SMOOTH SAILING THROUGH THE OSHA VPP AUDIT Juanita

SMOOTH SAILING THROUGH THE OSHA VPP AUDIT Juanita Wilson, DNP, CRNP, MSN, MHA, COHN-S Donna Ferreira, ANP, MS, COHN-S/CM, FAAOHN March 2019

• Voluntary Protection Program • An OSHA program that promotes competent worksite safety and health • A collaborative program that engages management, labor and OSHA to work together cooperatively Source: OSHA, Office of Partnerships & Recognition WHAT IS VPP?

TYPES OF VPP AND PARTICIPANTS FEDERAL ONLY AS OF 11/30/2018 MWF - 58 4% Merit - 7 1% • Demonstration – Building Programs • Merit – Stepping Stone • Star - Exemplary Source: https: //www. osha. gov/Osh. Doc/data_General_Facts/factshee t-vpp. pdf Star - 1322 95% Source: OSHA, Office of Partnerships & Recognition

VPP VALUE • VPP certification is recognition by OSHA for demonstrating the achievement of an exceptional occupational health and safety program • VPP is a company’s ongoing partnership with OSHA to provide the best possible conditions for worker health and safety Source: OSHA, Office of Partnerships & Recognition

DATA & STATS • State Participation and Location • Types of Industries • Union vs. Non-Union Source: http: //creativesafetypublishing. com/wp-content/uploads/2015/01/oshainspector. jpg

Distribution Of VPP Sites By State Federal Only As of 11/30/18 NH: 8 10 13 27 14 MA: 28 6 55 102 23 33 4 13 78 15 40 8 41 CT: 7 NJ: 46 16 11 DE: 5 44 35 331 97 RI: 5 32 46 111 50 Source: OSHA, Office of Partnerships & Recognition

DISTRIBUTION OF VPP SITES BY STATE FEDERAL ONLY AS OF 11/30/2018 350 331 300 250 200 150 111 100 50 102 97 78 32 50 44 33 4 7 5 46 15 14 28 41 13 55 46 35 10 13 23 8 8 40 27 5 6 11 16 0 AL AR CA CO CT DE FL GA ID IL KS LA MA ME MO MS MT ND NE NH NJ NM NY OH OK PA RI SD TX VA WI WV Source: OSHA, Office of Partnerships & Recognition

& te as M t ng 100 W cs Sv g si n fg 54 al es si on Pr of ou ar eh M ui p . er 36 W ry ne hi ac M Eq or t. S al et M 51 tio n pp Su rta po ns in ed 38 Tr a m Ad s 46 ic at as tic Pl es til iti 44 U um le tro 37 Pe r pe r. 38 Pa Se 50 dr y un La od 58 br & Fo rs l ic a ct o tra on C m he C 150 Fa al de Tr a rs on Pe lty ec ia Sp Top 15 Industries in the VPP Federal Only As of 11/30/18 250 213 200 125 81 58 58 34 0 Source: OSHA, Office of Partnerships & Recognition

Union & Non-Union VPP Sites Federal Only As of 11/30/18 Union, 21% Non-Union, 79% Source: OSHA, Office of Partnerships & Recognition

RECOMMENDATIONS FROM THE FIELD • OSHA VPP prep - a lengthy process • The (4) VPP elements must be in place for (1) year prior to OSHA performing an onsite review - Leadership & Employee Involvement - Worksite Analysis - Hazard Prevention & Control - Safety & Health Training • Prepare a 3 -ring binder with all safety program elements. Internally review and critique program (must go above and beyond basic OSHA compliance) • Employee prep and training to understand support for VPP (education and promotional campaigns) http: //www. workplace-safety-nc. com/articles/Ready-for-VPP. html

BENEFITS OF VPP • Employees: Safe workplace, improved training, better morale • Employers: Statistical evidence – Lower DART rate - Lower employee turnover and increased productivity and cost savings - Recognition in the community - Aids in securing contracts and business - Greater profit margins (reduced injuries, workers’ compensation costs and insurance premiums) https: //www. osha. gov/dcsp/vppflyer. html

VPP SUCCESS STORIES • 22 companies have posted success stories with documented outcomes • DART rate 60 - 80% below national average • TCIR rate 54% below national average • One company decreased WC costs by 75% in one year https: //www. osha. gov/dcsp/vpp/success_stories. html

OVERVIEW OF THE VPP PROCESS • Application information package • Submit a written application to OSHA • Application reviewed by OSHA • OSHA on-site review performed • Site is approved as Star or Merit by the Assistant Secretary for OSHA

SAMPLE AUDIT SCHEDULE • Informational Meeting: OSHA with management and employees • One week OSHA VPP Inspection: • • Day 1 Opening Meeting and general tours Day 2 -3 Specific department tours Day 4 Revisit open issues and writing Day 5 Closing meeting and announcement of results pending approvals

TYPICAL OSHA AUDIT SCHEDULE • 4 -8 auditors (OSHA & Special Government Employees • Duration is typically 5 days (initial) and 3 days (renewal)

OSHA VPP: SELF ASSESSMENT • Facility • Interviewing Skills • Medical Surveillance • Relationship with Safety Department • Knowledge of OSHA record keeping and worksite Walkabouts • Wellness • Worker’s Compensation records

Work. Comp. 10 Records l l 5 l 0 l l 5 l l 10 Facility *Adapted from Tony. Polecastro. com Wheel of Guitar Improvement 10 Interview Skills l l l 5 l l l 0 l l 5 l l 10 l l l Wellness Programs l 0 0 0 l l 5 l l 0 l Medical Surveillance 0 10 10 l l 5 l l 0 l l 5 l l 5 l l l 1 l 0 Worksite Walk Abouts Relationship with Safety 10 Dept. l Knowledge of OSHA recordkeeping and VPP

Work. Comp. 10 Records l l l l 5 l 0 l l 5 l l 10 Facility 10 Interview Skills l l l 5 l l l 0 l l 5 l l 10 l l l Wellness Programs l 0 0 0 l l 5 l l 0 l Medical Surveillance 0 10 10 l l 5 l l 0 l l 5 l l 5 l l l 1 l 0 10 Relationship with Safety Worksite Walk Abouts Dept. l Knowledge of OSHA recordkeeping and VPP

Facility Work. Comp. Records Interview Skills Wellness Programs Worksite Walk Abouts Medical Surveillance Relationship with Safety Dept. Knowledge of OSHA recordkeeping and VPP

GET READY • The Facility (2 months before) • Occupational Health Records & Documentation (1 -2 months before) • The Staff (2 weeks before)

STAGES OF GRIEF VS STAGES OF VPP PREP Ferreira Kubler-Ross • Denial • Anger • Anxiety • Bargaining • Acceptance • Depression • Relief & Appreciation • Acceptance Kubler-Rose 1969 On Death and Dying

HOW TO PREPARE YOUR SITE FOR OSHA’S VOLUNTARY PROTECTION PROGRAM

GET READY • The Facility (2 months before) • Occupational Health Records & Documentation (1 month before) • The Staff (2 weeks before)

THE FACILITY • Ceilings • Signs: Exits, Bio. Hazard, Cabinets/Drawers, O 2 • Oxygen secured • Doors: Full Swing • Clutter free

FACILITIES CONT. • • • Electrical cords Storage MSDSs for products Evacuation Plan Clean: Floors, walls, carpets, counters • Equipment Note: VPP prep can be leverage for improved facilities

OSHA ACCESS LETTER

OCCUPATIONAL HEALTH RECORDS & DOCUMENTATION • Policies and Procedures • Work related incident reporting • Medical Directives

OCCUPATIONAL HEALTH RECORDS & DOCUMENTATION • • Medical Records Certifications of Staff Manifests for Bio Waste transfers Wellness Activities Evidence of collaboration with Safety Evidence of employee input Renewals – Evidence of continued improvements

OCCUPATIONAL HEALTH RECORDS & DOCUMENTATION • Surveillance Programs • • Lead, Hearing, Asbestos, Respirator, Haz Mat, etc Program participants lists Procedures for notifications when participants list changes Medical records of surveillance program compliance

OCCUPATIONAL HEALTH RECORDS & DOCUMENTATION • Medial records match OSHA log • # of cases • # lost days, restricted days • First Aid cases vs Medical Treatment • Communication between Health Center and Safety • Communication with supervisor

QUIZ TIME! IS IT OSHA RECORDABLE? • Sutures • Steri-Stips • Keflex prescription • Finger Guard • Finger Splint • Fracture • Restricted Duty • Lost Time • Tetanus Injection • Drilling a fingernail • Dermabond

QUIZ TIME! IS IT “OSHA RECORDABLE? ” • Sutures • Steri-Stips • Keflex prescription • Finger Guard • Finger Splint • Fracture • Restricted Duty • Lost Time • Tetanus Injection • Drilling a fingernail • Dermabond Sutures Yes Steri-Stips No Keflex prescription Yes Finger Guard No Finger Splint Yes Fracture Yes Restricted Duty Yes Lost Time Yes Tetanus Injection No Drilling a fingernail No Dermabond Yes 1904. 7 (b)(5)

DOCUMENTATION BLOODBORNE PATHOGENS • Exposure Control Plan reviewed annually to include “solicit input from …employees” 1910. 1030(c) • Participants offered Hep B or signed a declination • Annual BBP training • 1910. 1030(f)(4) Post Exposure, employer provides evaluating healthcare professional with a copy of the OSHA standard, route and type of exposure, result of source individual testing

STAFF • Preparation is key • Inform • Questions • Role play (interview) • Have management support present • Resources • Have cell #s • Facilities • Plant Manager • Safety • Staff

ROLE OF THE OHN AT THE OSHA VPP AUDIT • Manage the scene • Focus on what is asked • Showcase successes

QUESTIONS FOR OCC. HEALTH • Who is responsible for recordkeeping? • What are your qualifications and licenses? • What procedures are in place to ensure that health care services are delivered consistently and effectively? • What type of audit procedures do you use to compare your process with acceptable standards of practice and OSHA requirements? • Are employees provided timely access to services?

QUESTIONS FOR OCC. HEALTH • How do you assure that work restrictions or work removal are followed? • How are you made aware of the job hazards at this facility? • Are you included in identification of workplace hazards, or development of restricted duty jobs, or other onsite issues?

QUESTIONS FOR OCC. HEALTH • What kinds of health surveillance programs are in place? • How do you communicate health surveillance data to employees and management to reduce future risk? • Explain how you evaluate the effectiveness of your occupational health care program.

AUDIT READY, EVERY DAY! • “Auditors look…for evidence of continual improvement…” (Guzik, 2016 Quality Progress publication) • OSHA conducts extensive employee interviews. Sample question: “What has senior management done recently to improve worker safety? ” (Wallace, 2016)

REAL LIFE EXPERIENCE • “You are missing a wing nut on that oxygen tank holder” • “I just fell in the hallway and hurt my knee” • “What do you think the OSHA VPP program is about? ” • “Tell me what happens when there is a work related injury” • Auditor became ill • “Are there any questions I did not ask? ” • “Tell me about the programs here” • What happens in the “off hours? ”

OSHA VPP IS A PARTNERING AND COLLABORATIVE EFFORT BETWEEN OSHA AND COMPANIES FOR THE COMMON GOAL OF EMPLOYEE SAFETY AND WELL BEING.

ATTITUDE: A CHOICE • Don’t be nervous and worried but rather consider an OSHA VPP audit a time to share the amazing things the company and occupational health team provide and promote in the goal of keeping workers safe, healthy, and productive at work. • Instead of “OMG!!!” … say … “Bring it! I can’t wait to share all that we do!”

REFERENCES • Guzik, J. J, 2016. Prove It: How to demonstrate risk-based thinking or auditors. Qualty Progress publication • healthandsafetyatwork: https: //www. bing. com/th? id=OIP. j. J 0 a. Ruc. JYn. Mo. Ar 4 h. Tt. Gex. AHa. Ha&pid=Api • Moore, P. V, Moore, R. L. (Editors) 2014. Fundamentals of Occupational Health Nursing: AAOHN Core Curriculum 4 th Edition, AAOHN Academy Inc. • OSHA VPP: https: //www. osha. gov/dcsp/vpp/all_about_vpp. html • osha-inspector-group: http: //creativesafetypublishing. com/wp-content/uploads/2015/01/osha-inspector-group. jpg • osha-inspector: http: //creativesafetypublishing. com/wp-content/uploads/2015/01/osha-inspector. jpg • osha-inspection: https: //www. creativesafetysupply. com/content/education-research/5 S/images/oshainspection. jpg? v=2 • Wallace, J. , 2016. So You Think You’re Ready for OSHA VPP? Workplace Safety-nc. com • thinksafeworksafebesafe: https: //tse 4. mm. bing. net/th? id=OIP. Xd 6 w. K 3 J-xwj. Qih. Dnu. CY-MAHa. Fu&pid=Api • Tonypolecastroguitar. com • vpplogo_large. jpg: https: //www. osha. gov/dcsp/vpp/newlogo. html