OSHA is responsible for enforcing the provisions of the Occupational Safety and Health Act of 1970 for about half the states; the remaining 26 states have been granted authority to set and enforce their own safety and health standards under a state plan approved by OSHA. At present, 22 of these 26 states enforce occupational safety and health provisions under a state plan covering all worksites, and have their own VPP programs. The other 4 states have plans covering only public sector employer worksites; VPP sites in these 4 states are part of OSHA’s federally managed VPP. To help ensure compliance with federal safety and health regulations and standards, OSHA conducts enforcement activities and provides compliance assistance to employers. Enforcement represents the preponderance of agency activity and includes safety and health inspections of employer worksites. Among its compliance assistance efforts, OSHA established the VPP in 1982 to recognize worksites with safety and health systems that exceed OSHA’s standards. A key requirement for participation in the VPP is that worksites have low injury and illness rates compared with the average rates for their respective industries. The VPP is divided into three programs (see table 1): the Star, Merit, and Star Demonstration programs. The Star program has the most stringent requirements because it is for worksites with exemplary safety and health systems that successfully protect employees from fatality, injury, and illness. OSHA’s Directorate of Cooperative and State Programs—the national office—oversees the VPP activities of each of its 10 regional and 80 area offices. Each regional office has a regional administrator, who coordinates all of the region’s activities, including the VPP, and a VPP manager, who implements and manages the program. The VPP manager conducts outreach to potential VPP sites and encourages participants to continually improve their safety and health systems. In addition, the VPP manager coordinates the region’s activities related to the program, such as reviews of applications submitted by potential sites and on-site reviews of VPP sites. Employer worksites apply to OSHA to participate in the VPP. They must meet a number of requirements, including having an active safety and health management system that takes a systems approach to preventing and controlling workplace hazards. As shown in figure 1, OSHA has defined four basic elements of a comprehensive safety and health management system. These requirements must be in place for at least 1 year. In addition, there must be no ongoing enforcement actions, such as inspections, at the worksites or willful violations cited by OSHA within the 3-year period prior to the site’s initial application to participate in the VPP. VPP sites are also required to have injury and illness rates below the average rates for their industries published by Bureau of Labor Statistics. These rates must be below the average industry rates for 1 of the most recent 3 years. VPP sites are required to report their injury and illness rates to OSHA’s regional offices annually. The VPP managers review this information and send summary reports to the national office. For each calendar year, the national office compiles a summary report of injury and illness rates for VPP sites participating in the program. OSHA determines whether worksites are qualified to participate in the VPP through its approval process, which includes an on-site review of each worksite. According to OSHA guidance, the regional offices are required to conduct an on-site review of each potential VPP site to ensure that the four elements are in place and to determine how well the site’s safety and health management system is working. As part of these reviews, the regions are required to verify the sites’ injury and illness rates, interview employees and management, and walk through the facilities. This initial on-site review usually lasts about 4 days and involves approximately three to five OSHA staff, according to OSHA’s VPP policies. OSHA also uses volunteers from other VPP sites—Special Government Employees who have been trained by OSHA—to conduct some portions of these reviews. OSHA’s national office is responsible for the initial approval of all new VPP sites. VPP sites in the Star program must also be reapproved every 3 to 5 years after an on-site review is conducted by the region. OSHA’s approval process is outlined in table 2. Once they have been approved, VPP sites must commit to continuously improving the safety and health of their worksites, maintaining low injury and illness rates, and reporting annually to OSHA on the status of their safety and health systems. The VPP sites’ annual reports detail their efforts to continuously improve and detail the sites’ injury and illness rates. OSHA’s regional offices review these reports to ensure that the VPP sites’ injury and illness rates have not increased beyond the program’s requirements. According to OSHA’s VPP Policies and Procedures Manual, OSHA must request that a site withdraw from the VPP if it determines that the site no longer meets the requirements for VPP participation. OSHA may also terminate a site for failure to maintain the requirements of the program. The national office is responsible for collecting the injury and illness data reported annually by VPP sites to the regions. If VPP sites’ 3-year average rates rise above the average rates for their industries published by the Bureau of Labor Statistics, the regions must place the site on a rate-reduction plan if an on-site review is not conducted that year or must place the site in a 1-year conditional status if an on-site review is conducted. The regions must also notify the national office of actions they take in response to incidents, such as fatalities and serious injuries, at VPP sites. The regions are required to review sites’ safety and health systems after such incidents to determine (1) whether systemic changes are needed to prevent similar incidents from occurring in the future and (2) whether the site should remain in the program. The regions may also conduct on-site reviews of VPP sites if they determine that the incidents were related to deficiencies in the sites’ safety and health management systems. The decision to recommend whether a site at which a fatality has occurred should remain in the program is left to the discretion of the regional administrator. The VPP has grown steadily since its inception, with the number of employer worksites in the program more than doubling—from 1,039 sites in 2003 to 2,174 sites in 2008. During this period, the number of sites in the federally managed VPP, representing over two-thirds of all VPP sites, increased at a similar rate as the number of sites in the state managed programs. In 2003, there were 734 sites in the federal VPP and 305 in the state managed VPP. By the end of 2008, both the federal and the state programs had more than doubled to 1,543 and 631, respectively. (See fig. 2.) Although the industries represented in the VPP did not change significantly from 2003 to 2008, there were substantial increases in certain industries. The largest industry in the VPP was the chemical industry, which accounted for a 43 percent increase in the number of VPP sites, from 208 in 2003 to almost 300 in 2008. The motor freight transportation industry, which had only 20 sites in 2003, grew tenfold to just over 200 sites in 2008, due in part to the growth in the number of Postal Service sites. In addition, the number of sites in the electric, gas, and sanitary services industries increased from about 50 sites to more than 200 during the same period. See figure 3 for a comparison of the largest industries represented in the VPP in 2003 and 2008. While 4 federal worksites—including the Tobyhanna Army Depot in Tobyhanna, Pennsylvania, and the National Aeronautics and Space Administration Langley Research Center in Hampton, Virginia—have participated in the VPP since the late 1990s, the number of federal worksites increased to almost 10 percent of all VPP sites in 2008. At the end of 2008, almost 200 VPP sites were federal agencies or Postal Service sites. The majority of these sites—157—were post offices, processing and distribution centers, and other postal facilities, while most of the remaining sites were Department of Defense facilities, such as naval shipyards, Army depots, and Air Force facilities. In addition, from 2005 to 2008, 7 OSHA area offices in 1 region were approved as new VPP sites as a result of OSHA’s efforts to have all of its offices participate in the program so that they could be role models for the federal agencies. The average size—based on the number of employees—of VPP sites has become increasingly smaller in the last 5 years. From 2003 to 2008, the average number of employees at VPP sites decreased from 501 to 408. In addition, the median size of a VPP site decreased from 210 to 145 employees. As shown in figure 4, the proportion of VPP sites with fewer than 100 workers increased from 28 percent in 2003 to 39 percent in 2008. Across all VPP sites, the number of employees covered by the VPP has grown to over 885,000 workers. A key factor influencing growth of the VPP has been OSHA’s emphasis on expansion of the program. For example, in 2003, the Secretary of Labor for OSHA announced plans to expand eligibility for the VPP to reach a larger number of worksites. These plans included adding more federal sites, such as Department of Defense facilities and certain types of construction sites. OSHA’s national office has given each of its 10 regions targets for the number of new sites to be approved each year. While the regions did not always meet these targets from fiscal years 2003 to 2008, they generally increased the number of new sites each year, as shown in table 3. Several OSHA regional administrators told us that expanding the program beyond the current level of approved sites will be difficult, given their current resources.