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VPP in Construction

VPP in Construction. Paula O. White Director, Cooperative and State Programs Occupational Safety and Health Administration ASSE June 14, 2005. VPP for Construction Why?. Provides flexibility to meet unique aspects of industry Companies may attain recognition at different levels.

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VPP in Construction

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  1. VPP in Construction Paula O. White Director, Cooperative and State Programs Occupational Safety and Health Administration ASSE June 14, 2005

  2. VPP for Construction Why? • Provides flexibility to meet unique aspects of industry • Companies may attain recognition at different levels

  3. VPPC OVERVIEW • Site-based • Similar to traditional VPP but only available for long-term sites (two or more years in duration) • Demonstration • Allows VPP approval for alternative programs that may not be covered by VPPC • Corporate, Division, Business Unit (C/D/BU) • Covers all work activities within a designated geographical area

  4. Highlights: What’s New Eligibility: C/D/BU • Corporate • Division • Business Unit • Open to all contractors • Large generals • Small subs

  5. OSHA Proposed C/D/BU • Approval and Recognition • All contractually responsible work • Limited to state boundaries • Option for expansion • Evaluations • One Corporate onsite • Site/project-level onsite evaluations will follow a tiered approach • Corporate evaluations recognized by all regions

  6. Major Issues With the Proposal • Number of Site/Project Evaluations • Union Support • Method • Amount • New Requirements • Corporate Oversight • Fall Protection • Sub-contractor prequalification • Drug Program • Proposal Too Cumbersome

  7. What We Heard:How many C/D/BU evaluations should be required? • 90% of responders support the concept of a tiered approach as proposed in VPPC • 33% of supporters prefer to see a higher number of site inspections (closer to 10%)

  8. Union Support Complex Issue: • Jobs not planned or started • Uncertainty of which unions are affected • Some unions come to site for short periods of time (1 day to 2 weeks)

  9. Union Support OSHA Proposal: • Each union could do own signed statement of support • President of local Building Trades Council could sign on behalf of all local unions • President of Building and Construction Trades Dept, AFL-CIO, and/or general presidents of international unions could sign statement of support.

  10. OSHA Proposed:Corporate Oversight • A process to review and analyze project/site information regarding the identification, correction, and tracking of workplace hazards • 100% of responders agreed that a corporate oversight system is a good requirement

  11. Related Questions 100% Fall Protection 50% said yes Subcontractor Prequalification 44% said yes Drug Testing/Screening 66% said Yes

  12. Some Commenter Concerns • Proposal too cumbersome for small contractors • Requires too much administrative effort for small companies without full time safety personnel • Inadequate incentives provided for participation • Potentially negative impact on OSHA inspection program

  13. Cooperative Programs to Participate In Now • Traditional VPP (Site Based) • Demonstration Programs • Short-Term Construction • Mobile Workforce • Region V Demonstration Pilot • Resident Contractor at Non-VPP Sites • OSHA Challenge – Construction Track • Partnerships

  14. VPP Demonstrations • 1993: Resident Contractor Demo • JE Merit, Brown& Root • 2001- Adopted into regular VPP • 1998: Mobile Workforce Star Demo* • LPR Construction , E & K of Omaha, HDR Engineering • 1998: Short-Term Construction Star Demo* • J.E. Merit, Torcon, Black and Veatch • 2003- Region V Mobile Workforce Pilot • Century, Danis, Furgerson • 2004- Resident Contractors at non-VPP host sites.

  15. OSHA Challenge • Road Map for safety and health • Recognition • Conserve OSHA resources • Increase and expedite participation

  16. Challenge Administrators • Curtis Lumber Company • United States Postal Service • VPP Participants’ Association • Black & Veatch • Construction Safety Council • Ohio Valley VPPAC • Associated Builders and Contractors • Associated General Contractors of America • NEA - Association of Union Constructors • Independent Electrical Contractors

  17. Next Steps • Continuing review with the Agencies • Final decision will determine the timeframe for revised FRN • Final FRN may reflect changes from the original proposal based on decisions by the Acting Assistant Secretary. Questions? Contact the Directorate of Cooperative and State Programs 202 693-2213.

  18. Questions or Comments?

  19. Contact Paula White white.paula@dol.gov 202-693-2200

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