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ASSP Comments on OSHA's Effort to Modernize VPP

Apr 14, 2023

In February 2023, OSHA announced it was seeking public comments on modernizing its Voluntary Protection Programs (VPP). The program was last updated in 1989. Since then, the agency published its Recommended Practices for Safety and Health Programs (2016) and voluntary consensus standards related to safety management systems have been published — including  ANSI/ASSP Z10-2019 (national) and ISO 45001-2018 (international).

As a result, ASSP asked its membership to provide insight to inform our comments. Several hundred ASSP members offered feedback, which was used to shape our overall statement.

ASSP has long supported VPP, including this position statement:

ASSP supports cooperative compliance efforts that recognize or promote employer or employee programs that reduce, or control, recognized workplace hazards and risks, along with fostering employee involvement. Examples of such efforts include the Voluntary Protection Program (VPP) and the Safety and Health Achievement Recognition Program (SHARP).

In its technical comments, ASSP noted the following:

  • Near unanimous consensus from responding members that VPP is worthy of a modernization effort.
  • Near unanimous consensus that use of accepted voluntary national consensus standards such as ANSI/ASSP Z10 and ISO 45001 should be considered, as should guidance found in ANSI/ASSP Z16.1 and ASSP TR-31000-2020.
  • A strong consensus that OSHA should look at new initiatives to enhance inclusion and participation from companies that perform construction and demolition activities.
  • A strong consensus that OSHA take care to not weaken the program's requirements in its efforts to modernize VPP.
  • The unanimous consensus to keep VPP name.

Read ASSP's comments on VPP

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