VPP for Construction (VPPC) joins VPP Corporate Pilot and OSHA Challenge Pilot (both launched last May) as the newest cooperative program tto recognize and promote effective health and safety management systems. The agency is seeking public comment on the VPPC proposal, which was published in the Aug. 31 Federal Register.
"The construction industry has not been able to take advantage of the benefits of VPP participation, mainly due to eligibility requirements since VPP was originally designed for fixed workplaces," Henshaw told the participants. "We've learned a great deal from our ongoing relationships with the construction industry, labor and VPPPA, and OSHA has crafted a program we believe will maintain VPP's high performance standards while, at the same time, respond to the industry's unique needs. We believe our proposal has the potential to significantly contribute to reductions in injuries, illnesses and fatalities in one of the nation's most hazardous industries."
Under the current VPP structure, the focus in construction has been long-term projects. OSHA has been testing ways to open VPP to other kinds of construction projects via Short-Term and Mobile Workforce Star Demonstration programs.
Henshaw said the agency has had numerous meetings with stakeholders including the VPPPA, their companies in the demonstration program, major industry associations and the building trades and has worked closely with OSHA regional administrators, to get a broad range of perspectives.
Henshaw said that under VPPC, Safety and Health Management System requirements remain the core, and Star, Merit and Star Demonstration designations will continue to be available. Site-based options are still available for long-term projects, those lasting 2 or more years.
A new option for individual corporations, divisions or business units (C/D/BU) will include:
- Applications that cover the work an applicant is "contractually responsible for," instead of a specific site the applicant controls.
- C/D/BU's will apply for approval within a defined geographic area. The current proposal is for an area no broader than state-wide, with the option to expand after initial approval if OSHA's regional administrator and the participant agree that this is appropriate.
- OSHA will conduct a corporate onsite evaluation, including review of C/D/BU-wide safety and health management policies and procedures, and corporate safety and health oversight strategies. Then, the agency will conduct onsite evaluations for a representative sample of work. The number of on-site evaluations will depend on the number of sites/projects operating within the defined area.
- If during these on-site visits, the walk-through and employee interviews indicate that the safety and health systems are working well, OSHA will do an abbreviated review.
- Quarterly updates to OSHA in addition to the requirement for annual reports.
"VPP for Construction is a shift away from an exclusively site-based focus," said Henshaw. "It will open VPP to a broad range of previously ineligible employers subcontractors, general contractors with short-term projects, mobile workforce employers, specialty trade contractors and construction managers."
