VPP: What it Takes to be a Star

The companies that participate in OSHA's Voluntary Protection Programs have some of the best occupational safety and health programs in the country. What does it take to join VPP, and what does it take to stay a Star?

It's a little ironic. John Storm wants to take time out of his schedule to talk about his facility's participation as a Star site in OSHA's Voluntary Protection Programs, but he's busy very busy he explains via a preliminary e-mail.

Storm's been thinking about stars quite a bit; as the director of Facilities Management Services, Space Gateway Support, at Kennedy Space Center in Florida, he's one of many people helping to ensure the space shuttle Discovery has a safe and successful flight to the stars.

Space Gateway Support (SGS), a joint venture created to provide launch support and base operations services to Kennedy Space Center, Cape Canaveral Air Force Station and Patrick Air Force Base, is one of nearly 1,300 worksites a number that is growing on an almost daily basis participating in VPP through state plans and federal OSHA. Talking to Storm, the effort and commitment required to become a VPP Star becomes apparent.

"Our proposal to the government included our commitment to become an OSHA Star company and in doing so, demonstrate to our customers and our employees our core value of workplace safety and health excellence," says Storm. "Our contract was awarded on Oct. 1, 1998. We immediately began the planning and preparations for submitting our VPP application to OSHA. Our application was accepted, and our first OSHA on-site inspection was conducted in October 2001."

This initial visit, he went on to say, consisted of approximately 15 OSHA VPP special government employees (SGEs they are employees of VPP sites who have received training from OSHA in how to conduct on-site audits) and OSHA field compliance specialists who carried out what Storm calls "an extremely thorough" evaluation of the facility, perused safety and health records and written programs and conducted in-depth interviews with employees.

While the thought of not one but of many OSHA "inspectors" on site can send a chill through the heart of even the toughest safety manager, Storm seems almost elated by the experience, calling it "an outstanding opportunity to learn from our evaluators and improve our program." Although the evaluation process turned up some problem items, says Storm, Space Gateway Support was able to correct them immediately.

He adds, "The great part of the inspection process was the interaction between the inspectors and the floor-level shop employees." The visitors from VPP were "experts with many, many years of safety and health experience," says Storm, who commends them for their efforts to mentor and educate Space Gateway Support employees.

The facility completed its VPP audit with no major findings, 13 best practices and a Star.

1,300 and Counting

In 1979, VPP took its first baby steps, when California began an experimental program similar to VPP. In 1982, OSHA formally announced VPP and approved the first site. In 1998, federal worksites became eligible for VPP.

The Bush administration has placed an emphasis on cooperative programs and alliances, and former Assistant Secretary of Labor John Henshaw "challenged the safety and business communities to grow this program significantly," notes Paula White, OSHA's director of Cooperative and State Programs. In fact, in 2004, Henshaw threw down a gauntlet and said he'd like to see 8,000 worksites participating in VPP.

"I called that his challenge and my nightmare," jokes White, who adds that current Acting OSHA Administrator Jonathan Snare is equally as committed to the program.

VPP sets performance-based criteria for management commitment, employee involvement, hazard recognition and mitigation and employee training; invites sites to apply; and then assesses applicants against the criteria. OSHA's verification process includes an application review and a rigorous onsite evaluation by a team of OSHA safety and health experts that includes, in some cases, SGEs.

The SGEs are tough, admits Christopher Thursby, a senior safety engineer at Monsanto's Muscatine, Iowa, Star site who also has shepherded the VPP process at a Monsanto Star facility in Soda Springs, Idaho. "The SGEs are from sites that are already in VPP and they really scrutinize your program,'" he says.

Concurs R. Davis Layne, the executive director of the Voluntary Protection Program Participants Association (VPPPA), "SGEs have the attitude of 'It was hard for me to get through, and you've got to go through the same process if you want to be admitted.'"

OSHA approves qualified sites to one of three programs: Star, Merit or Star Demonstration, which provides recognition for worksites that address unique safety and health issues. Sites that make the grade must submit annual self-evaluations and undergo periodic onsite re-evaluations to remain in the programs.

Management Commitment

The VPP program is "designed to change the safety culture of participants," says White. "The reason the program is successful is because it sells itself. This program makes a difference. It saves lives and reduces costs. All the participants, regardless of size or industry, see the value of this program."

The largest employer in VPP is the Northrop Grumman Newport News with over 19,000 employees. The smallest participant in VPP has six employees. They all have one thing in common: Management made a choice and a serious commitment of resources to apply for VPP. Why? What is it about VPP that companies are willing to devote hundreds of employee hours to the application process, the inspection process and the recertification process?

"Monsanto feels that compliance is a bare minimum," explains Thursby. "What we're looking for is best practice and that's what the VPP and Voluntary Protection Program Participants Association are to us."

At the Monsanto facility where Thursby works in Iowa, for example, best practice includes some 20 different safety committees that "own" specific parts of the safety process from confined space and hot work to safety and health promotions and goal setting for the safety department. The challenge is to drive the safety process further and further down into the business.

"I'd say it would be very difficult to run a business and stay competitive if you're not committed to safety and health," says Thursby, who adds, "As an employee, I expect this level of occupational safety and health for me, personally."

The goal at Monsanto, he adds, is to have all of its sites either in VPP or, if the sites are overseas, to have them be what the company calls "Monsanto Star" sites, meaning they have met the same criteria as the OSHA Star sites in the United States.

Layne, who for years served as an administrator in several OSHA offices before becoming executive director of VPPPA, remembers "back in the 1980s when very few companies wanted to sit down with OSHA." The agency, he explains, had to offer the "carrot" of exempting companies from scheduled inspections if they participated in VPP. (Back then, inspections were based on broad industry codes, not dependent, as they are now, on injury and illness rates.)

Davis recalls a time, while he was the regional OSHA administrator in the Atlanta office, when the agency "fought tooth and nail, going to federal court, the works," with International Paper. "Finally, they came to us and said, 'This isn't a good way to do business. We want to make a commitment to VPP.' Now, someone from International Paper sits on the board of directors for VPPPA."

Anecdotal evidence is fine, but statistical evidence for VPP's success is impressive as well. The average VPP worksite has a Days Away Restricted or Transferred (DART) case rate of 52 percent below the average for its industry, according to OSHA.

Kirk Mahan, safety manager, Corporate Safety, at Georgia-Pacific Corp., says his company, which has 68 facilities approved for VPP and was the first company to be approved for the VPP Corporate pilot program (see sidebar), has seen a 15- to 20-percent lower incident rate at VPP sites than at non-VPP sites, with correspondingly lower workers' compensation costs. And many of Georgia-Pacific's sites already had incident rates far below the national average for their industry.

"It's very easy to show the benefits of VPP to management," says Mahan. "Our ultimate goal was a standardized safety management system at all our facilities. The core safety elements were very similar to the elements of VPP, which made our facilities well-positioned to step into VPP."

At Georgia-Pacific, two employees are dedicated to the process of preparing facilities for onsite visits and recertification efforts. Many companies don't have those kinds of resources to dedicate to VPP efforts, but that shouldn't stop them from trying, says Mahan. "VPP can't happen without management commitment and employees buying into it, and that support can happen at any size company."

The push was even harder at SGS: For a team as large as SGS and its prime subcontractors, "the investment was and still is substantial," Storm admits.

At the onset, SGS formed a VPP Committee with representatives from each operating organization, a team of around 35 members. Their major task at the start was to complete the VPP application. Approximately 20 employees were directly involved in the VPP application process some of them almost on a full-time basis for more than a year.

Employees have a Starring Role

When management at SGS launched on the VPP process, some employees and managers needed convincing that it was the way to go. The contractors who formed the joint venture had very good safety and health compliance programs, according to Storm, and employees already were accustomed to strict safety regulations concerning the numerous hazards of the space launch business.

"So," he says, "the challenge was to answer some basic questions to the entire work force: What is VPP? Why is the company doing this? How will it be administered? What's in it for me?"

At SGS, seven unions had to buy into the program. "Our VPP Committee explained the program to each group, and all seven Local presidents signed commitment letters for our VPP application," notes Storm.

He says that the Facilities Directorate, in particular, owes the VPP success "and a big chunk of our Star status" to the leadership and dedication of the two major unions representing the bulk of its 900 employees: the International Association of Machinists And Aerospace Workers (IAM) on Kennedy Space Center, and the Transport Workers Union of America (TWU) on Cape Canaveral Air Force Station. "The absolute essential ingredient in Facilities' success was the grass-roots leadership from a few key on-site union members," Storm says, in particular, Alan Markham, an IAM member who participated in numerous safety training classes and who was an adjunct trainer for IAM with many certifications. "His position was if the company kept their side of the bargain, then the union would make it work. We did and he did," says Storm.

Tales of employees championing the VPP process are common at Star sites. "VPP can't happen without employees buying into it," says Georgia-Pacific's Mahan. "This is a grassroots type of program, and you can't fudge knowledge of the safety process or participation in the safety program. The onsite employee interview process includes open-ended questions and asks employees to explain safety systems. There's no way to fake that or gloss it over. They either know it or they don't and if they don't, then you're not at the VPP level yet."

Mentoring and Beyond

Once a company receives its Star, part of its mandate is to participate, if asked, in a mentoring program, formalized in 1994, that matches a potential VPP site with a current VPP site. The mentor site helps the candidate improve its safety and health management system and assists managers and employees in preparing for participation in VPP.

Georgia-Pacific sites that are part of VPP not only mentor other Georgia-Pacific sites that are starting the process, but sites outside the company as well.

"Mentoring is an important part of the process and we are committed to it," says Mahan. "To be identified as having a world-class safety process, we must be a leader, and being a leader means sharing what we've learned about safety and health processes with other companies."

Participation in mentoring programs is necessary, he adds, as is the recertification process for VPP Star sites. "It reminds facilities that this isn't a race and you didn't just win and you can't quit. The safety culture may fall apart if you don't continue to feed that safety process," asserts Mahan.

As for VPPPA's Layne, he wholeheartedly believes in the mentoring process one of the reasons for the formation of VPPPA and adds that what makes some companies Stars is the concept of no boundaries. "If a worksite needs help, a Star is willing to help them. There are no business boundaries when it comes to occupational safety and health."

Sidebar: VPP: What's Next?

As part of OSHA's ongoing efforts to grow VPP and include smaller companies or companies with one or just a few sites, Paula White, OSHA's director of Cooperative and State Programs, says the VPP program administrators asked themselves: "What can we do to improve? What can we do to make the program more accessible to companies?"

"There are a number of companies out there that are asking themselves, 'How do I get from where I am now to where I want to be in terms of VPP?'" says White.

OSHA came up with three programs designed to increase participation in VPP and improve the process of being part of the program: the VPP Corporate pilot program, VPP Challenge and VPP for Construction (VPPC).

The VPP Corporate pilot program was designed to streamline the VPP application and onsite evaluation processes for corporations that have made a commitment to VPP. The initiative also focuses on eliminating redundancy in the application requirements for sites from the same corporation.

Seven organizations or companies have applied for the VPP Corporate Pilot General Electric, International Paper, Dow Chemical Co., Johnson & Johnson, Maytag, Georgia-Pacific Corp. and the United States Postal Service (USPS) and 25 additional companies have indicated they are interested in the program as well.

Georgia-Pacific Corp. was the first company in the VPP Corporate pilot program.

"Safety leadership and employee-driven safety programs the cornerstone of VPP have been a part of Georgia-Pacific for more than a decade now," noted A.D. "Pete" Correll, Georgia-Pacific's chairman and CEO during a ceremony in 2004 honoring the company's acceptance into the program. "We're proud to have OSHA recognize our dedication to safety by making us the first corporation in their VPP Corporate Pilot. Our goal is to bring our remaining manufacturing facilities under the umbrella of VPP."

Georgia-Pacific was accepted after a comprehensive program evaluation of the company's safety and health management systems at its headquarters in Atlanta. The evaluation included key aspects of Georgia-Pacific's safety and health policies, programs and records, as well as interviews with senior managers and executives. Key to their approval was the strength of their internal prescreening processes to ensure VPP readiness of Georgia-Pacific locations prior to submitting an application and OSHA conducting the onsite evaluation.

In July 2005, OSHA approved the USPS as the first federal organization in the VPP Corporate pilot program.

"The U.S. Postal Service has been a strong partner with OSHA in a variety of cooperative initiatives, and has been an active participant in VPP since 2001," said Acting Assistant Secretary of Labor for OSHA Jonathan Snare during ceremonies at USPS headquarters in Washington. "The continued commitment to the safety and health of the entire USPS work force is truly exemplary and worthy of emulation by other corporate entities. We are proud to recognize that commitment and we applaud your willingness to continue to work with us for even safer and healthier workplaces."

Postmaster General John E. Potter said that the VPP Corporate pilot initiative is a driving force for the continued safety and health of the more than 700,000 career postal employees at more than 37,000 facilities nationwide. Said Potter, "We are committed to working with our partners to achieve safety and health excellence. This initiative is a triple win; our employees benefit, the organization benefits and the country benefits."

USPS now has 17 worksites actively participating in VPP. About 100 USPS worksites are expected to apply for VPP designation in 2005.

The OSHA Challenge Program was launched in May 2004. The program is designed to reach employers in all industry groups who are committed to improving their safety and health management systems and want to pursue recognition for their improvements. Open to private or public-sector employees, Challenge provides a roadmap to improve performance and ultimately to VPP Merit or Star.

The Challenge program outlines the requirements needed to develop and implement effective safety and health management systems through incremental steps. A number of companies and associations have stepped forward as Challenge administrators to work with employers as they move through the steps of the Challenge program. Charter administrators with the program were Associated Builders and Contractors, the Associated General Contractors of America, Black & Veatch, the Construction Safety Council, Curtis Lumber Co., the Independent Electrical Contractors, NEA-The Association of Union Constructors and Voluntary Protection Programs Participants' Association.

VPP for Construction (VPPC) is based on OSHA's VPP experience, in general, as well as successes garnered through the construction-related Mobile Workforce and Short-Term Construction Star Demonstration Programs. The core of the initiative is based on the principle of effective safety and health management systems. It mirrors the general VPP design by continuing to offer participation at either the Star or Merit level, with the possibility of future Demonstration Programs. The new initiative is unique, however, in that it creates two categories of participation: one for long-term, site-based construction projects; and the other for companies, divisions and other business units that employ mobile workforces and work at various sites or projects not always controlled by the participant.

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