Usually about five days, depending on the size of your facility and/or the complexity of your operations. The team may request administrative support.
Do I Have To Wait Until the End of the Review To Find Out My Chances of Being Approved?
The team leader will discuss the day's accomplishments with your designated representatives at the end of each day. What remains to be done will also be discussed to give you an idea of how the review is going.
The recommendation of the team regarding approval of your site will be based on its comprehensive assessment of your operations in relation to the VPP requirements. This cannot be done until the review is complete. The team makes a recommendation based on the information.
What Will The Team Be Doing While It Is Onsite?
The team performs a review that includes several steps:
- Initial meeting
- Document review
- Formal and informal interviews
- Closing meeting
The team will hold a brief introductory meeting with you and your key people. Anyone who may be called upon to assist the team should attend. Employees who are accountable for meeting or maintaining VPP requirements also should attend. The team leader will describe the VPP approach, and what the team expects to accomplish. You will have the opportunity to point out special accomplishments that may not be part of your application.
Records are examined to verify implementation of your safety and health program. This typically takes one or two days. A private area such as a conference room will be needed for the document review.
Prior to the onsite visit, the team leader will confer with you about materials the team will want to see. Collection of these materials beforehand will greatly facilitate the review. Documents and programs typically requested during a VPP onsite review include:
- OSHA log and workers' compensation first reports of injury for the last 3 complete calendar years and year-to-date
- Hours worked
- Comprehensive health and safety surveys identifying potential hazards
- Industrial hygiene monitoring and sampling records
- Sample safety and health training materials for supervisors and employees, along with attendance records
- Routine general inspection reports, with documentation of hazard correction
- Documentation of employees reports of safety and health concerns and evidence of steps taken toward correction Accident/incident investigation reports
- Plant safety and health rules
- Hazard analysis procedures and results, with safe work procedures
- Personal protective equipment programs
- Emergency preparedness program (i.e., fire, evacuation, emergency shutdown, chemical spill, etc.)
- Medical program
- Safety committee minutes
- Line accountability documentation
- Safety and health program self-evaluation reports
- Site contractor program
- All other applicable programs, including those required by TOSHA standards
Any additional information that shows the quality of the site's safety and health program is also requested.
The OSHA log and first reports of injury should be separated from other materials. This will help the review and recalculation of the injury rates.
While the site representative(s) will have primary responsibility for presenting and answering questions, corporate safety and health staff and other site personnel may assist in liaison with the TOSHA team.
The review team specialists will walk through the pertinent areas of the facility to assure that the program is fully operational. They will assess the adequacy of the program to handle potential hazards. This typically takes 1 to 2 days.
The walkthrough is not an enforcement inspection, but if the team notes any hazards, you will be expected to correct the problems.
The team will have brief, informal interviews with randomly selected employees. The talks will be held near employee workstations to minimize any work interruption.
Tennessee Department of Labor/TOSHA