Common Deficiencies Found on VPP Evaluations & Annual Reports

Common Deficiencies Found on VPP Evaluations&Annual Reports By Matt Gaines VPP Manager

Two Types of Evaluations • Initial Certification • Recertification

Recertifications: • 18 – 24 Months for MERIT • STAR, First Recertification = 3 years • STAR, After First Recertification = 5 years

Emphasis on Initial Certification • Verify what is stated in Application • Does site meet the requirements of VPP • Understanding of OSHA and VPP requirements

Emphasis on Recertification • What has changed since last audit? • Special emphasis on S&H Program improvements (Looking for continual improvement!) • Is site still meeting VPP requirements? • Recertification report will include a special section entitled “Program Changes and Improvements”

Meeting the Requirements? • Sites must be be familiar with the questions in the VPP Site Worksheet in order to be successful! • MR = Minimum Requirement (Must be met to be in/remain in VPP) • Non MR’s = MERIT Goal or STAR Conditional Goal

6 Focus Areas • Injury/Illness Rates • Management Commitment • Employee Involvement • Worksite Analysis • Hazard Prevention & Control • Training

Common Deficiencies Found in the Six Focus Areas

Injury & Illness Rates • Increase in rates 1) Trend analysis? 2) Hazard recognition training?

Recordkeeping • Properly recording on OSHA Logs is now a Minimum Requirement! • Ensure that you record-keeper is properly recording injuries & illnesses. • Improper recording can lead to application denial or withdrawal from VPP!!

Management CommitmentInitial Certification • Are management and employees knowledgeable about safety & health/VPP??? • Are you applying for VPP for the right reasons?....... To keep OSHA Compliance OUT or Wanting just a free consultation visit vs. To improve your safety and health management systems and join the elite

Management CommitmentRecertifications • Change of management personnel??** • Redirection of priorities? (production vs. safety) – Economic Issues • Less time spent on safety/VPP • Less resources for safety ($$) • Are new managers/employees knowledgeable about safety & health/VPP???

Management Musical Chairs! • It has been noted that sites with frequent management personnel changes often incur problems on recertifications and with annual report submissions. • Site or corporation must have strong “continuity of culture” procedure. • Are you a good candidate for VPP?

Employee InvolvementInitial & Recertification 1) Employees MUST be involved in all aspects of VPP evaluation (open to close!) 2) There must be at least 3 meaningful ways for employees to participate (If you eliminate one means of participation, you must come up with another!) 3) Employees not knowledgeable of VPP or elements (New employees on recert) 4) No follow-up with employee suggestions or reports of hazards

Employee Involvement, Continued • Submittal of application before you have employee/local union buy-in. Remember….For VPP you must have established a safety and health “culture.” That means employee involvement and buy-in!

Worksite AnalysisInitial Certification • Those tasked with performing safety and health audits have poor hazard recognition skills (ie. – numerous 90-day items) **Know the OSHA Standards!!! • Hazard recognition skill is a Minimum Requirement • JSA/JHAs for routine tasks not developed

Worksite AnalysisRecertifications • Site no longer performs monthly inspections or ensures quarterly coverage of entire site. • New equipment, process, or chemicals and no new IH sampling • New process and no new JSA/JHA • New equipment and no specific LOTO procedure • Analyze new equipment for safety prior to purchase (ie – machine guarding) • Poor hazard recognition skills of new staff (90 day items)

Hazard Prevention and ControlInitial & Recertification • Site not following the hierarchy of controls • Emergency drills not held annually • First Aid/CPR response must cover ALL shifts. • Inadequate contractor safety program

PSM Issues • Sites that fall under PSM will undergo a comprehensive PSM program evaluation. • Emerging issue: Sites are unable to abate PSM deficiencies within 90 days.

First Aid / CPR Issue! • If you are more than 5 minutes from public emergency responders, you must provide training and DESIGNATE first responders. • Simply providing the training without clarifying who is designated is not enough!

Safety & Health TrainingInitial & Recertification • Inadequate training for new hires • Inadequate training for temporary employees • Lack of knowledge of VPP • Lack of hazard recognition skills as evidenced by numerous hazards noted on walkthrough

Other Deficiencies • Safety incentive programs tied to injury/illness rates • Failed to correct a 90-day item from the previous VPP audit that you said you corrected!!!! • Little or no improvements to S&H program since the last VPP evaluation

Other Concerns – Continued: • Employee complaints filed with OSHA (S&H and 11c) • OSHA Citations The above could lead to termination of VPP participation!

Emerging Trend • Upper Management or Corporate Push: “You will submit the VPP application by XX/XX/2013……OR ELSE!”

SPEAK UP! • Safety and Health “Culture” MUST be established. • If the site is not ready, the results of the onsite may result in embarrassment.

Incentive Programs! • Incentives cannot create a disincentive to report injuries and illnesses. • Examples: Monetary bonuses Meals Gift Cards Days off

Incentives, cont. • “Incentive programs should promote safety awareness and participation in safety-related activities.” (VPP P&P Manual) • There is no problem with celebrating milestones so long as they are not “advertised” in advance. “We just…..” vs. “IF we……”

Incentives, cont. Examples of positive incentives: • Rewards for near-miss reporting • Rewards for involvement • Reward for hazard identification and/or abatement ideas

Incentives, cont. • “Regardless of the monetary value of the reward offered, a company whose incentive program has the potential to discourage worker reporting fails to meet the VPP’s safety and health management system requirements.” VPP Policy Memorandum #5 – Dr. David Michaels

Further Clarification • Refer to: Richard Fairfax Memo dated March 12, 2012 • “Employer Safety Incentive & Disincentive Policies and Practices” • Available on www.osha.gov

Annual Reports • Due February 15 every year • Please update me of personnel/email changes ASAP or you may not receive the annual report template • Follow correct format! (Sent Nov/Dec prior) • Rate table must reflect prior 3 years, not just 1 year

Annual Reports, cont….. • Rate table mistakes (60% average) • Elevated I/I rates and no explanation • Report must contain recommendations for improvement NEW: 10% of the annual reports are now audited by the National Office annually

Conclusion • Keep looking for ways to improve your program. • Benchmark with other VPP sites. • Participate as an SGE. • Keep abreast of new VPP policies. • Keep your STAR!!!!

Questions??

Contact information: Matt Gaines 816/283-0545 ex247 gaines.matt@dol.gov

Common Deficiencies Found on VPP Evaluations & Annual Reports