Audit, Compliance and Risk Blog

OSHA Voluntary Protection programs

Posted by Jon Elliott on Mon, Jan 31, 2022


 The US federal Occupational Safety and Health Administration (OSHA) administers “Voluntary Protection Programs” (VPPs) to encourage employers to establish and implement voluntary worker Safety and Health Programs that exceed minimal efforts to comply with applicable OSHA standards.  As its name states, participation in any VPP is voluntary.  They are designed to encourage employer/employee/OSHA cooperation, and to reward such cooperation by granting employers increased flexibility and reduced likelihood of inspection. VPP sets performance-based criteria for a managed safety and health system, invites sites (and discrete mobile workforces) to apply, and then assesses applicants against these criteria. OSHA provides for full participation (the “Star” program) for sites/workforces that meet all criteria, conditional participation where an employer claims to meet some VPP criteria by non-standard methods (the “Demonstration” program), and qualified participation where the employer fully meets some VPP criteria and has definite plans to meet others (the “Merit” program).

The remainder of this note summarizes VPP criteria and provides additional information about the status of the programs.

What are OSHA’s VPP criteria?

To fully qualify for (Star program) participation in VPP, a site or mobile workforce must demonstrate the following criteria are met:

  • Injury and illness (I&I) rates lower than the national average for the employer’s industry(ies), demonstrated by at least 3 years of data

  • a safety and health program that includes all the following elements:

 - Management leadership and employee involvement

    • commitment to safety and health protection

    • commitment to VPP participation

    • planning—integration of safety and health protection into overall worksite planning and management

    • written Safety and Health Program

    • management leadership

    • employee involvement (including at least three separate employee-involvement mechanisms, such as participation in job hazard analyses, safety audits, and accident investigations)

    • coverage of all contract workers (this includes requirements that the host require contractors to comply with the host’s safety and health programs, encourage contractors to develop and implement their own programs, and provide documented oversight of contractor activities)

    • Safety and Health Program self-evaluation (at least annual)

 - Worksite analysis

    • procedures to ensure analysis of all newly acquired or altered facilities, processes, materials, equipment, and/or phases before use begins, to identify hazards and the means for their prevention or control

    • comprehensive safety and health surveys, at appropriate intervals

    • routine examination and analysis of safety and health hazards associated with individual jobs, processes, or phases and inclusion of the results in training and hazard control programs

    • system for conducting routine self-inspections at least monthly (and covering all operations at least quarterly), which follows written procedures or guidance and that results in written reports of findings and tracking of hazard elimination or control to completion

    • reliable system for employees, without fear of reprisal, to notify appropriate management personnel in writing about conditions that appear hazardous and to receive timely and appropriate responses

    • accident/incident investigation system, which includes near-misses

    • system to analyze trends through a review of injury/illness experience and hazards identified

 - Hazard prevention and controls

    • site hazards identified during the hazard analysis process must be eliminated or controlled by developing and implementing systems, using the following hierarchy:

 - engineering controls (preferred)

 - administrative controls

 - work practice controls

 - personal protective equipment (PPE)

    • occupational health care program using health care professionals

    • written emergency preparedness and response procedures must be prepared for all types of emergencies on all shifts, must comply with OSHA standards, and must be exercised at least annually 

 - Safety and health training

    • training appropriate to hazards, and tailored to managers, supervisors, and non-supervisory employees (including contractors)

Now what?

VPP is large and continues to grow – in 2020 OSHA collected and compiled data from 1,212 Federal jurisdiction site-based non-construction VPP participants representing more than 345,000 employees. Many of the states authorized to administer OSHA requirements (“state plan states”) also oversee comparable voluntary programs. A Voluntary Protection Programs Participants’ Association (VPPPA) solicits memberships and provides participants with informational resources and networking opportunities.

Self-Assessment Checklist

Do any of the organization's locations participate in one of OSHA’s VPP programs?

  • Star program (fully qualified)

  • Demonstration program (conditionally qualified)

  • Merit program (participating while completion qualifications)

Where Can I Go For More Information?

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About the Author

Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years. 

Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).

Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).

You may contact Mr. Elliott directly at:

Tags: Health & Safety, OSHA, Safety and Health at Work, workplace safety, VPP