Among its compliance assistance  efforts, OSHA established the VPP in 1982 to recognize worksites with  safety and health systems that exceed OSHA’s standards. They must  meet a number of requirements, including having an active safety and  health management system that takes a systems approach to preventing  and controlling workplace hazards. The VPP Has Grown Significantly in Recent Years Due to OSHA’s Emphasis on Program Growth and Outreach to New Participants

The VPP has grown steadily since its inception, with the number of  employer worksites in the program more than doubling—from 1,039 sites  in 2003 to 2,174 sites in 2008. The motor freight transportation  industry, which had only 20 sites in 2003, grew tenfold to just over 200  sites in 2008, due in part to the growth in the number of Postal Service  sites. As shown in figure 4, the proportion of VPP sites with fewer  than 100 workers increased from 28 percent in 2003 to 39 percent in 2008. A key factor influencing growth of the VPP has been OSHA’s emphasis on  expansion of the program. OSHA Lacks a Policy Requiring Documentation of Actions Taken by the Regions in Response to Fatalities and Serious Injuries at VPP Sites

OSHA’s lack of a policy requiring documentation in the VPP files of  actions taken by the regions in response to incidents, such as fatalities and  serious injuries, at VPP sites limits the national office’s ability to ensure  that regions have taken the required actions. From our review of OSHA’s VPP files, we found that there was no  documentation of actions taken by the regions’ VPP staff to (1) assess the  safety and health systems of the 30 VPP sites where 32 fatalities occurred  from January 2003 to August 2008 or (2) determine whether these VPP  sites should remain in the program. OSHA’s Internal Controls Do Not Ensure That Its Regional Offices Comply with VPP Policies

OSHA’s oversight of the VPP is limited because it does not have internal  controls, such as management reviews by the national office, to ensure  that its regions consistently comply with VPP policies for verifying sites’  injury and illness rates and conducting on-site reviews. In addition, OSHA’s national office did not review the actions taken by the  regions to ensure that they followed up when VPP sites’ injury and illness  rates rose above the minimum requirements for the program. As a result, some sites that have not met a key requirement of the  VPP have remained in the program. First, OSHA has not developed  performance goals or measures to assess the performance of the program. However, these rates may not be the best measure of performance. Second, OSHA has not  evaluated the impact of the VPP on sites’ injury and illness rates, such as  comparing VPP sites’ injury and illness rates with those of similar sites  that do not participate in the program. OSHA Has Not Adequately Evaluated the Effectiveness of the VPP

In response to a recommendation in our 2004 report that the agency  evaluate the effectiveness of the VPP, OSHA contracted with The Gallup  Organization to study the effectiveness of the program—the results of  which were reported in September 2005. However,  the study had significant design flaws. Recommendations for Executive Action

To ensure proper controls and measurement of program performance, the  Secretary of Labor should direct the Assistant Secretary for Occupational  Safety and Health to take the following three actions:    develop a documentation policy regarding information on follow-up  actions taken by OSHA’s regional offices in response to fatalities and  serious injuries at VPP sites;    establish internal controls that ensure consistent compliance by the  regions with OSHA’s VPP policies for conducting on-site reviews and  monitoring injury and illness rates so that only qualified worksites  participate in the program; and   establish a system for monitoring the performance of the VPP by  developing specific performance goals and measures for the program. Appendix I: Scope and Methodology

To identify the number and characteristics of employer worksites in the  Voluntary Protection Programs (VPP), we analyzed data in the Department  of Labor’s Occupational Safety and Health Administration (OSHA) VPP  database. To determine the extent to which OSHA ensures that only qualified  worksites participate in the VPP, we reviewed OSHA’s internal controls for  the program and limited our review to VPP sites in the federally managed  program that were part of the Star program.
Why GAO Did This Study

The Department of Labor's Occupational Safety and Health Administration (OSHA) is responsible for ensuring workplace safety. OSHA has established a number of programs, including the Voluntary Protection Programs (VPP), that take a cooperative approach to obtaining compliance with safety and health regulations and OSHA's standards. OSHA established the VPP in 1982 to recognize worksites with exemplary safety and health programs. GAO was asked to review (1) the number and characteristics of employer worksites in the VPP and factors that have influenced growth, (2) the extent to which OSHA ensures that only qualified worksites participate in the VPP, and (3) the adequacy of OSHA's efforts to monitor performance and evaluate the effectiveness of the VPP. GAO analyzed OSHA's VPP data, reviewed a representative sample of VPP case files, and interviewed agency officials.

What GAO Found

The VPP has grown steadily since its inception in 1982, with the number of employer worksites in the program more than doubling--from 1,039 sites in 2003 to 2,174 sites in 2008. Although industries represented have not changed significantly, with the chemical industry having the largest number of sites in the VPP, the number of sites in the motor freight transportation industry--which includes U.S. Postal Service sites--increased tenfold from 2003 to 2008. The proportion of smaller VPP sites--those with fewer than 100 workers--increased from 28 percent in 2003 to 39 percent in 2008. Key factors influencing growth of the VPP have been OSHA's emphasis on expansion of the program and VPP participants' outreach to other employers. OSHA's internal controls are not sufficient to ensure that only qualified worksites participate in the VPP. The lack of a policy requiring documentation in VPP files regarding follow-up actions taken in response to incidents, such as fatalities and serious injuries, at VPP sites limits the national office's ability to ensure that its regions have taken the required actions. Such actions include reviewing sites' safety and health systems and determining whether sites should remain in the program. GAO reviewed OSHA's VPP files for the 30 sites that had fatalities from January 2003 to August 2008 and found that the files contained no documentation of actions taken by the regions' VPP staff. GAO interviewed regional officials and reviewed the inspection files for these sites and found that some sites had safety and health violations related to the fatalities, including one site with seven serious violations. As a result, some sites that no longer met the definition of an exemplary worksite remained in the VPP. In addition, OSHA's oversight is limited because it does not have internal controls, such as reviews by the national office, to ensure that regions consistently comply with VPP policies for monitoring sites' injury and illness rates and conducting on-site reviews. For example, the national office has not ensured that regions follow up as required when VPP sites' injury and illness rates rise above the minimum requirements for the program, including having sites develop plans for reducing their rates. Finally, OSHA has not developed goals or measures to assess the performance of the VPP, and the agency's efforts to evaluate the program's effectiveness have been inadequate. OSHA officials said that low injury and illness rates are effective measures of performance. These rates, however, may not be the best measures because GAO found discrepancies between the rates reported by worksites annually to OSHA and the rates OSHA noted during its on-site reviews. In addition, OSHA has not assessed the impact of the VPP on sites' injury and illness rates. In response to a recommendation in a GAO report issued in 2004, OSHA contracted with a consulting firm to conduct a study of the program's effectiveness. However, flaws in the design of the study and low response rates made it unreliable as a measure of effectiveness. OSHA officials acknowledged the study's limitations but had not conducted or planned other evaluations of the VPP.