Audit, Compliance and Risk Blog

Since 1982, the Occupational Safety and Health Administration (OSHA) has administered “Voluntary Protection Programs” (VPPs) to encourage employers to establish and implement worker Safety and Health Programs that exceed minimal efforts to comply with applicable OSHA standards. OSHA designs VPP eligibility to encourage employer/employee/OSHA cooperation, and to reward such cooperation by granting employers increased flexibility and reduced likelihood of inspection. OSHA presently oversees three programs (which I described in more detail HERE), and is undertaking a “VPP Modernization” initiative to evaluate ways for “modernizing, improving, and expanding” these efforts. On February 16 OSHA posted questions about possible changes, which I discuss in the rest of this note.

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 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.

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