On Safety: OSHA’s SHARP and VPP

Although it’s regarded as an enforcement agency, OSHA gives equal footing to compliance assistance and cooperative programs. Two of the agency’s exemplary cooperative programs are the Safety and Health Achievement Recognition Program – administered by the state consultation programs – and the Voluntary Protection Programs, overseen at the federal level.

Look SHARP

SHARP recognizes small businesses that have used OSHA’s On-Site Consultation Program services and operate an exemplary safety and health program. Acceptance into the program is an achievement that signals that an organization is a model for worksite safety and health. SHARP is funded by OSHA but run by state grantees.

SHARP is designed for small employers – those with 250 or fewer onsite employees and fewer than 500 corporatewide employees. This upper corporate size limit doesn’t apply to individual franchisees. To join SHARP, an employer must:

• Request a comprehensive consultation visit, which involves a complete hazard identification survey, from the local On-Site Consultation Program office.
• Involve employees in the consultation process.
• Correct all hazards identified by the consultant.
• Implement and maintain a safety and health program that, at a minimum, addresses OSHA’s Safety and Health Program Management Guidelines; Issuance of Voluntary Guidelines.
• Maintain a DART rate (days away, restricted or transferred) and total recordable case (TRC) rate below the national average for their particular industry.
• Agree to notify their state’s On-Site Consultation Program office before making any changes in the working conditions or introducing new hazards into the workplace.

After you satisfy all of the SHARP requirements, the consultation project manager in your state may recommend your worksite for SHARP approval. The state consultation program, in conjunction with OSHA, will formally recognize your worksite with a SHARP certificate. Many states coordinate with your worksites to host ceremonies and further recognize your achievements.

When a worksite is certified, it’s granted an exemption from OSHA programmed inspections for up to two years. After certification, the worksite may request SHARP renewal for up to three years, provided the organization:

• Applies for renewal during the last quarter of the exemption period.
• Allows a full-service comprehensive visit to ensure the exemplary safety and health program has been effectively maintained or improved.
• Continues to meet all SHARP eligibility criteria and program requirements.
• Agrees, if requesting a two- or three-year renewal, to conduct and submit an interim year SHARP site self-evaluation to the manager of the state’s On-Site Consultation Program manager. The evaluation is based on the elements of the Safety and Health Program Management Guidelines; Issuance of Voluntary Guidelines and includes the worksite’s injury and illness logs, which are required by OSHA to be maintained.

Consider VPP

VPP recognizes both employers and workers in the private industry and federal agencies (no size requirements) who have implemented effective safety and health management systems as well as maintained injury and illness rates below Bureau of Labor Statistics averages for their respective industries. To participate, employers must apply to OSHA and undergo onsite evaluation by a team of safety and health professionals. Union support is required for applicants represented by a bargaining unit. VPP participants will be reevaluated every three to five years to remain in the programs. They’re exempt from OSHA programmed inspections while they maintain their VPP status.

Key elements a worksite must demonstrate to become a VPP member include:

• Maintain injury and illness rates below those identified by BLS for their corresponding industry
• Operate a comprehensive safety and health management system that addresses the following elements:
  • Management leadership
  • Employee involvement
  • Worksite analysis
  • Hazard prevention and control
  • Safety and health training

So, what’s the difference?

SHARP and VPP are excellent programs, but what’s the difference between them? Both require OSHA rates to be below their industry average, onsite visits to examine the site programs and the implementation of SHMS. VPP, however, applies to any employer, regardless of their size; SHARP applies to only small employers. If an organizations achieves either VPP or SHARP status, both programs offer an exemption from OSHA programmed inspections.

States carry out SHARP through the free OSHA On-Site Consultation Program, funded by OSHA through grants to the states. VPP is funded and operated by OSHA. Both programs are overseen by OSHA’s directorate of cooperative and state programs in the agency’s national office. The argument can certainly be made from a funding and resource perspective that both programs are essentially the same and should be combined into a single recognition program. Combining the two programs has the potential benefit of better use of limited resources and budget, and perhaps setting the stage for expansion of members into a single, united exemplary program.