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Subject Area Regional Offices National Office
  1. Consistency in VPP Administration
  • Adhere to VPP Policies and Procedures Manual and the VPP FRN including application format, onsite evaluations, VPP report writing, and other VPP activities. Current modifications to these procedures are being reviewed.
  • The revised VPP onsite evaluation worksheets, once approved, must be used for all VPP onsite evaluations.
  • Follow policies and procedures outlined in the VPP Policies and Procedures Manual, CSP 03-01-003, April 18, 2008 and the VPP Federal Register Notice, 74 FR 927, January 9, 2009.
  1. Restricted communication with VPP applicant/participant about OSHA VPP recommendations
  • Regional Administrator approval is required prior to discussing recommendations for VPP participation with the VPP applicant/participant.
  • Regional Administrator approval is required prior to sharing a copy of the draft VPP onsite report with the VPP applicant/participant.
  • Regional VPP Manager must ensure that Regional Administrator is briefed on any 90-day items.
  • Ensure that all 90-day items are completed before Regional Administrator makes participation decision/recommendation.
  
  1. Respond to and document actions taken following a fatality/significant event at a VPP site
  • Following a fatality/significant event, maintain full documentation in the participant file; include documentation of the event, a summary of enforcement actions with final disposition or contested status, a complete record of VPP actions taken, and a chronology of VPP actions taken.
  • Keep Directorate of Cooperative and State Programs, Office of Partnerships and Recognition (DCSP-OPR) informed of all fatalities/significant events and follow-up actions via email to Director DCSP with a cc to Director OPR and OPR Regional Liaison.
  • Regional Administrator to make and document decision for continued VPP participation, request for VPP withdrawal, or termination recommendation. If termination, follow appropriate termination procedures. Document VPP decision and rationale, and maintain in participant file and in Area Office enforcement file.
  • Track fatalities/significant events by updating the VPP Fatality/Significant Event Tracking Log to include actions taken by the Regions and final VPP disposition.
  • Annually, conduct a review of a sample of Regional VPP files and provide feedback to Regions, as appropriate.
  1. Required actions when a VPP participant’s 3-year TCIR and/or DART rate exceeds VPP requirements
  • Determine, during onsite reevaluation or review of participant’s annual self-evaluation, whether a 2-year rate reduction plan and/or 1-year conditional status is warranted; document the final disposition of the actions taken; document rationale if action not taken.
  • Notify DCSP-OPR of actions taken: VPP participant put on a 2-year rate reduction plan and/or a 1-year conditional status, or no action, via email to the Director DCSP-OPR with a cc to the OPR Regional VPP Liaison.
  • Notify DCSP-OPR of the final disposition of any 2-year rate reduction plans and 1-year conditionals.
  • Maintain complete records including the plan/status, periodic updates and final disposition in the participant file.
  • Update the VPP Annual Summary Log to track incidences of 3-year rates exceeding VPP requirements and actions taken by Regions, e.g., 2-year rate reduction plans, 1-year conditional status, or other.
  • Work with the Directorate of Information Technology (DIT) to modify VPP Automated Data System (VADS) to record when a VPP participant is put on a 2-year rate reduction plan and/or a 1-year conditional status and the final disposition. Also DIT to produce a new tracking report.
  • Annually, conduct a review of a sample of Regional VPP files and provide feedback to Regions, as appropriate.
  1. Procedures when a VPP participant’s SHMS no longer meets VPP requirements
  • Follow procedures in the VPP Policies and Procedures Manual to track completion of 90-day items and 1-year conditional status.
  • Maintain complete records in the VPP participant file with relevant information and documentation.
  • Inform DCSP-OPR via email to the Director DCSP-OPR with cc to OPR Regional Liaison when a VPP participant is placed on a 1-year conditional status and the final disposition.
  • Work with the DIT to modify VADS to record when a VPP participant is put on a 1-year conditional status.
  • Annually, conduct a review of a sample of Regional VPP files and provide feedback to Regions, as appropriate.
  1. Review and verification of annual VPP participant self-evaluations, including verification of injury and illness data
  • Review self-evaluations for continued compliance with VPP requirements.
  • Review the injury and illness rates during onsite evaluations and compare to any rates submitted by the VPP participant on the annual self-evaluation.
  • Report any changes to DCSP-OPR via email to the Director DCSP-OPR with a cc to the OPR VPP data coordinator.
  • Modify VPP worksheets to document team’s comparison of participant injury and injury rates reviewed during the onsite evaluation and the rates reported on the participant’s annual self-evaluation.
  • Work with DIT to modify VADS to capture participant’s injury and illness rates and to create a report to identify sites that exceed rate requirements.
  • Conduct a review of sample self-evaluations from each Region and provide feedback, as appropriate.
  1. Medical Access Orders (MAO)
  • Request MAO from Directorate of Technical Support and Emergency Management (DTSEM) at least three weeks prior to the scheduled VPP onsite evaluation date.
  • Maintain a copy of the MAO in the participant file.
  • Indicate on the updated VPP Team Composition Sheet the status of the MAO.
  • Establish a Regional MAO tracking system to help ensure all MAOs are requested and received prior to the conduct of the VPP onsite evaluation.
  • Revise the VPP documentation to include information regarding the MAO request and disposition.
  • Work with the DTSEM to revise MAO procedures and tracking mechanisms.
  • DTSEM to generate a quarterly report for the Deputy Assistant Secretary with cc to Director DCSP tracking VPP Regional MAO activities. Quarterly reports due: January 15, April 15, July 15, and October 15.
  1. Timeliness of Onsite VPP Evaluations
  • Submit monthly the VPP Activity Report Form (VPP Log) to provide status of VPP applications in the Region.
  • Run reports from VADS or other tracking database system.
  • Notify DCSP-OPR of decisions to postpone onsite evaluations via an email to the Director DCSP with a cc to the Director DCSP-OPR and the OPR Regional VPP Liaison.
  • Maintain in the participant file a complete record of delayed onsite evaluations.
  • DCSP to work with DIT to revise VADS reports to record and track application acceptance, onsite evaluation date, and delays in onsite evaluations.
  • OPR Regional VPP Liaisons to run VADS report on a quarterly basis to track the timely conduct of onsite evaluations not flagged as delayed.
  • OPR Regional VPP Liaisons to report overdue onsite evaluations to Director OPR, who will inform Director DCSP.
  • Director DCSP to notify the Regions of overdue onsite evaluations not flagged as delayed.
  1. Regional VPP Audits
  • Update the Regional audit process and documentation (in coordination with the Directorate of Evaluation and Analysis) to monitor the policies and procedures described in #1-8 above.
  • Coordinate with Directorate of Evaluation and Analysis to update the National Audit Template as needed.
  1. Updated worksheets to document VPP onsite evaluations
  • Once final and approved, use updated worksheets during all onsite evaluations.
  • Complete worksheet revisions. When finalized, make available on O: drive.
  1. VPP File Retention Plan
  
  • Revise the VPP File Retention Plan to include new documentation requirements.
  1. OIS
  
  • Coordinate with OSHA Information Systems (OIS) team on all changes to VPP data applications.