Playing on OSHA's Team

Establishing a Voluntary Protection Program is worth the effort. Once implemented, it becomes integral to the company's way of doing business.

• By Mike Avery
• May 01, 2003

FOR most companies, including the majority of manufacturing firms, worker safety is a genuine priority. But when OSHA comes for a visit, safety personnel and management can feel their throats tightening and their heads pounding. OSHA and the companies it monitors have a long and difficult history of struggling not to behave as adversaries, albeit adversaries who, in the end, share a number of the same goals for workers.

The Voluntary Protection Programs were initiated by OSHA in recognition of the fact that, as stated on the OSHA VPP Web site, "compliance enforcement alone can never fully achieve the objectives of the Occupational Safety and Health Act." These programs allow committed, qualified companies to become partners with OSHA in promoting effective safety and health management. The approximately 615 companies that have implemented federal VPPs to date enjoy a number of both measurable and less tangible benefits.

But what is involved in establishing a VPP? And, from a company's perspective, is it worth the effort?

American Saw has been a VPP site since 1997. We have thus had the opportunity to go through not only the application and establishment phase of VPP, but also the current situation in which we maintain and continually improve the internal programs, processes, and culture required to make it work. As a leading manufacturer of band saw blades, sawing fluids, hand tools, and power tool accessories, we, like most manufacturing companies, have experienced our share of safety issues, accidents, and worker's compensation claims. But, as a company, we have always been committed to safety and that commitment led us to explore the possibility of taking our involvement to a higher level with VPP.

Is VPP Really Different?
Most companies that hear about the Voluntary Protection Program and the partnership it provides with OSHA are, at first, either skeptical about its value or reluctant to embroil themselves, as they fear, in additional red tape and perusal. Business people ask if VPP is just another program that will require a lot of paperwork without changing the day-to-day safety standards and activities behind it.

In fact, VPP provides value that radiates well beyond the obvious benefits of reducing accidents, lost work days, and worker's compensation claims. VPP is a whole approach to safety and health that touches on every aspect of daily operations. Once implemented, it becomes integral to the company's way of doing business.

VPP provides not only quantifiable safety and health benefits, but also enhances the production environment, worker morale, community reputation, and even the bottom line. For a safety manager, it can also help transform a relationship from one in which OSHA is seen as a dreaded policing agent to one in which the company becomes a respected and responsible partner to OSHA in creating a safe and productive environment. Participants are not subject to routine OSHA inspections, because OSHA's VPP on-site reviews ensure the health and safety programs put in place by the company are providing superior protection. In fact, OSHA statistics indicate that VPP participant sites generally experience 60 to 80 percent fewer work days lost to injuries than would be expected of an "average" non-VPP site in their industries.

Does Our Company Want VPP?
While VPP can be a great boon for a company, it does require a top-to-bottom commitment. Everyone--from the president to the person hired just today to work on the manufacturing floor--has to buy into the demonstrated dedication to proactive safety management.

Safety isn't always convenient. The foreman who has to meet a goal certainly may be unhappy if one of his machines has to be locked out for safety reasons, but sometimes that needs to happen. That's why it is important to get everyone on board--and to keep everyone on board--regarding the long-term importance of safety.

For management, commitment is often an issue of time and money. At American Saw, our new employees are pleased and amazed that the company cares enough to make safety the "first stop." Thanks to management commitment to VPP and to workers' safety, every new person learns about safety issues, which, depending on the job the person has, may range from hearing and eye protection to lockout and tagout training. For some jobs, the orientation period, including hands-on training for the use of specific floor equipment, can take up to six months.

Employment positions have an associated "job hazard analysis" to determine which dangers are associated with which jobs, so that appropriate orientation and refresher training can be provided. Seasoned employees participate in regular refreshers throughout the year, on issues ranging from respirator use to machine set-up processes. All of this requires substantial commitment from the top and buy-in from everyone.

Also, when considering whether your company wants to apply to become a VPP participant, it is important to assess how strong your safety program is now. VPP is admittedly an elite program. In order to qualify for VPP, management must agree to operate an effective program that meets an established set of criteria, and employees must agree to participate in the program and work with management to assure that the workplace is safe and healthful. If your program is poor now, it is wise first to bring it up to standards that you feel would pass OSHA muster before actually presenting a VPP application to the agency.

A company's size generally should not affect whether it should participate in VPP. Even some very small companies participate in VPP. Any company in which OSHA inspections are currently required may want to look into the program.

The application process and the on-site review have a well-deserved reputation for being rigorous. The application will require a great deal of information on demonstrated management commitment, accountability, resources and planning, a comprehensive work site analysis, information on hazard prevention and control, statements of commitment from management and the unions, if any, and much more. For American Saw, the on-site review was a five-day event, involving five representatives from OSHA who worked to ensure the activities described in the application were actually being conducted. Going through the application and on-site review process is extremely useful as a tool for self-assessment and improvement.

For us, preparing the application involved getting the company ready for VPP. The process took us two years of sweeping efforts, with one of the results being a comprehensive program resource binder that remains a valuable guide today.

A Safety Director's Perspective
At American Saw, VPP is a tremendous reputation builder and provides an ongoing support for good employee morale. Accident rates have fallen by 50 percent since we began, and worker's compensation costs are approximately one-seventh of what they were.

Employees feel a sense of empowerment because many of the processes and programs that are integral to VPP put them in an excellent position both to understand the workings of the company and to exercise their individual interests in their own and their co-workers' safety and health. For example, VPP requires that the company conduct at least three meaningful, ongoing programs to get employees actively involved in maintaining safety and health. At our company, these programs include a safety committee, department safety meetings, and safety inspections conducted monthly by members of the committee. The inspections are a valuable tool in getting everyone on the same page in terms of the importance of proactively working for safety. We also provide a suggestion box that can be used anonymously if desired.

Employee buy-in is key to the success of VPP. At the same time, in the real world, the program has to have teeth. It is important that the company enforce its safety expectations in instances in which employees fail to, or even refuse to, perform to standards. American Saw has a process that includes verbal warnings, written warnings, time off, and even discharge. These disciplinary actions are used in succession or as needed when employees do not comply with health and safety requirements. Without these provisions, all the admonitions in the world will not work with everyone.

As a safety director, it is important to know, too, that changing a culture--including a safety and health culture--takes time, which many experts estimate may be in the range of five to seven years. But the process can be well worth the effort, and of course, the work is never done.

It is my job to give safety equal billing to production. Strange as it may sound, this is a smart practice for a manufacturing company like ours, even from the profit perspective. When safety management is poor, worker's compensation can be very expensive, so the proactive approach becomes the best choice.

The day-to-day management of a VPP program means the safety director is very active in decisions ranging from machinery purchases to employee production scheduling. It means the safety director is part of the team, out on the floor, involved in daily activity, not sitting in his or her own office waiting for the phone to ring or a problem to arise. It's a great way to have impact in a company you believe in, and it is an unbeatable way to help others--workers, management, customers, vendors and the community--to believe in your company, too.

This article originally appeared in the May 2003 issue of Occupational Health & Safety.