VPP Mobile Workforce Demonstration for Construction

VPP Mobile Workforce Demonstration for Construction

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Highlights

• Eligibility• Application Process• Approval Process• Continuing Participation Requirements

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Eligibility

Eligibility Determination and Application GuidanceVPP Manager or Coordinator

Contact InitiatedDemonstration Candidate

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Who is Eligible?

• Construction industry SIC/NAICS• 3 years operating in construction industry• GCs and Specialty Trade Contractors at the

Corporate, Division, or Business Unit level• Long-term and short-term projects• May or may not have authority and responsibility

for safety and health over the entire site• Inspection History

– No open citations

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Application Process


Application ReviewVPP Manager or Coordinator

Application SubmittalDemonstration Candidate


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Unique Application Features

• Designated Geographic Area (DGA)• Union Support• Participation Plan• Applicant’s Prescreening/Oversight Processes• Injury and illness data

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Designated Geographic Area (DGA)

• No smaller than an Area Office– May cover multiple AOs within a single Region– AOs do not have to be within the same state

• No larger than a Region– May cover multiple states within a Region– Applicants who want to participate in multiple Regions

should contact the NO

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Union Support

OSHA expects each applicant to determine whether the requirement for union support applies. Calculate the percentage of your employees (including temporary employees) and subcontractor employees who are represented by unions at the time of your application. Then use the chart below.

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Applicant Participation Plan

• Designed to address elements of VPP that are different from those published in the current VPP FRNs, such as:– DGA– Annual Emergency Evacuation Drills– Baseline hazards analysis– Employee Involvement

• Alternative program elements must provide protection equal to that of traditional VPP

• Emphasis on good practices

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Applicant’s Prescreening/Oversight Processes

• Applicant must perform onsite prescreening/oversight processes for all worksites within DGA– Assure VPP-quality safety and health protection at all active

worksites within the DGA – Demonstrates direct corporate oversight and involvement in S&H

at worksites

• OSHA will verify effectiveness of and compliance with an applicant’s processes– Review documentation during the corporate onsite evaluation– Verify effectiveness during worksite evaluation(s)

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Calculating Injury & Illness Data

• Injury and Illness Rate Requirements– 3-year TCIR and DART rate reflecting experience of

the participant’s workforce throughout the DGA

• Required at Application – Company-only data for the first two years – Combined injury and illness data, including all

subcontractors, for the most recent calendar year

• Subsequent reporting must continue to build upon the combined rate data

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First Year Combined Injury and Illness Data (Sample)

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Application Format

• Largely follows the current VPP application format– Emphasize subcontractors, where applicable– Injury and Illness data– Prescreening

• Supplemental application instructions cover differences

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Participation Decisions



Participation DecisionsVPP Manager/RA (in conjunction with Candidate)



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• Determine applicant’s eligibility• Review application, including:

– Applicant’s Participation Plan– Union Support– Prescreening Process– Injury and Illness Data– Active/anticipated worksite list

• OSHA, after consulting with the applicant, will determine the DGA

Participation Decisions

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Two Phase Onsite Evaluation

Corporate Onsite EvaluationOSHA Evaluation Team

Worksite Evaluation(s)OSHA Evaluation Team



Participation DecisionsVPP Manager/RA (in conjunction with Candidate)



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Two-Phased Onsite Evaluation

• Corporate Onsite Evaluation

• Worksite Evaluation(s)

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Phase 1 - Corporate Onsite Evaluation

• The focus is to verify that the applicant has all of the policies, procedures, and programs (e.g. confined space) in place to effect VPP Star quality safety and health at all locations within the DGA

• Verify all information described in the application

and participation plan– Length of onsite evaluations may vary

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Corporate Onsite Evaluation Elements

• Evaluation elements will include:– Assessment of management leadership– Assessment of employee involvement– Review of corporate SHMS– Review of prescreening/oversight processes– Measure safety and health performance– Review Recordkeeping– Annual Evaluations

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How Many Worksites Do We Evaluate?

• The Regional Administrator has the discretion to select the number of onsite evaluations based on the following criteria:– The number needed to cover all the types of work performed– The phases of construction and the nature of the hazards– The geographic scope of the application– Other factors which OSHA determines may affect its ability to fully

and accurately assess the effectiveness of the SHMS

• Normally will not exceed the number of programmed inspections the Regional Administrator would otherwise expect an applicant to receive– F.W. Dodge Reports serve as basis, where applicable

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Phase 2 - Worksite Evaluation(s)

• Number and Location determined by OSHA• Evaluated using a similar process to a VPP

Corporate Facility– Verify that the corporate SHMS is in place and

effective– Interview employees and management– Review any site-specific elements– Verify compliance with OSHA regulations

• Non-controlling applicants will need to gain written assurance from controlling employer that OSHA can come onsite

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Selected Worksite VPP Approval

• Decisions– VPP Star – VPP Merit – Application Denial

• One or more sites do not meet VPP minimum requirements (MR)

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Report Format

• Use VPP Site Report and VPP Worksheet to Document Corporate SHMS– Will provide supplemental instructions regarding

differences– Temporary solution

• One report that documents and verifies findings

Continuing Participation Requirements

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Reapproval, Withdrawal and Termination

• Reapproval – Evaluate additional worksite(s) every 12 to 18 months

• Number of sites same rules as application process

– Evaluate corporate SHMS every 5 years

• Withdrawal/Termination– RA will:

• Give the company 30 days to meet requirements; or • Ask the company to withdraw from the Demonstration.

– May terminate if employer fails to withdraw

• Appeals to Assistant Secretary

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Annual Evaluation

• Submit by February 15th

• Same format as traditional VPP with few exceptions:– Employment estimates for previous Year +TCIR and

DART Rates– Active/anticipated worksite list for current year– Union support update for current year

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The Path Forward

• Effective October 1, 2006, all current VPP Star Demonstration Programs will terminate

• Current Demo participants grandfathered into new Mobile Workforce Demonstration for Construction

• Traditional VPP still available– Long-term sites– Resident contractors at VPP sites– VPPC FY 2007

Documents

VPP Mobile Workforce Demonstration for Construction