"There have been numerous calls and comments concerning the Stakeholders meetings OSHA conducted regarding VPP. The future for VPP is very bright and we are on the verge of another great growth period for the program, both on the federal level and the state plan level. Federal OSHA is back as a full partner with VPPPA and has committed to getting the backlog of old applications caught up. In their strategic plan, it also includes having an additional 100 new sites each year.
The two stakeholders meetings conducted in Washington, D.C., and at the Safety+ Symposium in New Orleans, were very beneficial and OSHA listened to everyone present. In addition, OSHA opened an official docket for comments. OSHA identified common themes from the comments and determined the most prominent categories:
Simplification of the VPP Process and Documentation
Promotion of VPP and Increased Recognition of Participants
Data Collection/Effectiveness of VPP and Best Practice Sharing
Increased Training and More Formalized Mentoring
Increase in OSHA Commitment, Resources and Funding
Changes to Increase Incentives and Benefits of Participation
Changes to the Corporate Program
Special Government Employee (SGE) Specific Recommendations
Use of Third Party Provider for Audits
Comments on VPP Memos (Specifically #7)
We, VPPPA, worked with the national OSHA office to revise Memo 5, regarding incentive programs and it is now back similar to the policy before Memo 5 was issued. Basically it now again allows injury/illnesses to be part of a company's incentive program. The onsite audit team will review a site's program to determine if the team thinks the program could lead to under reporting of injuries. Additionally, we have provided input on revising Memo 7 regarding fatalities at VPP sites. When the new Memo is officially issued we think the changes will make it more workable for everyone."
Sincerely,
Mike Guillory, Chairperson
VPPPA National Board of Directors
