This publication does not itself

alter or determine compliance

responsibilities, which are set forth

in OSHA standards themselves, and

the Occupational Safety and Health

Act. Moreover, because interpretations and enforcement policy may

change over time, for additional

guidance on OSHA compliance

requirements, the reader should

consult current administrative

interpretations and decisions by the

Occupational Safety and Health

Review Commission and the courts.

Material contained in this

publication is in the public domain

and may be reproduced, fully or

partially, without the permission of

the Federal Government. Source

credit is requested but not required.

This information will be made

available to sensory impaired

individuals upon request.

Voice phone: (202) 219-7266;

Telecommunications Device for the

Deaf (TDD) referral phone:

1-800-326-2577.
U.S. Department of Labor

Occupational Safety and Health Administration

1997

You’ve Been Selected

 to Be a VPP

Onsite Team Member!

Now What?

About VPP................................................................... 1

Types of Onsite Reviews ............................................... 3

Pre-Approval Onsite Review ............................................ 3

The Evaluation Onsite Review ......................................... 3

Merit Sites .................................................................... 4

Star Sites ...................................................................... 5

Demonstration Sites ..................................................... 6

The Team ......................................................................... 6

Planning the Visit ............................................................. 7

Conducting the Visit ................................................................... 8

The Opening Conference ................................................. 8

Documentation Review .................................................... 8

Site Tour........................................................................... 9

Safety Review ............................................................ 10

Industrial Hygiene Review .......................................... 10

Informal Interviews ..................................................... 10

Problem Areas ........................................................... 11

Hazard Correction .......................................................... 11

Formal Interviews ........................................................... 11

Management Interviews ............................................. 11

Employee Interviews .................................................. 12

Contractor Interviews ................................................. 12

Preparation of Findings .................................................. 12

Compliance and Status of Correction ........................ 12

Eligibility for VPP ........................................................ 12

Non-Eligibility for VPP ................................................ 13

Draft Report .................................................................... 13

Team Responsibilities ................................................ 13

Review by Applicant ................................................... 13

Presentation of Findings and Recommendations .......... 14

Preliminary Briefing .................................................... 14

Final Briefing .............................................................. 14

OSHA Regional Offices.................................................. 15

Contents

i

1

Welcome to the Voluntary Protection Programs (VPP)

Team! You are about to join a multidisciplinary group that

will evaluate the effectiveness of the safety and health

program at a worksite seeking OSHA’s recognition for

excellence.

This is a great opportunity to see firsthand how an

outstanding occupational safety and health program actually

works. And it’s a chance to help a site already committed to

safety and health improve its program. Although the site

visit is similar to an inspection in some regards, the cooperative approach creates an entirely different climate and

focuses on the worksite’s safety and health program. OSHA

enters not unannounced, but at the invitation of the company. It’s nice for a change to go where you’re welcome and

wanted. Enjoy the difference!

You will have received from the OSHA team leader,

information about the site in advance of the visit, and

usually, you also will have received your specific team

assignments. The outcome of the visit will be a report

supporting the OSHA VPP team’s recommendation to the

Regional Administrator or to the Assistant Secretary of Labor

concerning the site’s participation in the VPP.

VPP is a strong component of the “New OSHA’s” commitment to partnership with companies that want to do the

right thing. Your participation on the review team enables

OSHA to recognize model programs and to encourage other

companies to strive for excellence. Thanks for your help.

OSHA’s VPP is built on the twofold foundation of

■ voluntary workplace safety and health excellence, and

■ cooperation among industry, labor, and government.

About VPP
General industry, construction, and maritime sites may

apply to the VPP. The application is initially reviewed by

OSHA personnel at the regional office. When OSHA judges

the application complete, a date is set, in cooperation with the

applicant site, to conduct an onsite visit. This visit helps to

determine if the safety and health program described in the

application is effectively implemented at the site.

In the VPP application, the site’s management agrees to

correct any hazard found. Any hazards not corrected before

the team leaves the worksite will be described, along with the

agreed upon correction, in a document referred to as the “90

Day Item List,” meaning that all items will be corrected

within 90 days.

Managers and employees will be very helpful and cooperative. They will be eager to show you the successes of their

safety and health program. When you have suggestions for

improvement, they will be ready to listen to you. Because all

hazards found will be corrected, and because the site has

voluntarily requested an OSHA review, no citations will be

issued.

VPP sites are models from which others in the industry

can learn. They also serve as models for the safety and health

specialists who comprise OSHA’s VPP review teams, demonstrating the remarkable results that can follow when companies and their workers place a priority on workplace safety

and health.

To assess a site’s safety and health program, the VPP team

will review program-related documents at the site, interview

employees and site contractors, and tour the site. The final

day at the site usually is spent writing the draft report of the

team’s findings.

You can expect your days at the site to be long and the

work to be intense, but you can also expect to enjoy the spirit

of cooperation typical of VPP site visits. We will all be working toward one goal: to keep America’s workers safe and

healthy.

2
In participating in a VPP onsite review, there are a number

of things you need to be familiar with—such as the opening

conference, documentation review, site tour, formal interviews, preparation of findings, and evaluation. Let’s take a

look at what you need to do at the site and after the visit.

Pre-Approval Onsite Review

If you have been selected to participate on a pre-approval

onsite review team, you will be assessing the safety and

health program of the applicant worksite. This means the site

has decided to apply to the VPP, has worked to implement

quality protection for employees, and has invested many

hours in preparing its application to participate. You will

help determine if the worksite qualifies for the VPP. The

goals for a pre-approval onsite review are as follows:

■ Verification. Ascertain the accuracy of the information

supplied in the application.

■ Program Assessment. Identify both the strengths and

weaknesses of the site’s safety and health program as

currently implemented.

■ Recommendation. Compile data for the Assistant

Secretary of Labor to make an approval decision.

The Evaluation Onsite Review

If you have been selected to be part of a VPP evaluation

onsite review team, you will be assessing the safety and

health program of a currrent participant in the VPP. It may

be between 1 and 5 years since the last VPP onsite review,

depending on the program in which the worksite participates

and the length of time the site has been in the program. The

following four goals apply to the evaluation onsite review:

■ Program Assessment. Determine that the program

continues to provide effective safety and health

protection to employees.

3

Types of

Onsite Review
4

■ Goal Progress (for Merit and 1-year conditional evaluations). Determine the progress toward reaching Merit

goals or 1-year conditional goals.

■ Program Effectiveness (for Demonstration evaluations).

Determine the effectiveness of alternative

requirements being tested.

■ Recommendation. Compile for the Assistant Secretary of

Labor or the Regional Administrator, as appropriate,

information necessary to make a decision to continue

the site in its current program or advance the site to

the Star program.

The review of a participating VPP site’s safety and health

program follows the same procedures established for the

pre-approval onsite review, except for the following:

Merit Sites

At sites participating in the Merit program, the team will

assess the site’s progress toward meeting its Merit goals.

■ If the site has met all its Merit goals, and if the site’s

performance remains strong with regard to the other

requirements for Star, the team may recommend that

the Assistant Secretary of Labor approve the site as a

Star site.

■ If the site is making good progress toward meeting its

Merit goals, but if time remains in the approved Merit

period, the team may recommend continuation as a

Merit site. This recommendation is made to the OSHA

Regional Administrator, who has the authority for

approval.

■ If the site is not making good progress toward meeting

its Merit goals, and if the time in the approved Merit

period has elapsed, the team may recommend to the

Regional Administrator that the site discontinue

participation in the VPP.

■ If the site has not completed its Merit goals and the

approved period for Merit has expired, but the site has

made a consistent and good effort to meet the goals
5

and has had its performance affected by significant

change, such as a change in plant manager, the team

may recommend that the Regional Administrator

extend the Merit period.

Star Sites

At sites participating in the Star program, the team will

assess the safety and health program to determine whether

the site remains at Star quality. The team should make particular note of program improvements since the previous

onsite visit.

■ If the site continues to meet all the requirements for

Star, the VPP onsite review team may recommend that

the Regional Administrator approve continuation of

the Star program. The Director of the Directorate of

Federal-State Operations in the national office should

be informed of the approval, and the Assistant Secretary of Labor will send a letter to the plant manager

indicating his knowledge of the approval.

■ If the site has a good program in place, but one or two

of the program elements has slipped slightly in quality,

the VPP onsite review team may recommend to the

Regional Administrator a 1-year conditional approval,

with specified goals to meet within that 1 year. When

the team reviews the site at the end of that year, if it

recommends to the Regional Administrator a return to

full Star status, that date of approval is considered the

site’s first year in Star for purposes of future

evaluation.

■ If the site has slipped so far from Star quality that the

team judges the site’s commitment to safety and health

excellence to be insufficient, the team may recommend

to the Regional Administrator that the site withdraw

from the VPP.
6

Demonstration Sites

At sites participating in the Demonstration program, in

addition to determining that the worksite is maintaining a

Star quality safety and health program, the team will determine if the alternatives to the Star requirements being demonstrated provide effective protection to employees. All demonstration approval decisions are made by the Assistant

Secretary.

■ If the team determines that the alternatives require

futher testing, it recommends approval for

continuation in the Demonstration Program.

■ If the team determines that the alternatives provide

effective protection, it recommends that the Star

program requirements be changed to permit inclusion

of the alternative requirements.

■ If the team determines that the alternatives are creating ineffective protection, it recommends that the

Demonstration be ended and the worksite withdraw

from the Demonstration program.

The Team

The onsite review is conducted by a team of OSHA personnel, often supplemented by Special Government Employees (SGEs) with occupational safety and health expertise who

have volunteered from participating VPP sites and personnel

from other government agencies. The VPP regional program

manager chooses the team. Team size will depend on the size

and complexity of the site, but will include the following:

■ A team leader (OSHA)

■ A safety professional (OSHA or SGE), and

■ An industrial hygienist (OSHA or SGE).

At large and/or more complex sites, the team may be

expanded to include the following:

■ Other safety and health professionals, such as a PSM

specialist (OSHA or SGE), and

■ A back-up team leader (OSHA).
Planning the Visit

The team leader coordinates arrangements for the onsite

review. This requires that he/she

■ Be thoroughly familiar with the site’s application;

■ Provide pertinent information, including sections of

the application, to team members;

■ Coordinate the timing and duration of the review with

team members and site management; and

■ Determine what personal protective equipment (PPE)

team members should bring and what PPE will be

provided by the site.

The team leader will conduct a strategy meeting just prior

to the onsite review. All team members must attend. At this

meeting, team members assignments will be reviewed for

completing the following specific onsite review tasks:

■ Review of injury log and recalculation of rates,

■ Review of the written safety and health program and

supporting documentation,

■ Site walkthrough and informal employee interviews,

■ Formal interviews, and

■ Draft preparation of the review report.

Monday Tuesday Wednesday Thursday Friday

AM Travel Records and Formal Report Closing

 Strategy Document Interviews Writing Conferencence

 Meeting Review & Site Tour

PM Opening Document Formal Report Travel

 Conference Review Site Interviews Writing

 & Site Tour Tour and Site Tour

The following chart describes a typical week for onsite

evaluations.

At the end of each day, the team will hold a short meeting

to share the experiences of the day. This is followed by a brief

reporting session between team members and personnel

7
Documentation Review

The team will review site documents relating to all aspects

of the safety and health program to determine whether they

adequately address hazards at the site. Sample items to be

reviewed include the OSHA 200 log, health hazard reports,

and other documents and information, such as the following:

■ OSHA 200 injury/illness logs for the past 3 full

calendar years and year-to-date, with supporting

documents such as workers’ compensation first

reports of injuries, first-aid logs, and employee

medical records. In advance of the onsite visit, the

team leader will provide the site with a medical

access order. The employer must post this order in

an obvious place. The team will review site logs and

site logs for the contractors whose employees have

worked on the site at least 500 hours a quarter.

■ Baseline surveys for safety and health hazards,

including all industrial hygiene sampling records

and material safety data sheets (MSDSs).

Conducting

the Visit

designated by the site, such as the site safety manager, the

plant manager, and any designated hourly employees. The

joint session provides the opportunity to share the day’s

findings, ask and answer any questions, and raise concerns.

Often the team’s recommendation can be shared with this

group on Thursday evening.

The Opening Conference

The team leader leads the initial briefing of personnel

designated by the site. This briefing defines the review’s

scope and expectations and clarifies needed assistance.

8
■ Evidence of line accountability, such as performance

evaluations and bonus systems.

■ Hazard analyses, such as change analyses, process

hazard reviews, job hazard analyses, and phase hazard

analyses.

■ Employee reports of safety and health hazards and

suggestions, including documented responses.

■ Reports of site inspections and accident investigations,

including documented responses.

■ Preventive maintenance records.

■ Emergency procedures, including critiques of drills

and documented responses to recommendations for

improvement.

■ All specialized programs required for complilance

with OSHA regulations, such as lockout/tagout,

confined spaces, and bloodborne pathogens, to name a

few.

■ Safety Committee mminutes, if applicable, and/or

records of other methods of elmployee involvement.

■ Training records, including types of training given,

how curriculum is developed and reviewed, how

understanding of training is assessed, and how an

individual employee’s training is documented.

■ The annual evaluation of the site’s safety and health

program, including documented responses to the

evaluation’s suggestions for improvement.

Team members may request additional documents and

records for review. Requests for documents must be properly

and clearly communicated to the applicant.

Site Tour

The review team’s site tour ensures that the safety and

health program is operating as described in the application

and ascertains the effectiveness of the program’s implementation. There are a number of reviews the team performs during

the tour, which are identified in the following paragraphs.

9
Safety Review

The safety professional(s) conducting this review should

■ Follow the entire process/operation flow, where

possible;

■ Suggest revisions to the corresponding safety and

health management system documents (e.g., emergency planning, self-assessment procedures and

reports, and employee complaints or reports of hazards) where work procedure improvements are

needed; and

■ Note specific hazards needing correction and discuss a

time frame for correction.

Industrial Hygiene Review

The industrial hygienist should

■ Follow the entire process/operation flow, where

possible;

■ Check known hazard areas, where applicable (e.g.,

ventilation, storage, handling and use of toxic materials,

emergency equipment, respirator use and maintenance,

and radiation and noise protective measures), based on

review of monitoring records and material safety data

sheets. Look for possible problems in work practices;

■ Look for evidence that these hazards are appropriately

managed and that no other hazards have escaped

management’s attention; and

■ Suggest program revisions to the corresponding safety

and health management system documents where improvements are needed (e.g., safe work practices and

training, respirator program, industrial hygiene sampling

and analysis, and hazard communication systems).

Informal Interviews

■ During the tour, team members will interview randomly

selected employees at their work stations. Interviewers

should include supervisors, maintenance personnel,

safety committee members, and contract and temporary

employees.

10
■ Typical questions should address work procedures,

emergency procedures, and PPE.

■ Interviews should be conducted in a manner that

avoids disruption of normal operations.

■ Interviews are to be conducted in a confidential manner that encourages employees to speak freely.

■ Contractor employees should be included in the informal interviews to ensure that equally effective protection is provided to all employees involved in the

contractor’s operations.

Problem Areas

Special attention should be given during the site tour to

any problems that have shown up repeatedly during interviews

and records review, especially during the review of the OSHA

200 log.

Hazard Correction

All hazards found must be corrected immediately, if possible,

and otherwise within 90 days. When safety and health program deficiencies are found, the onsite review team and site

personnel will agree upon goals for program improvement.

Formal Interviews

The team leader and, where present, the backup team leader

conduct the formal interviews.

Management Interviews

Interviews with site management provide the review team

with information about the site’s safety and health program,

management’s commitment to and involvement in the

program, and the management oversight system.

11
Contractor Interviews

Contractor interviews indicate the contractors’ awareness

of site hazards and of the site’s requirement for a contractor’s

safety and health program.

Preparation of Findings

 Prior to closeout with the site’s management, the team

should meet to review and summarize its findings. To achieve

team consensus, time should be allowed for a complete

discussion of issues, such as the following:

Compliance and Status of Correction

■ Items that cannot be corrected immediately will be

described along with proper correction. This list,

referred to as the “90-Day Items,” will be attached to

the draft report given to the site management.

■ The draft report of the team’s findings will not be

prepared for the Assistant Secretary’s signature until

the regional VPP manager has received assurances in

writing that all 90-day items have been corrected.

Eligibility for VPP

■ If the team decides that the site is eligible for Merit, the

team then must agree on the Merit goals (the programmatic improvements the site must make), the evidence

the site must produce to show that the goals have been

met, and the amount of time the site will be allotted to

make these improvements, usually from 2 to 4 years.

■ If the team decides that the site is eligible for Star, the

team will write the report recommending Star

approval. This report will stress the particularly

12

Employee Interviews

Employee interviews gauge the extent of employee

awareness of hazards, and awareness of and involvlement in

the program, and the management oversight system.
impressive aspects of the site’s safety and health

program. Important considerations include whether

• A Star site has few 90-day items to correct,

• All safety and health program elements and

subelements have been in place and operating

effectively for at least 1 year, and

• Injury incidence and lost-workday case rates are at or

below the most recently published industry average.

Non-Eligibility for VPP

If the team decides that the site is not eligible for VPP, the

site leader will suggest that the site withdraw its application.

If the team chooses not to withdraw, the team will write a

report clearly stating the deficiencies and recommending no

approval.

Team Responsibilities

■ The team leader is responsible for preparing a report

following the format prescribed in TED 8.1a, VPP

Policies and Procedures Manual,* Appendix F or H, as

appropriate. He or she may assign other team

members to prepare sections of the report.

■ The draft report will be written before the team leaves

the site, whenever possible.

■ Each team member will review the draft report, which

will reflect the team’s consensus on the applicant’s

qualifications for approval.

13

*For copies of the manual, contact the nearest OSHA regional office listed elsewhere in this

booklet, or call the OSHA Directorate of Federal-State Operations at (202) 219-7266. See also

OSHA’s Web site at http://www.osha.gov/ for this and other agency information.

Review by Applicant

Before the final report is issued, the team leader will give

the applicant an opportunity to review the draft report for

accuracy. The applicant will be assured that factual

corrections will be made.
14

Presentation of Findings

and Recommendations

Preliminary Briefing

The onsite review findings may be presented to the applicant in a preliminary briefing, prior to the formal presentation. This preliminary briefing is usually held Thursday

evening.

Final Briefing

The team leader and team members will hold a formal,

final briefing with site management and employee representatives at the conclusion of the onsite review. The team’s findings and its recommendation to the Assistant Secretary of

Labor or Regional Administrator must be presented before

leaving the site. The team leader will stress that the team is

making a recommendation, not an approval decision. The

responsibility for making a decision regarding a new approval rests with the Assistant Secretary of Labor, and for

continuation in the Star and Merit programs, with the

Regional Administrator.
*These states and territories operate their own OSHA-approved job safety and health programs

(Connecticut and New York plans cover public employees only). States with approved programs

must have a standard that is identical to, or at least as effective as, the federal standard.

15

OSHA Regional Offices

Region I

(CT,* MA, ME, NH, RI, VT*)

JFK Federal Building

Room E-340

Boston, MA 02203

Telephone: (617) 565-9860

Region II

(NJ, NY,* PR,* VI*)

201 Varick Street

Room 670

New York, NY 10014

Telephone: (212) 337-2378

Region III

(DC, DE, MD,* PA, VA,* WV)

Gateway Building, Suite 2100

3535 Market Street

Philadelphia, PA 19104

Telephone: (215) 596-1201

Region IV

(AL, FL, GA, KY,* MS, NC,

SC,* TN*)

Atlanta Federal Center

61 Forsyth Street, S.W.

Room 6T50

Atlanta, GA 30303

Telephone: (404) 562-2300

Region V

(IL, IN,* MI, MN,* OH, WI)

230 South Dearborn Street

Room 3244

Chicago, IL 60604

Telephone: (312) 353-2220

Region VI

(AR, LA, NM,* OH, TX)

525 Griffin Street

Room 602

Dallas, TX 75202

Telephone: (214) 767-4731

Region VII

(IA,* KS, MO, NE)

City Center Square

1100 Main Street, Suite 800

Kansas City, MO 64105

Telephone: (816) 426-5861

Region VIII

(CO, MT, ND, SD, UT,* WY*)

1999 Broadway, Suite 1690

Denver, CO 80202-5716

Telephone: (303) 844-1600

Region IX

(American Samoa, AZ,*

CA,* Guam, HI,* NV,* Trust

Territories of the Pacific)

71 Stevenson Street

Room 420

San Francisco, CA 94105

Telephone: (415) 975-4310

Region X

(AK,* ID, OR,* WA*)

1111 Third Avenue

Suite 715

Seattle, WA 98101-3212

Telephone: (206) 553-5930