February 2, 2011

This memorandum, which supplements the August 3, 2009 memorandum, "Improving the Administration of the Voluntary Protection Programs (VPP)," and subsequent VPP policy memorandums, clarifies actions for OSHA Regions to implement in the Occupational Safety and Health Administration's (OSHA) continuing efforts to improve its administration of the VPP. The following instructions clarify policy and procedures for the annual data submission required of all VPP participants and OSHA's review of the submissions. Unless otherwise noted, these instructions are effective immediately.

OSHA Instruction CSP 03-01-003 VPP Policies and Procedures Manual Appendix C provides a format which describes the required data VPP participants are expected to submit to OSHA on an annual basis. It was discovered, through inconsistent data submissions, that Appendix C did not clearly describe the data OSHA was requiring from VPP participants. This memorandum provides clarification of data that is to be submitted by VPP participants on an annual basis.

Procedures for Submission of CY 2010 Injury and Illness Data:

OSHA has developed the document found in Attachment A: "Format for Annual VPP Participant Submissions." This document, which will be posted on OSHA's VPP webpage, will replace Appendix C of OSHA Instruction CSP-03-01-003, VPP Policies and Procedures Manual dated April 18, 2008. The revised format reflects the new ways to participate established by the January 9, 2009 Federal Register Notice, 74 FR 927 and clarification for annual data submissions. You will find changes in the introduction and Sections A and B only.

OSHA expects all participants to adhere to the revised requirements for participant injury and illness data submission beginning with the data from CY 2010. The new format clearly delineates the data submission requirements for site-based non-construction participants, site-based construction participants, and mobile workforce participants. Each Regional VPP Manager will provide Attachment A by email to the Region's VPP participants under federal jurisdiction to ensure a timely submission for their annual self evaluations. Subsequently, in reviewing participants' annual submissions for CY 2010 and subsequent years, each Regional VPP Manager must consider these revised data submission requirements.

For participants' CY 2010 data and annual self-evaluation only, the deadline for submission to OSHA is extended from February 15, 2011 to March 15, 2011.

Attachment