Preparing for the OSHA VPP Audit Team, Lessons …

1 Andrew Palhof Compliance Assistance Specialist Concord, NH Area Office 603-225-1629 Preparing for the OSHA VPP Audit Team, Lessons Learned, Common Audit Findings & Prevention Measures MOST OF SAFETY & HEALTH- GOOD COMMON SENSE 90% WORKPLACE INJURIES - HUMAN ERROR 10% EQUIPMENT ERROR Updates to OSHA s Recordkeeping and Reporting Rule Effective January 1, 2015 employers must report the following to OSHA with 24 Hours. 4 National Statistics Star 2,141 Merit 30 Total Sites 2,239 Employees 862,398 Source: OSHA, Office of Partnership & Recognition * Number reflects active participants at the close of the calendar year 11 32 46 63 71 104 175 282 391 542 665 890 1162 1545 1720 1681 1516 1437 1400 0200400600800100012001400160018002000`82 `84`86`88`90`92`94`96`98`00`02`04`06`08` 10`12`14`15`16 Number of Participants Calendar Year Growth of VPP Participants Federal Only - as of 03/31/16 Growth of VPP State Plan States 3 3 12 21 35 61 89 115 149 197 249 292 333 392 469 528 592 632 720 712 735 743 766 774 781 0100200300400500600700800900 Fiscal Year Source.

2 OSHA, Office Partnerships & Recognition As of 03/31/2016 7 Improved Oversight and Controls Would Better Ensure Program Quality VPP 8 Opening Conference / Orientation How to successfully get through the Audit RECERT vs. INITIAL Audit Day 1- Opening Conference / Site Orientation & Processes Comprehensive Walkthrough Audit Day 2- Continue walkthrough Interviews Day 3- Interviews Continue walkthrough Day 4- Program Review / Report Writing Day 5- Clean up loose ends Closing Conference 9 10 Preparing for the Evaluation Documents for review should be readily available, organize and appropriately labeled in a room set aside for the VPP Evaluation Team. 11 Preparing for the Re-Evaluation Develop a bullet list of significant safety and health program changes since the previous evaluation or any since the application was submitted.

3 12 Conduct an Internal VPP Audit Assessment Review 4 Elements of VPP Use questions from VPP report template and answer them. Reference Appendix E from VPP P&P Manual, User Guide Randomly select employees to interview and use sample questions Identify areas for improvements 15 Audit Team will look closely at: Sites Vetting Process OSHA history Injury / Illness Rates? Oversight of contractors onsite Discipline Request- Daily List of all contractors on site 16 Recommendation: Review and Complete the OSHA VPP Evaluation prior to the evaluation Working Lunches Have Employees Showcase Best Practices and Achievements of SHMS. Employee Participation & Presentations Counted as Informal Interviews.

4 Difference between Formal and Informal? 17 Formal Interviews To Validate Employee Awareness and Participation in the sites S&H Program. Site Employees, Contractors, Temporary Workers, Supervisors and Top Level Management. No right or wrong answers. Confidential 15 - 30 minutes in length. 18 19 20 Protecting Temporary Workers Success Stories EMPLOYEE INVOLVEMENT 21 22 Corporate Poster 23 Be Prepared to correct hazards during the evaluation. Ensure personnel are available to answer the team s questions. Executives should take part in the Audit and will need to be interviewed! for the Evaluation Hazards vs. Recommendations? 24 Employee Training Records 25 26 27 First Aid Log INSURANCE LOSS RUN REPORT 29 Covered Employees Include all employees including salaried, executive, part-time, migrant and seasonal workers Includes temporary workers (from other employers or agencies) if locally supervised on a day-to-day basis 30 INCENTIVE PROGRAMS Incentives that promote injury and illness reporting and worker involvement Reward workers for reporting injuries, illnesses, near-misses, attending safety training, reporting hazards, working safety 31 32 DISINCENTIVE PROGRAMS Disincentives that discourage injury and illness reporting and worker involvement.

5 Nothing learned, nothing reported, hazards not corrected OSHA Health Emphasis Programs Heat Stress Noise Lead Silica Isocyanates Chrome VI Safer Chemicals & Alternatives Why do it? Improve worker health and safety Reduce or eliminate exposures Personal Protective Equipment (PPE) Hazard Assessment PPE last resort Review hazard assessments periodically Certified assessment Hand protection and permeability to chemicals Safety glasses versus chemical goggles Assure PPE used is in good condition Don t forget these Maintenance Machine guarding, cleaning chemicals, noise, working at heights (ex., roof tops) Construction Contractors Grounds keeping/landscapers Use of PPE (ex.)

6 , eye protection), noise, working near or in active roadways (high visibility clothing) Security Maintenance Staff & Outside Contractors 38 CONTRACTOR PROGRAMS Landscaping 40 41 Rolling Stock 42 Powered Industrial Trucks and Training Is Fall Protection Required for Snow Removal? Do the Construction or General Industry Standards Apply? 45 46 50 51 52 56 Listing / Labeling Cylinder Storage Unsecured Acetylene Oxygen 61 62 63 Closing Conference 64 What to Expect after the Audit Site must complete the 90 Items before the report is submitted. Team Leader submits the report. Site is officially notified after NO Approval. 65 Pfizer Andover Recertification April 12, 2016