Corporate Commitment, Local Dedication Pave the Way to Success

During the audit, you have to be prepared for everything.

The Occupational Safety & Health Administration, through its Voluntary Protection Programs (VPP), sets high standards for companies. The challenge, and the reward, is to have safe working environments that not only meet government standards, but also exceed them to the point that your company’s safety program can be self-sustaining and become a model for your industry.

At Clean Harbors, we recently received our fourth VPP certification; this one is for our Kimball, Nebraska incineration facility. Along the way, we’ve developed expertise that we are applying inhouse and that could be helpful to other companies in the industry.

VPP Overview
First, it makes sense to recap the VPP. There is plenty of information, including the Policies and Procedures Manual, on the OSHA Web site at dcsp/vpp/index.html. To summarize, VPP is a voluntary, performance-based program that is open to any group covered by OSHA. It includes a rigorous review process of a company’s health and safety management systems.

VPP has three levels:

• Star: Companies that have “exemplary worksites” with injury and illness rates below the national average. Incident rates at Star sites are reviewed every year, and the sites must be reevaluated (recertified) every three to five years.

• Merit: Merit sites have good safety records and have demonstrated the commitment and the potential to achieve Star status. Locations can carry the Merit rank for only one three-year period. At the end of that time, they must either advance to Star or lose their Merit designation.

• Star Demonstration: This level is for sites that are exploring alternative Star certifications for special situations. Successful programs can become Star certified. Star Demonstration sites are re-evaluated every 12 to 18 months. VPP evaluates four program elements: Management commitment and employee involvement, including temporary workers and contractors: This requires documenting management systems and an annual review, as well as setting goals to address gaps.

Work site analysis: This requires that systems are implemented to identify hazards. Tools include safety and industrial hygiene surveys, inspections, incident investigations, etc.

Hazard prevention and control: This is the program element that addresses safety issues. Engineering workplace practices, personal protective equipment, confined space programs, and other standard safety programs are the components that support this effort.

Safety and health training: This requires well-documented and well-designed safety and health training programs that communicate a safety culture and teach detailed safety procedures.

At about this point, you’re probably saying to yourself, “We do most of that stuff anyway just to keep in compliance.” You’re right. VPP takes you to the next level; it is a commitment to continuous improvement for companies that want to exceed OSHA minimum requirements.

Mentoring is Part of the Process
Both OSHA and the Voluntary Protection Programs Participants’ Association provide resources to help with the certification process. VPPPA is an independent association for representatives from VPP-certified facilities and non-VPP sites who come together to network and share information. In addition to local chapter meetings, the organization also hosts an annual conference. The 2008 meeting will be Aug. 25-28 in Anaheim, Calif.

VPPPA provides a roster of the companies that have been through the process and lists individuals in those companies who volunteer as mentors. Company mentors can share their war stories and give mentor program at Clean Harbors, and some of our staffers now volunteer to help other companies.

Some of the OSHA regions also provide mentoring services before the on-site audit. Often, the mentors (and auditors) are Special Government Employees (SGEs) from approved Star or Merit sites who have passed background checks and training. Clean Harbors also has employees who offer their services as SGEs.

Setting a Corporate VPP Strategy at Clean Harbors
At Clean Harbors, we realized that we could execute the program at many, if not all, of our fixed facilities to bring them to a higher level. We’re proud that we are the first company in our NAICS (North American Industry Classification System) code (562211—Hazardous Waste Treatment and Disposal) to achieve VPP status. The decision to pursue VPP certification was made at the corporate level, but we understood from the outset that success depends on direct employee involvement.

Initially, we planned to work with just one or two sites; we soon changed our minds and decided to start the process at several facilities because we saw that the process itself would deliver operational and safety benefits. We ended up with a list that included two sets of facilities. The first set already had outstanding health and safety programs that we thought would qualify relatively easily. The second set met OSHA regulations, but we expected they would require some work to achieve the more stringent VPP status.

There was no size requirement. Both our largest incineration facility, Deer Park in La Porte, Texas, with 350 employees, and a smaller landfill, Lone Mountain in Waynoka, Okla., with a staff of 50, began the process. Regardless of the facility’s size, we sought general managers who were interested in doing a VPP project at their site. It’s no surprise that general managers who actively embrace the program from the start are the most successful.

Making VPP Happen at the Local Level
VPP elements are well defined by OSHA. However, the way those requirements are implemented at each company and facility is a little different based on the line of business and the personalities involved. Understanding this, we created our own Clean Harbors VPP project planning tool for local management and for the local VPP committees. It complements other available resources and includes all of the required forms and documents, including a GAP analysis tool—it’s a roadmap that enables them to put a frame around their own particular circumstances.

Although VPP is essentially a local process, we monitor progress at the corporate level, report VPP program status to top management, and encourage participation in the program by our general managers and staff.

The key to VPP success is local employee involvement. The general manager establishes a VPP committee made up of employees representing the major departments at the facility. It focuses only on certification and is separate from the standing safety committee. This is the most effective approach, because we found that when employees take on the mission, they eagerly participate and get excited about the whole VPP process.

The committee’s first step is to conduct a GAP analysis (equivalent to OSHA’s annual evaluation) to identify weaknesses in the management system. Next, they develop action plans to address the gaps. Then management and staff concentrate on improvements, tracking progress, and documenting results in accordance with VPP guidelines.

Once the VPP committee determines the site is ready (typically, six months to a few years after the initial GAP analysis), the application is submitted and an onsite evaluation is scheduled. The OSHA audit team always has a team leader, a safety specialist, and an industrial hygienist, and often it includes a Process Safety Management (PSM) specialist and perhaps an electrical engineer or other specialist, depending on the facility’s function. The team will likely include both OSHA staff and SGEs.

Beyond the actual audit team, it pays to get to know how your OSHA region approaches VPP. We’ve found that even though VPP has a formal checklist, the evaluation is dependent on both the expertise of the representatives who audit the facility and on how your particular regional office handles the VPP program.

The team conducts a physical inspection to make sure management systems are in place. Every audit is different, depending on the region, your line of business, and the team personnel—the industrial hygienist concentrates on his or her area of expertise, while an electrical engineer focuses on other issues. You have to be prepared for everything.

The audit team also requires a full employee roster, including temps and contractors, and always conducts confidential interviews to determine management and staff commitment, to see whether the VPP management systems are in place, and to gauge employee participation and attitude. All employees may be interviewed in small facilities; a sample will be taken in larger facilities.

There are three possible outcomes of the audit. The team may tell you that you qualify for Star or Merit, or they can say you’re not ready. If you do qualify, they may give you a 90-day checklist of final issues to be addressed. Depending on your region, they may come back for another inspection or require written proof of compliance.

Once the audit is completed, the report is sent to the regional office for review/ approval and then goes on to Washington, D.C. OSHA issues the certification letter 30-60 days later. Typically, the whole process, from establishing the VPP committee and conducting the GAP analysis to the audit and the certification, takes one and a half to three years.

Keeping to the Standard
VPP status enables recipients to self-monitor many of their safety systems. They still have to report, and they have to be recertified every three to five years. At Clean Harbors, we keep VPP committees active after certification. They monitor progress through monthly meetings and make recommendations to management. Members of the standing VPP committee are appointed annually.

This article originally appeared in the May 2008 issue of Occupational Health & Safety.

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