Cal/VPP Program Eligibility Review Process
Initial application review
The initial review of the application is intended to verify the employer's qualifications as listed under the Employer Application Guideline and Cal/VPP Star Program. The application is reviewed by the Cal/VPP manager and consultants. The applicant has the opportunity to amend the application with additional or substitute materials for the purpose of completing the application. If initial review indicates significant program deficiencies, the applicant maybe recommended to apply for other Consultation services partnership programs before proceeding with the Cal/VPP Star program.
Initial Application withdrawal
If the applicant does not meet the requirements for approval or for any reason does not wish to continue the process, reasonable time (not to exceed 30 calendar days) shall be allowed for application withdrawal after the review.
Initial Application denial
If the application is denied, the applicant will be informed of the reasons for denial. The applicant may request a meeting Cal/VPP manager to discuss the reasons for denial of the application.
A pre-visit may be required prior to scheduling an onsite review visit. The purpose of pre visit is to confirm application information including OSHA log 300 incidence rates, meet with management and employees, to conduct an informal assessment of the safety and health programs including the site's physical hazards, submission of informal recommendations for the onsite visit preparations, and gather information necessary for the formation of a Cal/VPP onsite visit team and its related logistics. The pre visit maybe conducted by Cal/VPP consultants or a Special Team Member (STM)
C) Onsite Evaluation
The Pre-approval onsite evaluation is aimed at an in-depth review of the site's safety and health programs, It is conducted at the site for which participation to the Cal/VPP Star program has been requested. The review will include:
- Verification of the information supplied in the application
- Identify strengths and weaknesses of the site safety and health program
- Determine whether the safety and health program adequately addresses potential hazards of the site
- Determine the site's readiness to participate in the program
- Submit a list of opportunities for improvement to the site addressing noted safety and health hazards and deficiencies
- Provide information to Chief of the Division of the Occupational Safety and Health for making the approval decision.
The review will be scheduled at a time mutually convenient to both Cal/OSHA and the applicant.
Cal/VPP Star team
The Cal/VPP Star team will consist of a team leader, Cal/VPP safety and health consultants, and Special Team Members (STM) appropriate for the size and complexity of the site.
Duration of the review
The time required for the pre-approval review will depend upon the size and complexity of the site and operations. A typical example includes two to five days.
All Pre-Approval Reviews will include interviews with relevant parties (such as members of joint safety committees, management personnel, randomly selected supervisory non-supervisory personnel, and contract and temporary employees). Onsite document review will include the following records (or samples of them):
- Injury and Illness Prevention Program
- Management statement of commitment to safety and health
- Line supervisor accountability
- The Cal/OSHA Forms 300, 300A and 301 for the last three years.
- Safety and health manual(s)
- Employee notifications of safety and health problems
- Safety rules, emergency procedures and sample safe work procedures
- Annual audits
- The system for enforcing safety rules
- Self-inspection procedures, reports and correction tracking
- Accident investigations
- Safety committee minutes
- Employee orientation and safety training programs and attendance records
- Industrial hygiene monitoring records
- Contractors safety and health program
- Preventive maintenance program
- Employees report of safety and health problems and documentation of response
- Other programs as required, i.e., confined space, lockout/tagout, Hazard Communication and Process Safety Management.
Note: For a complete list and the logistics of the onsite preparation. Click Here
D) Cal/VPP Report
Upon completion of the onsite visit, the team's report of findings, identifying the opportunities for improvements, will be sent to the site's VPP Coordinator within a reasonable time. The report will provide an overview of the site's safety and health related weaknesses and strengths. This includes the VPP elements and regulatory deficiencies as well as the site's injury and illness rate performance in comparison with the industry standards. A copy of the report is provided to the Chief of Cal/OSHA, stating the team's recommendation for approval of the site to the Cal/VPP program, upon the site's satisfactory completion of all identified opportunities for improvements. The site will have up to 90 days to take appropriate actions to correct deficiencies and implement opportunities for improvements.
If the applicant cannot meet the requirements for approval or for any reason at any time does not wish to continue the process, reasonable time (not to exceed 30 calendar days) shall be allowed for application withdrawal before a recommendation is made to the Chief of DOSH. The site shall submit a commitment letter that all regulatory issues will be addressed appropriately.
E) Follow-up Visit
A follow up visit will be conducted within 90 days of the receipt of the Cal/VPP report by the site's VPP coordinator. The purpose of the follow up is to determine the site's completion of all identified opportunities for improvements as listed in the Cal/VPP report. The follow up visit will be conducted by Cal/VPP consultants and may include a Special Team Member (STM)s. The scope of the follow up will be limited to the assessment of the completion of the opportunities for improvements identified in the Cal/VPP report.
Note: Upon, a satisfactory follow up visit, as determined by the Cal/VPP team, an approval letter, the Divisions certificate of approvals will be mailed to the site.
Upon Approval by the Chief of Cal/OSHA for the site to join the Cal/VPP Star program, the site is encouraged to perform a formal ceremony for the site's management-employee joint efforts and accomplishments. A suggestive guideline for the logistics of the ceremony is available from the Cal/VPP office upon request and/or the site is encouraged to contact the other approved VPP sites for their recommendations.
G) Annual Report
Every year on February 15, all Cal/VPP Star sites are required, as part of their continuous improvements efforts, to provide to Cal/VPP team, a report detailing the sites safety and health activities with respect to VPP elements, and other safety and health status updates and progress reviews. The sites approved in less than a year are exempt from this requirement for the first time.
H) Periodic Visits
A revisit of the site will be scheduled every 3 years to determine the site's eligibility to maintain the Cal/VPP Star status. The scope of the visit will be the same as the initial onsite review visit. The team conducting the visit may consist of the same or other consultants and STMs of similar qualifications.
Participation in the Cal/VPP program is voluntary and the participants may choose to terminate their status at any time. Cal-OSHA may also terminate a sites participation upon determination that the site no longer meets the VPP eligibility requirements. Examples of termination include but are not limited to the followings:
- Completion of construction work at the construction Star site.
- Sale of the approved site to another company unless new company undertakes and demonstrate all commitments.
- The participating site management, or the recognized collective bargaining agent, where applicable, terminating participation.
- Failure to maintain the safety and health program in accordance with the program requirements as determined by the Cal/VPP manager.
- Receipt of Cal-OSHA repeat or willful citations.
J) Post-approval assistance
Cal/OSHA support person
A Cal/OSHA compliance person will be assigned to each Cal/VPP Star work site as a resource person. The compliance person is invited to attend the opening conference only during the on-site visits and will be available to assist the Cal/VPP site, as needed, to assure smooth interface with Cal/OSHA compliance and to provide expertise as required.