BACKGROUND
The Occupational Safety and Health Administration (OSHA) is committed to expanding cooperative
programs and providing opportunities for all eligible employers interested in working with the
Agency to create safer and healthier workplaces for their employees. Current cooperative programs
include the OSHA Strategic Partnership Program, the Alliance Program, and the State Consultation
Program. Current OSHA programs that recognize safety and health excellence are the Voluntary
Protection Programs (VPP) and the Safety and Health Achievement and Recognition Program (SHARP).
OSHA has designed all these programs to meet the needs and interests of a diverse range of
employers. VPP in particular has attracted a wide spectrum of employers, from mom-and-pop operations
with limited resources to large industrial sites with fulltime safety and health professional staff.
However, a program is not currently available that caters specifically to organizations that are
interested in VPP but need a "roadmap" to attain VPP status. OSHA’s Challenge is intended to
satisfy this need. This new initiative is sufficiently flexible to recognize that there are many
employers working towards attaining VPP, and these employers are at different stages in the
development of an effective safety and health management system.
The OSHA Challenge enables these employers to receive recognition from OSHA for incremental
progress. In addition, the program formalizes procedures and methods currently used by many
corporations that have multiple VPP sites.
This paper outlines the program and discusses specific concepts that were developed by
several workgroups including representatives from the OSHA National and Regional Offices, the
Voluntary Protection Programs Participants’ Association (VPPPA), and several companies currently in
VPP.
DEFINITIONS
Challenge Stages (I, II, and III): Levels of progression that OSHA Challenge participants follow.
Each stage has defined requirements to successfully implement components of an effective safety and
health management system. These stages serve as a "roadmap" to guide participants towards achieving
VPP status.
Challenge Administrators: Organizations such as corporations, non-profit associations, or Federal
agencies that have dedicated resources to administer the OSHA Challenge for their worksites/members
or other organizations’ worksites/members. Administrators are involved in the application and review
process.
Challenge Candidate: A Challenge Candidate is an employer who has elected to submit an application
to a Challenge Administrator. The employer will remain a candidate until it receives OSHA
notification that it has been accepted into the OSHA Challenge.
Challenge Participant: A Challenge participant is a worksite that has been accepted into the
OSHA Challenge for the purpose of developing or improving its safety and health management system.
AUTHORITY
Section 21(c) of the Occupational Safety and Health Act gives OSHA the authority to develop programs
such as Challenge. The Act states, in part:
"The Secretary, in consultation with the Secretary of Health and Human Services, shall (1) provide
for the establishment and supervision of programs for the education and training of employers and
employees in the recognition, avoidance, and prevention of unsafe or unhealthful working conditions
in employments covered by this Act, and (2) consult with and advise employers and employees, and
organizations representing employers and employees as to effective means of preventing occupational
injuries and illnesses."
OBJECTIVES
The key objective of Challenge is to support OSHA’s mission to protect lives by reducing fatalities,
injuries and illnesses in the workplace. Other important objectives of the OSHA Challenge include:
- To support the Department of Labor’s Strategic Plan
- To support the OSHA Strategic Management Plan
- To logically integrate with the existing menu of cooperative programs
- To uphold required quality and integrity standards of the VPP
- To be responsive to stakeholders’ needs and maintain positive relations
PROGRAM DESCRIPTION
The OSHA Challenge is designed to be flexible to accommodate all major industry groups (e.g.,
manufacturing, construction, maritime, service industries, small businesses, unionized and
nonunionized organizations). The initiative will provide opportunities for employers in these
industries, as well as other employers not currently serviced by existing cooperative programs, to
work with OSHA. Challenge will cater to employers wanting to improve their safety and health
management systems and expedite their efforts to attain VPP status by providing a "roadmap" to guide
them through the process. The "roadmap" refers to the defined set of Challenge stages that Challenge
participants progress through. A separate roadmap or series of stages will be provided for the
construction industry. OSHA will provide recognition to these participants for successful completion
of each stage as they incrementally improve their safety and health management systems.
Administrator Eligibility
An important element of the OSHA Challenge initiative is to work cooperatively with qualified
Challenge Administrators. The work performed by Administrators will ease the burden on OSHA’s
limited resources. Challenge Administrators may be corporations, non-profit associations, and
Federal agencies that are approved by OSHA to act as such. Certain criteria are required of
Challenge Administrators, including demonstrated knowledge and experience in safety and health
management systems, availability of adequate resources, and a commitment to the program.
Administrators will act as the primary contact with their Challenge participants. They will guide
participants through a structured series of stages to make incremental improvements in their safety
and health management systems. Administrators will also have an important role in collecting and
reporting information on each candidate and participant, such as injury and illness data.
Candidate Eligibility
The OSHA Challenge is open to private or public-sector employers under OSHA’s jurisdiction who are
interested in and committed to improving their safety and health management systems. These
employers, if accepted, will be known as Challenge participants. Prospective candidates will need to
have the sponsorship of an approved Challenge Administrator and must confirm their commitment to
improve their safety and health management systems. All Challenge participants must be approved by
OSHA.
Completion of Stages
OSHA will accept participants at various stages, depending on which safety and health management
system elements they have already implemented, if any. Once approved, Challenge participants will
begin work with their Administrators to implement and/or improve these systems. All participants
will be required to show progression through the stages by demonstrating knowledge, actions,
documentation, and specific outcomes at the completion of each stage. At the completion of the final
stage (III), the participant should be prepared to apply for VPP.
Program Incentives
At the completion of each stage, OSHA will provide recognition to the participant. Recognition will
include congratulatory letters from OSHA acknowledging the participant’s accomplishment in
Challenge. The participant's site will also be featured on the OSHA web page.
Program Measures
OSHA will measure the program’s success at both the participant level and overall program level. At the
participant level, OSHA will evaluate quantitative and qualitative measures, such as illness and
injury data, and leading indicators for management commitment and employee involvement. OSHA Challenge
success measures will include evaluating the number of participants at each stage, percent of
participants progressing to the next stage, and the percent of those achieving VPP.
PROGRAM IMPLEMENTATION
OSHA will kick off the OSHA Challenge in a formal ceremony attended by OSHA Assistant Secretary
John Henshaw, as well as Administrators representing a corporation, a Federal agency, and a
nonprofit association.
Each OSHA Challenge Administrator will endeavor to sponsor ten approved participants. OSHA will
provide continuous monitoring and a formal evaluation after one year. Monitoring may include
quarterly conference calls, progress reports, and face to face meetings with the Challenge
Administrators and participants.
After the one-year evaluation, OSHA will determine, based on its findings, whether to continue,
modify, or terminate the program. Alternatively, the Assistant Secretary may decide to formalize
Challenge through normal procedures, for example, a Federal Register Notice or OSHA directive.
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