# Presentation: 498956

## VPP in Construction 

**Paula O. White**
**Director, Cooperative and State Programs**
**Occupational Safety and Health Administration**
**ASSE**
**June 14, 2005**

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## VPP for Construction  Why?

- Provides flexibility to meet unique aspects of industry
- Companies may attain recognition at different levels

## VPPC OVERVIEW

- Site-based
- Similar to traditional VPP but only available for long-term sites (two or more years in duration)
- Demonstration
- Allows VPP approval for alternative programs that may not be covered by VPPC
- Corporate, Division, Business Unit (C/D/BU)
- Covers all work activities within a designated geographical area

## Highlights:  What’s New

- Eligibility:  C/D/BU
- Corporate
- Division
- Business Unit
- Open to all contractors
- Large generals
- Small subs

## OSHA Proposed C/D/BU

- Approval and Recognition
- All contractually responsible work
- Limited to state boundaries
- Option for expansion
- Evaluations
- One Corporate onsite
- Site/project-level onsite evaluations will follow a tiered approach
- Corporate evaluations recognized by all regions

## Major Issues With the Proposal

- Number of Site/Project Evaluations
- Union Support
- Method
- Amount
- New Requirements
- Corporate Oversight
- Fall Protection
- Sub-contractor prequalification
- Drug Program
- Proposal Too Cumbersome

## What We Heard:How many C/D/BU evaluations should be required?

- 90% of responders support the *concept* of a tiered approach as proposed in VPPC
- 33% of supporters prefer to see a higher number of site inspections (closer to 10%)

## Union Support 

- Complex Issue:
- Jobs not planned or started
- Uncertainty of which unions are affected
- Some unions come to site for short periods of time (1 day to 2 weeks)

##   Union Support  OSHA Proposal:

- Each union could do own signed statement of support
- President of local Building Trades Council could  sign on behalf of all local unions
- President of Building and Construction Trades Dept, AFL-CIO, and/or general presidents of international unions could sign statement of support.

## OSHA Proposed:Corporate Oversight

**A process to review and analyze project/site information regarding the identification, correction, and tracking of  workplace hazards**
**100% of responders agreed that a corporate oversight system is a good requirement**

## Related Questions 

**100% Fall Protection**
- 		50% said** yes**
**Subcontractor Prequalification**
- 		44% said yes
**Drug Testing/Screening**
- 		66% said Yes

## Some Commenter  Concerns 

- Proposal too cumbersome for small contractors
- Requires too much administrative effort for small companies without full time safety personnel
- Inadequate incentives provided for participation
- Potentially negative impact on OSHA inspection program

## Cooperative Programs to Participate In Now 

- Traditional VPP (Site Based)
- Demonstration Programs
- Short-Term Construction
- Mobile Workforce
- Region V Demonstration Pilot
- Resident Contractor at Non-VPP Sites
- OSHA Challenge – Construction Track
- Partnerships

## VPP Demonstrations 

- 1993: Resident Contractor Demo
- JE Merit, Brown& Root
- 2001- Adopted into regular VPP
- 1998: Mobile Workforce Star Demo*
- LPR Construction , E & K of Omaha, HDR Engineering
- 1998: Short-Term Construction Star Demo*
- J.E. Merit, Torcon, Black and Veatch
- 2003- Region V Mobile Workforce Pilot
- Century, Danis, Furgerson
- 2004- Resident Contractors at non-VPP host sites.

## OSHA Challenge

- Road Map for safety and health
- Recognition
- Conserve OSHA resources
- Increase and expedite participation

##  Challenge Administrators

- Curtis Lumber Company
- United States Postal Service
- VPP Participants’ Association
- Black & Veatch
- Construction Safety Council
- Ohio Valley VPPAC
- Associated Builders and  Contractors
- Associated General Contractors of America
- NEA - Association of Union Constructors
- Independent Electrical Contractors

## Next Steps

- Continuing review with the Agencies
- Final decision will determine the timeframe for revised FRN
- Final FRN may reflect changes from the original proposal based on decisions by the Acting Assistant Secretary.
- Questions? Contact the Directorate of Cooperative
- and State Programs 202 693-2213.

## Questions or Comments?

## Contact

- Paula White
- _white.paula__[@dol.gov](mailto:aula@dol.gov)_
- 202-693-2200