a sites injury/illness data is one part of a multi-faceted approach to determine eligibility. Once eligibility is determined, the more difficult part of the journey beginsâ¦having to be able to show that there is a strong safety and health program and a proactive culture supporting the numbers presented and that employees are involved with decisions affecting their safety program. There are many sites with great injury/illness rates that will not make it into the VPP program. The determining factor will be if the site can prove their programs worthy through the VPP audit process. Also, regulatory compliance alone will not lead to a successful HSE program. The VPP program realizes this fact and provides employers a set of tools to help them achieve a greater level of success.
One of your other questions was âHow should each siteâs H&S management system be measured for effectiveness?â This is where a better knowledge of the VPP model would benefit your understanding. There are 4 major elements of VPP (Management Leadership and Employee Involvement, Worksite Analysis, Hazard Prevention and Control, and Safety & Health Training) with up to as many as 30 sub- elements (depending upon how the sub-elements are categorized). When OSHA reviews these elements and sub-elements, it allows them to âmeasure the effectivenessâ of the sites H&S management system. Employees, supervisors and other leaders are interviewed, both formally and informally, to allow the auditor to determine if the programs are truly working or are they just written on a piece of paper. It is through this in-depth process that OSHA can make the determination as to whether or not the site has an effective H&S management system. .
Lastly, in my 20+ years as an HSE professional, as well as my 15+ years of involvement with VPP programs, I have never once heard a company, site, or facility leader state that they wanted to achieve VPP merely to get removed from an OSHA inspection list. As Mark Norton pointed out previously in this blog, it is much easier for some companies to try to dodge OSHA compliance and, if caught, pay a fine. The problem with this model, as VPP has shown and Mr. Norton eluded to, is that the culture of the said company/site/ or leader does not change. If no significant shift in culture occurs, history will more than likely repeat itself.
I urge you to attend the upcoming VPPPA conference in San Antonio, Texas to learn more about the program prior to posting additional blogs that contain only a very small portion of the entire picture.
I am the Army (and client) Safety Manager at a $2 Billion Superfund site. Our principal contractor has been in the VPP Program for 10 years, another important long-term contractor about 8 years, and we (the Army oversight staff) have been in it for 3 years, entering at the merit level. I don't know where to tell you the importance of this program. The Safety Attitude and Commitment from the Program Manager to the lowest paid field worker has and is paying dividends that reach far beyond our site. Our OSHA recordable case and days away case rates run about 10% to 20% of industry standards. Our most serious injury since we went VPP was the fracture of a facial bone, due to improper tool selection. Usually, the injuries are a few stitches or prescriptions with or without physical therapy and work restrictions for muscle strains. People recover from these injuries. They are NOT life-altering events.
The level of safety cooperation at my site is a model for the entire region. Remedy subcontractors are transient--they perform a job and leave, often returning for another job. In between, they spread the safety culture to other jobs and even other companies. Safety teamwork and openness at my site is real and positive--nothing is hidden and lessons learned from all incidents are analyzed and shared--even with competing companies.
True, the GAO report found problems, principally in VPP program management quality between OSHA regions. The best OSHA VPP managers have known and care about this and therefore shared their concerns with the auditors. BUT--the problems are fixable.
VPP provides OSHA an immense, non-quantifiable benefit. OSHA Compliance Officers get to participate in VPP audits. This provides them a very important experience, and in fact, a "benchmark". They spend so much time with industries, companies, and worksites with problems that they don't realize what a world-class safety program can be like. Then, without dying or going to heaven, they get to see, touch, and inspect such a site. It is a very different and rewarding experience for most of them.
As an SGE and the Safety Manager of a VPP Site, I have rubbed shoulders with several of the best Region VIII Compliance Officers and some national subject matter experts on audits. Each has shared valuable insights that they have received from auditing VPP worksites. I also have learned a lot from them and my peer sites.
As I see it, OSHA really has two management problems with VPP. The first problem, differences in quality can be solved within existing resources--it will take some work, but in the end, it can, and will, be fixed. The second problem is a good one--it results from the success of the program. Since there are now 2,200 VPP sites and counting, OSHA will have to rethink how it manages the program. The growth and size have contributed to the other problem, especially in some regions. OSHA should consider how they can best leverage their staff and resources to manage and facilitate continued program growth. SGEs and Corporate-level VPP certifications can contribute more, but OSHA needs to be intimately connected for its own benefits.
Rocky Mountain Arsenal.
In response to the question you asked on Aug 12th.
Your Question: "With the benefits that you and others get out of VPP, such as the ones you mention, can your programs survive without OSHAâs heavy involvement?"
What defines heavy involvement? The VPP program provides an infrastructure for companies to achieve safety excellence. It is up to the companies striving to achieve VPP to assure they meet & sustain the elements of the program. OSHA provides a critical review of the company's program, exposes areas for improvement, and sets a high expectation for companies to continually challenge and improve their safety execution.
The benefits of VPP to this organization have been enormous. Prior to setting out on our journey to VPP we averaged three to six lost time accidents per year. With the implementation to the VPP tenents we've been able to reduce that to zero and maintained it for more than 6.5 years. The site takes great pride in this designation and works hard to maintain and live by the VPP elements. We believe in it to the extent that we've had three of our employees participate in the SGE Program to provide OSHA with additional resources, that Governent funding won't give them, to help other sites in the efforts fto gain VPP certification.
OSHA faces the same problems that the rest of the conuntry is facing, how to do more with less. However, the VPP program is literally saving lives and limbs. If I'm looking at a resouce to trim, it wouldn't be one that has such a positive impact on the workplace.
Without VPP OSHA's resources would , in my opinion, would be stretched even more as a result of the increased auditing they'd have to do to insure business compliance. The sites particpating in the program, for the most part, don't have to be checked, OSHA knows they're compliant, those that aren't come out of the program. VPP gives businesses the opportunity and a roadmap to do the right thing, for the right reasons. To lose this resources or to cut it would be tragic
As Plant Manager of a large electric power plant, I can attest to the positive effects we are seeing as we "jointly" work together with our Union and our employees to make our facility a safer and better place to work. This VPP effort is "not about the flag" - it is about making our work place a safer place to work, improving teamwork and producing a workplace that we can be proud to have anyone come to visit. It is amazing the results that can be achieved when everyone is working towards a common goal. In my opinion this OSHA VPP program is delivering positive results.
There seems to be a lot of talk about the strain that the VPP program puts on OSHA. What about the Benefits and cost savings it gives OSHA?
In the simplest terms, when a site becomes a STAR site they involve all of the sites employees in the Safety program. In fact, STAR sites are expected to mentor and help other sites improve their safety. If all the exemplary Safety companies help the ones struggling with safety, how can that not help reduce the strain OSHA. The employees feel empowered to take charge of their own safety, thus feel better and safer in their workplace. Most of our employees have interacted with OSHA members first hand during our certification process and know them now. Several of our employees have contacted OSHA directly to talk about improvements. Just think how easily they could report an issue if they felt there was one.
I have also heard a lot of false rumors about the so called exemptions that STAR sites receive. I can tell you that in our three years as a STAR site, whatever we were supposed to be exempt from we are already doing or it has not materialized. I do see the relationship we have built with all divisions of OSHA as a benefit not an exemption.
Unfortunately we have had a few incidents since our certification. We have welcomed the compliance division of OSHA into our plant to figure out what happened and how to keep it from ever occurring again. As a STAR site we need to be transparent in reporting and reviewing of our safety performance to include all divisions of OSHA. Just think if we were not doing those things as a STAR site. How much more time and difficult this could be for OSHA. Additionally, in our state the district manager is listed on our certification letter as a resource and he is directly involved with our certification approval. We also make our annual evaluation available to him every year so he can see what we have done and know what we are doing in regards to safety.
Lastly, I would like to touch on the company benefits that seem to be so hard for some to find. The bottom line for the company it could be a huge cost at first to become a VPP STAR site but the investment will repay itself ten fold in my opinion. Bottom line show you care about your employees and they will return the favor in their performance. I have seen VPP make improvements in our plant in so many ways that are not directly related to Safety. We have seen better productivity with fewer down times all while having fewer lower injuries as a result of VPP. In fact we have reduced our injuries 75% since becoming certified. I can tell you, my plant manager sees this as the bottom line for his company.
Our site has been VOSH Star-certified since 2002. Although our injury rate and incidents were well below industry standards before we were Star-certified, the benefits of being in the VPP have helped us continually push to drive the rates even lower through the mentoring, resources, and networking of the VPP. The VPP has, for us, been a rich source for sharing programs that work at other sites and adapting them for use at our site. Our IR has been consistently below 0.08 since being certified and without the help and assistance of other members, I have no doubt that we would have wasted time and resources using the "hit or miss" approach to trying new/different safety programs.
Vpp has been the best thing that happened to our manufacturing plant of 500+ employees. Each year our RCR has dropped and in fact 2007 and 2008 were the lowest ever recorded in our plants 35 year history. The best thing about VPP is it keeps you focused on "Continuous Improvement" year after year. It also becomes part of the plants "culture" which is what's really important.
I for one cannot believe anyone in the Federal and/or State goverment would even consider changing the basics of VPP.
In business we always talk about R.O.I. To me VPP provides an outstanding ROI not only for the company but our employees.
If the rumors I hear are true one would have to question the true motive behind changing this GREAT program. The US Goverment should be making a big push to get more companies VPP Star certified. It's much like the debate on Healthcare; taking care of the issue before it becomes one is the key.
The Voluntary Protection Programs have made a huge
difference for our company. In the sites where we have implemented the
program, not only have the rates of injuries decreased, but the employee
engagement has led to increased morale and higher productivity. In
fact, it has resulted in higher levels of operational performance. Even
our customers notice the difference. We never began the VPP process
with the thoughts of doing it only to prevent OSHA inspections. From the
beginning, it was a way of improving our safety. We wanted to go above
and beyond the basic levels of compliance. It was simply the right
thing to do. We are working towards implementing it in many more
locations and know that it will continue to lead to greater success as
we do so. VPP is the model safety management system for all of our
locations, whether they are in the US or Global. It is the foundation
of our Safety Business Plans. We know VPP is worth the efforts and are
pleased to be a part of the VPP success story.