What's Your Opinion? Some members of Congress want to make OSHA’s Voluntary Protection Programs a permanent entity. Do you believe VPP is 'sound policy'?

The VPP is what is right with industry and government interaction. Partnering is always the better solution, safer for employees, and more effective for compliance in the long run. It helps reduce the tension that can sometimes exist between OSHA and industry. OSHA inspections can often have a feeling of tension even for the most safe companies. VPP as a permanent policy is good for employers, employees, and OSHA.

Important program that saves workers lives

The value of VPP is region-specific. As an auditor for 28 years, I have been to plants that were "just recertified VPP" where unsafe general conditions abound. I have also been to worksites where VPP has driven safety down to the individual worker - sites where safety is highly valued and clearly a top priority. When you have a system with little funding, that relies on volunteer auditors - especially where the auditor in your locations knows you could be coming to theirs in the near future - you allow the potential for degradation of the high standards of VPP to be relegated to a quick plant walkthrough with some perfunctory findings, followed by a plaque on the wall, some pats on the back, and coffee in the conference room.

SCOSHA OVP is a great program to partner with, we try to invite them to our sites as much as possible. We have found that it is a great learning tool for our inhouse people as well as our subcontractors. When the team is aware that our company has an ongoing relationship with the OSHA OVP the level of safety awareness is highly increased. I can't speak for other states , but the team from SCOSHA OVP perform a very thorough inspection and work hard to get the message of employee safety out to contractors in the construction industry.

We don't need more permanent government positions. Unless a VPP agency was staffed completely by already employed federal workers, I cannot support it. Government is too big and inefficient and many agencies have responsibility over lap. The whole of what is the federal bureaucracy needs to hit the gym or some slim fast.

having a VPP program helps management and worker stay safe and have some where to turn if things get unsafe at work or get answers for safety questions when bosses want the job done no matter what it takes.

Each state has a full-time OSHA consultation staff capable of providing safety and health assistance to businesses within their state. Each state runs a SHARP program similar to VPP for small businesses. The most effective thing congress could do to improve business assistance programs is expand the state 21(d) consultation agreements to allow them to work with larger sized businesses.

VPP has merits in theory but is flawed too often in implementation. One of our facilities applied for VPP status several years ago through a state ran program. This facility had a stellar safety record with millions of hours without a Lost Time incident and a Total Recordable Rate 5X less than their peers in the same SIC classification. OSHA representatives spent days in the facility on two separate occasions, complementing everything from the extensive safety training program to the impeccable housekeeping throughout the facility. At their out briefing, state OSHA officials stated we were meeting all requirements for VPP certification but they would not certify the site for VPP unless we sent two representatives from our location to their very expensive VPP training program! The safety performance of our site, the written and well-implemented safety programs and processes and facility conditions mattered little to them as long as they got their money from a pair of VPP course registrations! After that disappointing and disillusioning experience, we decided to never again attempt to be a part of VPP at that site or any other of our 60+ US locations!

OSHA needs a healthy balance between just enforcement and positive encouragement, and they have a long way to go to catch up. The VPP is just a start, but a wonderful program that does a thousand times more than any citation can do to motivate workers and management to work together collaboratively to create an injury-free culture! I worked with a company to establish a VPP program and maintained it for 12 years, and also worked along side OSHA as a special government employee for 5 of those years, conducting VPP audits of other employers and it always impressed me how hard a team will work to eliminate hazards all for the right to fly the VPP flag. We would spend a week in a facility using a fine-toothed comb to find OSHA violations, and they would welcome them in order to get better! Conversely, I have seen how hard a team will fight against a compliance officer for finding three violations that will count against them, create a citation and go on the public record against them. It's all in the approach!

When government agencies set very specific regulations, those subject to those regulations will seek and apply every possible loophole or exemption from the requirements. This applies to the income tax code, EPA and OSHA standards, and any other area of commerce. OSHA took a different approach with VPP - if employers are exceeding expectations, work with them on creative ways to accomplish the overall goal, and approach regulations without a complies/violates view. This requires more imagination and insight on the part of the regulators, to determine whether the employers are getting the job done as well or better, and requires imagination on the part of the employers to find that better way. That's probably a good thing: innovative solutions work in every field imaginable, and it is only through innovation that we increase what is possible by more than minor increments. In my company, our stated objective is zero injuries. Is that possible? Yes, we go many days without injury; string enough days together, and we get a year without injuries. We had to find innovative ways to do that. If OSHA will partner with more employers instead of just being there to cite, fine, and instill fear, it will be an asset to its clientele. As Rex Butler wrote below: VPP is what is right with industry and government interaction. More of that will make for better, more competitive, safer US companies, which is better for everyone.

The VPP provides so many services to the small contractors and helps establishes a partnership where with compliance there's the fear factor.

Partnership between OSHA and General Industry makes a powerful team to drive reduction of illness and injury. It requires a commitment from management and involvement of all of the associates at the VPP site. OSHA regulations alone do NOT keep you safe. Commitment and Adherence to VPP principles will. VPP here in South Carolina (State administered OSHA program) is also about out-reach to the community, benchmarking other VPP sites and sharing best practices.

I believe a company should have a policy that is solid. Voluntary protection is a liability for companies in my eyes. If something happens to the employee that has voluntary wore PPE for example then they will find a way to turn it back to the company at being at fault. Not a good ideal.