On Safety: It’s time to combine the efforts of OSHA’s cooperative and enforcement programs
When one thinks of cooperative programs, the OSHA Voluntary Protection Programs or the agency’s partnerships generally come to mind. The fact is, OSHA has many programs under the cooperative programs umbrella – all of which are based on safety and health improvement strategies. For example, compliance assistance, alliances, partnerships, the Safety and Health Achievement and Recognition Program, and VPP are all part of the cooperative programs network. Former Assistant Labor Secretary John Henshaw used to liken the cooperative programs journey to steps on a ladder, beginning with basic compliance assistance and ending with VPP or SHARP.
Within OSHA, cooperative programs should carry the same rank and importance as enforcement, but they seldom do. Cooperative programs have historically been underutilized and not treated within the agency as an equal partner in injury and illness prevention. As a result, their funding lags behind that of enforcement. (In the fiscal year 2019 OSHA budget, 14% of funding went to compliance assistance and 39% went to enforcement).
Furthermore, the program resources that exist are not deployed strategically to achieve the greatest gain in risk reduction. These programs are there for the asking. However, OSHA doesn’t differentiate among those requesting services based on need or the severity of the hazard(s) they are trying to manage. Depending on the administration, cooperative programs are either important and a priority, or they take a back seat to enforcement. It’s time that both cooperative and enforcement programs be used jointly to reduce risk as well as advance workplace safety and health.
Cooperative programs provide the agency an opportunity to leverage the implementation of injury and illness prevention plans and/or safety and health management systems, especially if tied to an enforcement action. Cooperative programs are a cost-effective means to drive change and improve employee protection. These programs should be integrated with enforcement into a comprehensive agency approach targeted at sites and processes with the most serious hazards and the highest degree of risk. Additionally, cooperative programs should be directed at employers who want to protect employee health and safety but lack the resources or information to do so.
Unfortunately, in a number of organizations, safety and health programs and policies are viewed as an extra cost rather than an opportunity for investment that can lead to improved productivity, product quality and profitability. Safety and health professionals often find it an uphill battle to get their managers to make needed safety and health investments. Under cooperative programs, a step-by-step process described as the steps on a ladder may assist efforts of these safety and health pros. OSHA’s cooperative programs are a cost-effective means for driving change and improving worker protection. In expanding the use of cooperative programs, several additional points should be considered:
- Professional and employer associations should be allowed to partner with the agency.
- The VPP process should be streamlined and made consistent among all OSHA regions.
- The agency should expand the use of partnerships, VPP and compliance assistance to employers who want to improve employee health and safety but either lack resources or are unsure of how to proceed.
- OSHA should make use of the expertise of external VPP auditors and expand the Special Government Employee force to help provide assistance and guidance to those employers needing such help. In other words, lessen the resource drain on OSHA by using Special Government Employees to replace some agency personnel on VPP evaluations.
- Codify VPP.
- VPP and SHARP focus on employer excellence in safety and health. OSHA doesn’t have the budget or resources to carry two programs that are essentially the same. To improve efficiency and reduce costs, these programs should be combined. By combining the programs, resources from OSHA (the agency’s consultation service and the VPP-SGEs) can all be used together to work with employers.
This article represents the views of the authors and should not be construed as a National Safety Council endorsement.
Richard Fairfax (CIH, retired 2017) joined OSHA in January 1978 and retired from the agency in 2013. At OSHA, he was a practicing field industrial hygienist, as well as the deputy director and director of enforcement programs. In 2008, Richard served as acting director of construction and, in 2010, was designated deputy assistant secretary – overseeing all field, enforcement and training operations. From 1993 through 2010, Richard wrote an industrial hygiene column entitled, “OSHA Compliance Issues” for the Journal of Occupational and Environmental Hygiene. He still serves on the Editorial Review Board. Richard now works part time for NSC-ORC HSE.