716 Safety Management System Evaluation

Site-based participation continues VPP's traditional acceptance of applications from fixed worksites and some long-term construction sites. OSHA welcomes site-based VPP participation and accepts VPP applications from the owners and site officials who control site operations and have ultimate responsibility for assuring safe and healthful working conditions of:

• Private-sector fixed worksites in general industry and the maritime industry
• Construction worksites/projects that will have been in operation for at least 12 months at projected time of approval and that expect to continue in operation for at least an additional 12 months
• Federal-sector fixed worksites
• Resident contractors at participating VPP sites for the contractors' operations at those VPP sites
• Resident contractors at non-participating sites for the contractors' operations at those sites, so long as the resident contractors are part of a larger organization approved to participate under the corporate option

Based on positive experiences with past VPP Mobile Workforce Demonstrations and other VPP Demonstrations, OSHA introduced a VPP program designed for mobile workforces. OSHA believes this new way to participate will work for companies that typically function as contractors or subcontractors who may or may not have the authority for safety and health for an entire worksite and for those companies that have employees that move site-to-site such as a specialty trade contractor or repair and maintenance company regardless of size or length and duration of the project or service.

Following OSHA's review and acceptance of the application, a two-phased on-site evaluation takes place. In the first phase, OSHA's onsite evaluation team will review the applicant's corporate, division or business unit policies and procedures which include a review of safety and health management programs, document review and assessment of the management commitment to safety and health, and to VPP. The second phase is dedicated to review one or more worksites to verify the safety and health management programs are actually working outside the home office where employees may work unsupervised at sites that are not owned or controlled by the applicant.

VPP corporate is designed for corporate applicants, who demonstrate a strong commitment to employee safety and health and VPP. These applicants, typically large corporations or Federal Agencies, have adopted VPP on a large scale for protecting the safety and health of its employees. VPP corporate applicants must have established, standardized corporate-level safety and health management systems, effectively implemented organization-wide as well as internal audit/screening processes that evaluate their facilities for safety and health performance. Under VPP corporate, streamlined processes have been established to eliminate these redundancies and expand VPP participation for corporate applicants in a more efficient manner.

The VPP SMS consists of four critical interrelated elements. Effective implementation requires that they function together in one comprehensive and systematic effort.

1. Management Leadership and Employee Involvement. In a VPP-quality organization, management regards worker safety and health as a fundamental value and applies its leadership to safety and health protection with as much commitment, planning, and visibility as it does to other organizational purposes. In organizations with the most effective system, employees are actively and meaningfully involved in the planning and operation of the safety and health management systems and in decisions affecting their own safety and health.
2. Worksite Analysis. The successful management of workplace hazards begins with a thorough understanding of all hazardous situations to which employees may be exposed and the implementation of a meaningful system to recognize hazards as they arise.
3. Hazard Prevention and Control. Workplace hazards identified during the hazard analysis process must be eliminated or controlled by developing and implementing specified systems and by using the specified hierarchy of controls.
4. Safety and Health Training. Training is necessary to reinforce and complement management's commitment to prevent exposure to hazards. All employees must understand the hazards to which they may be exposed and how to prevent exposure to themselves and others from such hazards. Effective training enables employees to accept and follow established safety and health procedures, as well as to understand they are protected from retaliation for reporting hazards.