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White Paper: SimpleQuEs Explanation of a Comparison between OSHA VPP and OHSAS 18001

Written by: Larry Vance, Vice President - July 19, 2010 OSHA VPP The Voluntary Protection Programs (VPP) was established by the U.S. Congress in the passage of the Occupational Safety and Health Act of 1970 to promote effective worksite-based safety and health. In the VPP, management, labor, and OSHA establish cooperative relationships at workplaces that have implemented a comprehensive safety and health management system. Approval into VPP is OSHAs official recognition of the outstanding efforts of employers and employees who have achieved exemplary occupational safety and health. It is Congresss intent "to assure so far as possible every working man and woman in the Nation safe and healthful working conditions and to preserve our human resources - (1) by encouraging employers and employees in their efforts to reduce the number of occupational safety and health hazards at their places of employment, and to stimulate employers and employees to institute new and to perfect existing programs for providing safe and healthful working conditions." In practice, VPP sets performance-based criteria for a managed safety and health system, invites sites to apply, and then assesses applicants against these criteria. OSHAs verification includes an application review and a rigorous onsite evaluation by a team of OSHA safety and health experts. OSHA approves qualified sites to one of three programs: 1. Star: The first approval rating for establishing an OSHA compliant system. 2. Merit: The mid-term rating. 3. Star Demonstration: The highest rating. Recognition for worksites that address unique safety and health issues. OHSAS 18001 The OHSAS 18001 Standard was developed by a cooperative effort of International Health and Safety organizations covering Occupational Health & Safety (OH&S) management intended to provide organizations with the elements of an effective OH&S management system that can be integrated with other management requirements and help organizations achieve OH&S and economic objectives. This OHSAS Standard specifies requirements for an OH&S management system to enable an organization to develop and implement a policy and objectives which take into account legal requirements and information about OH&S risks. The success of the system depends on commitment from all levels and functions of the organization, and especially from top management. A system of this kind enables an organization to develop an OH&S policy, establish objectives and processes to achieve the policy commitments, take action as needed to improve its performance and demonstrate the conformity of the system to the requirements of this OHSAS Standard. The overall aim of this OHSAS Standard is to support and promote good OH&S practices, in balance with socio-economic needs. Comparison While both OH&S management systems have been established to promote a healthy and safe worksite environment for all people working for or on behalf of a company there are some major differences in the programs. VPP was established for companies operating in the United States and for compliance to all OSHA requirements as specified in the Code of Federal Requirements 1960 section 29 (29 CFR 1960). OHSAS 18001 was created as an International Standard which specifies conformance to the requirements of the standard. OHSAS 18001 does not establish absolute requirements for OH&S performance beyond the commitments, in the OH&S policy, to comply with applicable legal and other requirements to which the organization subscribes, whereas VPP does require strict compliance with all OSHA regulations. Both VPP and OHSAS have many similar requirements for establishing, implementing, and maintaining an OH&S management system. Both systems complement each other and could be integrated into one OH&S management system. It is unfortunate that at this time VPP does not fully recognize OHSAS certification as part of the VPP certification

program. However, having an established OHSAS management program would go a long way in meeting the requirements of the VPP. Both VPP and OHSAS contain requirements that can be objectively audited to obtain and maintain certification. Both programs require 3rd Party audits for certification as well as internal audits for continual monitoring, measuring and improving the effectiveness of OH&S management systems. Auditors for both systems must have a high level of knowledge and understanding of the OHSA regulations. VPP auditors must have a much higher level of knowledge and understanding of the OSHA regulations as their audits are focused on compliance with these requirements, while OHSAS auditors will need to assess whether someone in the organization has the knowledge and understanding of the OSHA requirements and how they maintain compliance. Both VPP and OHSAS audits will also include conformance to the additional requirements of the two programs.

Comparison between OSHA VPP and OHSAS 18001


OSHA VPP REQUIREMENTS Section I: Management Leadership & Employee Involvement A. Written Safety & Health Management System A1. Are all the elements (such as Management Leadership and Employee Involvement, Worksite Analysis, Hazard Prevention and Control, and Safety and Health Training) and sub-elements of a basic safety and health management system part of a signed, written document? (For Federal Agencies, include 29 CFR 1960.) If not, please explain. A2. Have all VPP elements and sub-elements been in place at least 1 year? If not, please identify those elements that have not been in place for at least 1 year. A3. Is the written safety and health management system at least minimally effective to address the scope and complexity of the hazards at the site? (Smaller, less complex sites require a less complex system.) If not, please explain. A4. Have any VPP documentation requirements been waived (as per FRN page 656, paragraph F5a4)? If so, please explain. OHSAS 18001 REQUIREMENTS

COMMENTS

4.4.4 Documentation The H&S management system documentation shall include: a.) the H&S policy and objectives; b.) description of the scope of the H&S management system; c.) description of the main elements of the H&S management system and their interaction, and reference to related documents, d.) documents, including records, required by this OHSAS standard; and e.) documents, including records, determined by the organization to be necessary to ensure the effective planning, operation and control of processes that relate to the management of its H&S risks. NOTE: It is important that documentation is proportional to the level of complexity, hazards and risks concerned and is kept to the minimum required for effectiveness and efficiency. A.1. VPP and 18001 have similar requirements for a documented Occupational Health and Safety Management System. Both will require a Policy Manual, Procedures, and Records as evidence of establishing, implementing and maintaining the OH&S Management System which has been reviewed and approved by Top Management. A.2. VPP requires the system to be in place for 1 year prior to the Star certification audit, while an OHSAS18001 system needs only show the system has been implemented. It is normal for an auditor to want see 3 months of objective evidence. A.3. Both systems must identify the scope of the system and identify any/all H&S hazards and risks that can be controlled or managed by the organization, and a control plan. A.4. Both systems will allow for exclusions of certain documentation requirements, with justification.

B. Management Commitment & Leadership B1. Does management overall demonstrate at least minimally effective, visible leadership with respect to the safety and health program (considering FRN items F5 A-H)? Provide examples.

4.4.1 Resources, roles, responsibility, accountability and authority 4.4.1 Top management shall take ultimate responsibility for Health and Safety and the Health and Safety Management System. Top management shall demonstrate its commitment by: a.) Ensuring the availability B1. Both systems require the commitment and involvement of Top Management. Management must show its commitment by assigning roles, responsibilities, and authorities, by providing

of resources essential to establish, implement, maintain and improve the H&S management system; b.) Defining roles, allocating responsibilities and accountabilities, and delegating authorities, to facilitate effective H&S management; roles, responsibilities, accountabilities, and authorities shall be documented and communicated.

resources for the management and execution of the H&S system, communicating to the organization the importance of compliance with all H&S requirements, and evaluating the effectiveness of the H&S system.

B2. How has the site communicated established policies and results-oriented goals and objectives for employee safety to employees? B3. Do employees understand the goals and objectives for the safety and health program?

4.2 H&S Policy f) is communicated to all persons working on behalf of the organization and make them aware of their obligations, 4.4.3.2 Participation and Consultation: The organization shall establish, implement and maintain a procedure(s) for, a) the participation of workers by their: * involvement in the development and review of OH&S policies and objectives, 4.3.3 Objectives and Programs: The objectives shall be measurable and consistent with the OH&S policy, including a commitment to the prevention of injury and ill health, to comply with legal and other requirements, and to continual improvement. 4.3.3 The organization shall establish, implement and maintain a program for achieving its objectives. Programs shall include as a minimum: a) designation of responsibility and authority for achieving objectives at each relevant function and level of the organization; b) the means and time-frame by which they are to be achieved. The programs shall be reviewed at regular and planned intervals, and adjusted as necessary. 4.3.3 Objectives and Programs When establishing and reviewing its objectives, an organization shall take into account the legal requirements and other requirements to which the organization subscribes, and its OH&S risks. It shall also consider its technological options, its financial, operational and business requirements, and the views of relevant interested parties.

B2. Both systems require communication of all Policies and procedures, and H&S goals and objectives. Objectives and goals must be known by all employees. B3. Both systems require employees to understand the objectives and work toward reaching the goals.

B4. Are the safety and health program goals and objectives meaningful and attainable? Provide examples supporting the meaningfulness and attainability (or lack there of if answer is no) of the goal(s). (Attainability can either be unrealistic/realistic goals or poor/good implementation to achieve them.) (See: TED Chapter 3 II C1a) B5. How does the site measure its progress towards the safety and health program goals and objectives? Provide examples.

B4. Objectives and Goals must be SMART. Specific, Measurable, Attainable, Realistic, and Timed

B5. Objectives and Goals must have clearly defined measures. They cannot be vague. Programs must be established for achieving the Objectives and Goals.

C. Planning C1. How does the site integrate planning for safety and health with its overall management planning process (for example, budget development, resource allocation, or training)?

C1. H&S Management must be part of a companys strategic planning. There must be a budget and resource allocations, for the H&S Management System. OSHA training must be a part of the H&S systems.

C2. Is safety and health effectively integrated into the sites overall management planning process? If not, please explain. D. Authority and Line Accountability D1. Does top management accept ultimate responsibility for safety and health in the organization? (Top management acknowledges ultimate responsibility even if some safety and health functions are delegated to others.) If not,

C2. Will be determined through Management Reviews and audits, both internal and external. 4.4.1 Resources, Roles, Responsibility, Accountability and Authority Top management shall take ultimate responsibility for OH&S and its management.

D1. Management accepts ultimate responsibility for all employees and those working under the companys directives.

please explain. D2. How is the assignment of authority and responsibility documented and communicated (for example, organization charts, and job descriptions)? D3. Do the individuals assigned responsibility for safety and health have the authority to ensure that hazards are corrected or necessary changes to the safety and health management system are made? If not, please explain. D4. How are managers, supervisors, and employees held accountable for meeting their responsibilities for workplace safety and health? (Annual performance evaluations for managers and supervisors are required.)

Top management shall demonstrate its commitment by; b) defining roles, allocating responsibilities and accountabilities, and delegating authorities, to facilitate effective OH&S management. These shall be documented and communicated. 4.4.1 The organization shall ensure that persons in the workplace take responsibility for aspects of OH&S, over which they have control, including adherence to the applicable OH&S requirements.

D2. Both systems require the defining of roles, responsibilities, and authorities. These are defined in Org. Charts and Job Descriptions for H&S Key Personnel. D3. Both systems require assigning authority for corrective actions and changes to the H&S system.

D5. Are adequate resources (equipment, budget, or experts) dedicated to ensuring workplace safety and health? Provide examples. D6. Is access to experts (for example, Certified Industrial Hygienists, Certified Safety Professionals, Occupational Nurses, or Engineers), reasonably available to the site, based upon the nature, conditions, complexity, and hazards of the site? If so, under what arrangements and how often are they used? E. Contract Employees E1. Does the site utilize contractors? Please explain.

4.4.2 Competence, Training and Awareness The organization shall establish, implement and maintain a procedure to make persons working under its control aware of; a) the OH&S consequences, actual and potential, of their work activities, their behavior, and the benefits of improved personal performance. b) their roles, responsibilities, and importance in achieving conformity to the policy and procedures and to the requirements of the OH&S management system, including emergency preparedness and response requirements c) the potential consequences of departure from specified procedures, 4.4.1 Top management shall demonstrate its commitment by; a) ensuring the availability of resources essential to establish, implement, maintain and improve the OH&S management system 4.4.3.2 Participation and consultation The organization shall ensure that, when appropriate, relevant external interested parties are consulted about pertinent OH&S matters.

D4. Both systems require accountability for actions taken as well as the consequences of not following the requirements of the H&S system. For VPP Performances evaluations are required for determining competency and identifying any additional training needs or improvements in knowledge and skill levels. OHSAS18001 does not specify annual evaluations, but this is a best practice. D5. Both systems require the determining of adequate resources, both human and capital (equipment, safeguards, PPE, etc.) D6. Both systems require having experts on sight or available for consultation, as appropriate to the organization.

E2. Were there contractors onsite at the time of the evaluation? E3. When selecting onsite contractors, how does the site evaluate the contractors safety and health programs and performance (including rates)? (See: TED Chapter 3 IV 3-19)

E1. Both systems require education of the H&S requirements to all people working on behalf of the company. E2. Auditor question. 4.4.2 Competence, training and awareness The organization shall ensure that any person(s) under its control performing tasks that can impact on OH&S is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records. 4.4.3.1 Communication With regard to its OH&S hazards and OH&S management system, the organization shall establish, implement and maintain a procedure(s) for: E3. Both systems require the treatment of contract employees and contracted services employees to be aware of, and comply with all OSHA and company H&S requirements. E4. Same as above. Must provide evidence of compliance.

E4. Are contractors and Subcontractors at the site to maintain effective safety and health programs and to comply with all applicable OSHA and company safety and health rules and regulations?

If so, please provide examples. E5. Does the sites contractor program cover the prompt correction and control of hazards in the event that the contractor fails to correct or control such hazards? Provide examples. E6. How does the site document and communicate oversight, coordination, and enforcement of safety and health expectations to contractors?

b) communication with contractors and other visitors to the workplace; 4.4.2 Competence, training and awareness The organization shall establish, implement and maintain a procedure(s) to make persons working under its control aware of: c) the potential consequences of departure from specified procedures. 4.4.3 b) communication with contractors and other visitors to the workplace; 4.4.6 c) controls related to contractors and other visitors to the workplace;

E5. Both systems require education of all persons working under the companys control on H&S procedures and responses to any incidents that might occur. E6. Both require documentation of communications regarding contractor and subcontractor compliance to OSHA and company H&S requirements. E7. Both systems require provisions for making people aware of the consequences or not complying with requirements. E8. Contract employees should be treated the same as company employees as it relates to their H&S. Both systems require documentation to show H&S training for all. Contracted service employees working on the behalf of the company must also show evidence of H&S training by their companies and should be aware of the organizations H&S system. E9. VPP - If an analysis shows that contract employees incur more injuries and illnesses than company employees, corrective actions must be taken. OHSAS does not impose this but it could be considered a best practice. E10. VPP specific to contract employees. Not stated as a requirement of OHSAS. However, all people working on behalf of the company are included. This does include employees, contract employees, and employees of contracted services. E11. This is to be determined by the auditor(s) for both VPP and OHSAS.

E7. Have the contract provisions specifying penalties for safety and health issues been enforced, when appropriate? If not, please explain. E8. How does the site monitor the quality of the safety and health protection of its contract employees?

E9. If the contractors injury and illness rates are above the average for their industries, does the site have procedures that ensure that all employees are provided effective protection on the worksite? If not, please explain.

E10. Do contract provisions for contractors require the periodic review and analysis of injury and illness data? Provide examples.

4.4.2 The organization shall establish, implement and maintain a procedure(s) to make persons working under its control aware of: c) the potential consequences of departure from specified procedures. 4.5.1 The organization shall establish, implement and maintain a procedure(s) to monitor and measure OH&S performance on a regular basis. This procedure(s) shall provide for: c) monitoring the effectiveness of controls (for health as well as for safety); e) reactive measures of performance that monitor ill health, incidents (including accidents, near-misses, etc.), and other historical evidence of deficient OH&S performance; 4.3.1 When determining controls, or considering changes to existing controls, consideration shall be given to reducing the risks according to the following hierarchy: a) elimination; b) substitution; c) engineering controls; d) signage/ warnings and/or administrative controls; e) personal protective equipment. 4.5.3.1 The organization shall establish, implement and maintain a procedure(s) to record, investigate and analyze incidents in order to a) determine underlying OH&S deficiencies and other factors that might be causing or contributing to the occurrence of incidents,

E11. Based on your answers to the above items, is the contract oversight minimally effective for the nature of the site? (Inadequate oversight is indicated by significant hazards created by the contractor, employees exposed to hazards, or a lack of host audits.) If not, please explain. F. Employee Involvement F1. How were employees selected to be interviewed by the VPP team?

4.5.1 The organization shall establish, implement and maintain a procedure(s) to monitor and measure OH&S performance on a regular basis. This procedure(s) shall provide for: c) monitoring the effectiveness of controls (for health as well as for safety);

4.4.3.2 Participation and consultation The organization shall establish, implement and maintain a procedure(s) for: a) the participation of workers by their: appropriate involvement in hazard identification, risk assessments and determination of controls; appropriate

F1. For both VPP and OHSAS, auditors (external and internal) are required to interview an adequate sample size of employees to determine their knowledge, understanding, and roles in both H&S management

involvement in incident investigation; involvement in the development and review of OH&S policies and objectives; consultation where there are any changes that affect their OH&S; representation on OH&S matters. Workers shall be informed about their participation arrangements, including who is their representative(s) on OH&S matters.

systems.

F2. How many employees were interviewed formally? How many were interviewed informally? F3. Do employees support the sites participation in the VPP Process? F4. Do employees feel free to participate in the safety and health management system without fear of discrimination or reprisal? If so, please explain. F5. Please describe at least three ways in which employees are meaningfully involved in the problem identification and resolution, or evaluation of the safety and health program (beyond hazard reporting). (See: FRN Chapter 3 Paragraph II.C.1.b)

F2. Question for Auditors

F3. Question for Auditors. Based on interviews. F4. Determined by interviews.

F6. Are employees knowledgeable about the sites safety and health management system? If not, please explain. F7. Are employees knowledgeable about the VPP program? If not, please explain. F8. Are the employees knowledgeable about OSHA rights and responsibilities? If not, please explain. F9. Do employees have access to results of selfinspection, accident investigation, appropriate medical records, and personal sampling data upon request? If not, please explain.

4.4.3.2 The organization shall establish, implement and maintain a procedure(s) for: a) the participation of workers by their: appropriate involvement in hazard identification, risk assessments and determination of controls; appropriate involvement in incident investigation; involvement in the development and review of OH&S policies and objectives; consultation where there are any changes that affect their OH&S; representation on OH&S matters. Workers shall be informed about their participation arrangements, including who is their representative(s) on OH&S matters. 4.4.3.2 involvement in the development and review of OH&S policies and objectives; representation on OH&S matters.

F5. The requirements identified in OHSAS 4.4.3.2 should also meet the requirements of VPP F5. There must be objective evidence of employee participation in each of the OHSAS requirements.

F6. Both systems require employee knowledge, understanding and involvement in the H&S system. F7. Specific to VPP. Requires employee knowledge of VPP and its requirements. F8. Both systems require some level of knowledge of OSHA rights and responsibilities. F9. Both systems require participation of employees. VPP requires that employees have access to their personal data when involved in an accident. They should also have access to data analysis results.

4.4.3.2 a) the participation of workers by their: appropriate involvement in incident investigation.

Section II: Worksite Analysis A. Baseline Hazard Analysis A1. Has the site been at least minimally effective at identifying and documenting the common safety and health hazards associated with the site (such as those found in OSHA regulations, building standards, etc., and for which existing controls are

4.3.1 Hazard identification, risk assessment and determining controls The organization shall establish, implement and maintain a procedure(s) for the ongoing hazard identification, risk assessment, and determination of necessary controls.

A1. Based on audit results for both systems. Both require an assessment of H&S Hazards and Risks based on OSHA regulations and building

well known)? If not, please explain.

standards. Once Risks have been identified controls must be established and implemented. 4.3.1 The procedure(s) for hazard identification and risk assessment shall take into account: a) routine and non-routine activities; b) activities of all persons having access to the workplace (including contractors and visitors); c) human behavior, capabilities and other human factors; d) identified hazards originating outside the workplace capable of adversely affecting the health and safety of persons under the control of the organization within the workplace; e) hazards created in the vicinity of the workplace by work-related activities under the control of the organization; f) infrastructure, equipment and materials at the workplace, whether provided by the organization or others; g) changes or proposed changes in the organization, its activities, or materials; h) modifications to the OH&S management system, including temporary changes, and their impacts on operations, processes, and activities; i) any applicable legal obligations relating to risk assessment and implementation of necessary controls, j) the design of work areas, processes, installations, machinery /equipment, operating procedures and work organization, including their adaptation to human capabilities. A2. Both systems require documented evidence of the H&S hazard and risk analysis with a definition of the methodology used. The identification of H&S hazards is a key element of both systems and requires a high degree of knowledge of OSHA regulations (29 CFR 1960) and building standards. OHSAS gives more explanation of hazard identification and risk analysis.

A2. What methods are used in the baseline hazard analysis to identify health hazards? (Please include examples of instances when initial screening and full-shift sampling were used. (See FRN page 45657, F5.B.2.b )

A3. Does the site have a documented sampling strategy used to identify health hazards and assess employees exposure (including duration, route, and frequency of exposure), and the number of exposed employees? If not, please explain. A4. Do sampling, testing, and analysis follow nationally recognized procedures? If not, please explain. A5. Does the site compare sampling results to the minimum exposure limits or are more restrictive exposure limits (PELs, TLVs, etc.) used? Please explain. A6. Does the baseline hazard analysis adequately identify hazards (including health) that need further analysis? If not, please explain.

A3. Specific requirement of VPP but should also be part of OHSAS system. When there is a potential for exposure to hazards there should be a process in place to sample and test employees. A4. Part of OSHA regulations. Applies to both systems. A5. Same as above.

A7. Do industrial hygiene sampling data, such as initial screening or full shift sampling data, indicate that records are being kept in logical order and include all sampling information (for example, sampling time, date, employee, job title,

4.3.1 The organizations methodology for hazard identification and risk assessment shall: a) be defined with respect to its scope, nature and timing to ensure it is proactive rather than reactive; and b) provide for the identification, prioritization and documentation of risks, and the application of controls, as appropriate. 4.5.4 The organization shall establish and maintain records as necessary to demonstrate conformity to the requirements of its OH&S management system and of this OHSAS Standard, and the results achieved.

A6. Required by both systems. The hazard and risk assessment must establish a base line. Those hazards that pose a higher risk to employee H&S must be analyzed further and controls implemented.

A7. Specific requirement of VPP but implied by OHSAS. Organizations must stress industrial hygiene as it applies. Hygiene practices should be part of the H&S systems to prevent

concentrated measures, and calculations)? If not, please explain the deficiencies and how they are being addressed. B. Hazard Analysis of Significant Changes B1. When purchasing new materials or equipment, or implementing new processes, what types of analyses are performed to determine their impact on safety and health? Is it adequate? B2. When implementing/introducing non-routine tasks, materials or equipment, or modifying processes, what types of analyses are performed to determine their impact on safety and health? Is it adequate? C. Hazard Analysis of Routine Activities C1. Is there at least a minimally effective hazard analysis system in place for routine operations and activities? C2. Does hazard identification and analysis address both safety and health hazards, if appropriate? If not, please explain. C3. What hazard analysis technique(s) are employed for routine operations and activities (e.g., job hazard analysis, HAZ-OPS, fault trees)? Are they adequate?

the spread of illness.

4.4.6 For those operations and activities, the organization shall implement and maintain: b) controls related to purchased goods, equipment and services; The procedure(s) for hazard identification and risk assessment shall take into account: a) routine and non-routine activities;

B1. Both systems require an assessment/consideration of potential H&S hazards for any new materials, equipment, and processes. B2. Any activity outside the norm must be evaluated for potential hazards and/or risks and appropriate controls initiated.

C4. Are the results of the hazard analysis of routine activities adequately documented? If not, please explain. D. Routine Inspections D1. Does the site have a minimally effective system for performing safety and health inspections (i.e., a minimally effective system identifies hazards associated with normal operations)? If not, please explain.

4.3.1 The procedure(s) for hazard identification and risk assessment shall take into account: a) routine and non-routine activities; 4.3.1 The organization shall ensure that the Occupational Health & Safety risks and determined controls are taken into account when establishing, implementing and maintaining its OH&S management system. 4.3.1 The organizations methodology for hazard identification and risk assessment shall: a) be defined with respect to its scope, nature and timing to ensure it is proactive rather than reactive; and b) provide for the identification, prioritization and documentation of risks, and the application of controls, as appropriate. 4.3.1 b) provide for the identification, prioritization and documentation of risks, and the application of controls, as appropriate 4.5.1 Performance measurement and monitoring 4.5.1 The organization shall establish, implement and maintain a procedure(s) to monitor and measure OH&S performance on a regular basis. This procedure(s) shall provide for: a) both qualitative and quantitative measures, appropriate to the needs of the organization; b) monitoring of the extent to which the organizations OH&S objectives are met; c) monitoring the effectiveness of controls (for health as well as for safety); d) proactive measures of performance that monitor conformance with the OH&S program(s), controls and operational criteria; e) reactive measures of performance that monitor ill health, incidents (including accidents, near-misses, etc.), and other historical evidence of deficient OH&S performance; f) recording of data and results of monitoring and measurement sufficient to facilitate subsequent corrective action and preventive action analysis.

C1. Both systems require a hazard analysis of all activities prior to certification and with any new or changed operations. C2. Both systems are for the management of both Health and Safety, not either or.

C3. Both systems require the organization to define the methodologies used to assess H&S hazards and risks. Objective evidence must be presentable to the auditor.

C4. Same as above.

D1. Both systems require monitoring and measuring the effectiveness of the H&S systems and periodic assessments or evaluations. H&S audits/tours must be part of both systems. OHSAS defines in more detail what must be included in the assessments.

D2. Are routine safety and health inspections conducted monthly, with the entire site covered at least quarterly (for construction: entire site weekly)? D3. How do inspections use information discovered through the baseline hazards analysis, job hazard analysis, accident/incident analysis, employee concerns, sampling results, etc.? D4. Are those personnel conducting inspections adequately trained in hazard identification? If not, please explain.

4.5.1 The organization shall establish, implement and maintain a procedure(s) to monitor and measure OH&S performance on a regular basis. 4.5.1 f) recording of data and results of monitoring and measurement sufficient to facilitate subsequent corrective action and preventive action analysis. 4.4.2 The organization shall ensure that any person(s) under its control performing tasks that can impact on OH&S is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records. 4.5.1 f) recording of data and results of monitoring and measurement sufficient to facilitate subsequent corrective action and preventive action analysis. 4.5.1 f) recording of data and results of monitoring and measurement sufficient to facilitate subsequent corrective action and preventive action analysis.

D2. VPP specifies times for the assessments where OHSAS allows the organization to define. D3. Both systems require the analysis of information from the periodic assessments and the appropriate actions to be taken. D4. Both systems require training specific to H&S requirements. Those conducting the periodic inspections must be knowledgeable of regulations and requirements. D5. Both VPP and OHSAS require a documented definition of how and when assessments are to be performed. D6. Inspection and/or audit reports must document the results, and must identify responsibility for timely actions. D7. Auditor question.

D5. Is the routine inspection system written, including documentation of results? If not, please explain. D6. Do the written routine inspection reports clearly indicate what needs to be corrected, by whom, and by when? If not, please explain. D7. Did the VPP team find hazards that should have been found through self-inspection? If so, please explain. E. Hazard Reporting E1. Does the site have a reliable system for employees to notify appropriate management personnel in writing about safety and health concerns? Please describe.

4.5.3 Incident investigation, nonconformity, corrective action and preventive action 4.5.3.1 Incident investigation The organization shall establish, implement and maintain a procedure(s) to record, investigate and analyze incidents in order to: a) determine underlying OH&S deficiencies and other factors that might be causing or contributing to the occurrence of incidents; b) identify the need for corrective action; c) identify opportunities for preventive action; d) identify opportunities for continual improvement; e) communicate the results of such investigations. The investigations shall be performed in a timely manner.

E1. Both systems require a method of documenting and reporting any H&S incidents. This should include even minor occurrences and near misses. All reports must be investigated and the appropriate actions taken.

E2. Do the employees agree that they have an effective system for reporting safety and health concerns? If not, please explain. E3. Is there a minimally effective means for employees to report hazards and have them addressed? If not, please explain. F. Hazard Tracking F1. Does the hazard tracking system address hazards found by employees, hazard analysis of routine and non-routine activities, inspections, and accident or incident investigations? If not, please explain.

E2. Auditor to determine based on interviews. 4.5.3.1 Any identified need for corrective action or opportunities for preventive action shall be dealt with in accordance with the relevant parts of 4.5.3.2. 4.5.3.1 The organization shall establish, implement and maintain a procedure(s) to record, investigate and analyze incidents in order to: a) determine underlying OH&S deficiencies and other factors that might be causing or contributing to the occurrence of incidents; b) identify the need for corrective action; c) identify opportunities for preventive action; d) identify opportunities for continual E3. Auditors to determine the effectiveness of the Corrective and Preventive Action process.

F1. Both systems require the identification, recording, investigating, and analysis of H&S hazards and incidents.

F2. Does the tracking system result in hazards being corrected and provide feedback to employees for hazards they have reported. If not, please explain. F3. Does the tracking system result in timely correction of hazards with interim protection established when needed? Please describe.

improvement; e) communicate the results of such investigations. The investigations shall be performed in a timely manner. 4.5.3.1 Any identified need for corrective action or opportunities for preventive action shall be dealt with in accordance with the relevant parts of 4.5.3.2. 4.5.3.1 The investigations shall be performed in a timely manner.

F2. Both systems require corrective actions for all H&S incidents and the provision of information to persons involved. F3. Both systems require immediate corrective actions be taken to minimize the impact and permanent corrective action to prevent reoccurrence. F4. Management and Auditors must evaluate the effectiveness of the tracking system.

F4. Does a minimally effective tracking system exist that results in hazards being controlled? If not, please explain. G. Accident/Incident Investigations G1. Is there a minimally effective system for conducting accident/ incident investigations, including near-misses? If not, please explain.
4.5.3.1 Incident investigation The organization shall establish, implement and maintain a procedure(s) to record, investigate and analyze incidents in order to: a) determine underlying OH&S deficiencies and other factors that might be causing or contributing to the occurrence of incidents; b) identify the need for corrective action; c) identify opportunities for preventive action; d) identify opportunities for continual improvement; e) communicate the results of such investigations. The investigations shall be performed in a timely manner. 4.4.2 The organization shall ensure that any person(s) under its control performing tasks that can impact on OH&S is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records. 4.5.3.1 The organization shall establish, implement and maintain a procedure(s) to record, investigate and analyze incidents in order to: a) determine underlying OH&S deficiencies and other factors that might be causing or contributing to the occurrence of incidents;

G1. Both systems require a method of documenting and reporting any H&S incidents. This should include even minor occurrences and near misses. All reports must be investigated and the appropriate actions taken. Management and auditors to evaluate the effectiveness of the process.

G2. Are those conducting the investigations trained in accident/ incident investigation techniques? If not, please explain.

G2. Both systems require proper training for all H&S personnel in their respective roles.

G3. Describe how investigations discover and document all the contributing factors that led to an accident/ incident.

G3. Both systems require an indepth investigation of all accidents/injuries. Root cause analysis is required.

G4. Were any hazards discovered during the investigation previously addressed in any prior hazard analyses (e.g., baseline, self-inspection)? If not, please explain. H. Safety and Health Program Evaluation H1. Briefly describe the system in place for conducting an annual evaluation.

G4. Management and auditors must evaluate to determine if the hazard identification process was effective. 4.5.5 Internal audit The organization shall ensure that internal audits of the OH&S management system are conducted at planned intervals H1. Both systems require internal audits of the H&S management systems. VPP requires annual audits while OHSAS allows the organization to specify the frequency. However, registrars recommend all clauses of OHSAS be audited annually. H2. Internal audits should cover all aspects of the H&S systems.

H2. Does the annual evaluation cover the aspects of the safety and health program, including the

4.5.5 a) determine whether the OH&S management system: 1) conforms to

elements described in the Federal Register? If not, please explain.

H3. Does the annual evaluation include written recommendations in a narrative format? If not, please explain.

planned arrangements for OH&S management, including the requirements of this OHSAS Standard; and 2) has been properly implemented and is maintained; and 3) is effective in meeting the organizations policy and objectives; b) provide information on the results of audits to management. Audit program(s) shall be planned, established, implemented and maintained by the organization, based on the results of risk assessments of the organizations activities, and the results of previous audits. Audit procedure(s) shall be established, implemented and maintained that address: a) the responsibilities, competencies, and requirements for planning and conducting audits, reporting results and retaining associated records; and b) the determination of audit criteria, scope, frequency and methods. Selection of auditors and conduct of audits shall ensure objectivity and the impartiality of the audit process. 4.5.3.2 Nonconformity, corrective action and preventive action: The organization shall establish, implement and maintain a procedure(s) for dealing with actual and potential nonconformities and for taking corrective action and preventive action.

VPP requires audits that include compliance to OSHA regulations while OHSAS only requires audits to the standard requirements.

H3. Both systems require documentation of preventive actions and opportunities for improvement. Auditors should look for the opportunities. H4. Management and auditors must determine the effectiveness of the internal audit process.

H4. Is the annual evaluation an effective tool for assessing the success of the sites safety and health system? Please explain. H5. What evidence demonstrates that the site responded adequately to the recommendations made in the annual evaluation?

4.5.3.2 b) investigating nonconformities, determining their cause(s) and taking actions in order to avoid their recurrence; c) evaluating the need for action(s) to prevent nonconformity(ies) and implementing appropriate actions to avoid their occurrence; 4.5.1 f) recording of data and results of monitoring and measurement sufficient to facilitate subsequent corrective action and preventive action analysis. 4.5.3.1 The organization shall establish, implement and maintain a procedure(s) to record, investigate and analyze incidents in order to: a) determine underlying OH&S deficiencies and other factors that might be causing or contributing to the occurrence of incidents; b) identify the need for corrective action; c) identify opportunities for preventive action; d) identify opportunities for continual improvement; 4.5.3.1 The organization shall establish, implement and maintain a procedure(s) to record, investigate and analyze incidents b) identify the need for corrective action 4.5.3.1 The organization shall establish, implement and maintain a procedure(s) to record, investigate and analyze incidents in

H5. Both systems require objective evidence of responses and actions taken to audit findings and opportunities.

I. Trend Analysis I1. Does the site have a minimally effective means for identifying and assessing trends? I2. Have there been any injury and/or illness trends over the last three years? If so, please explain.

I1. Both systems require a process for data and trend analysis and appropriate actions taken for negative trends. I2. Management and auditors must review trends of accidents, injuries and illnesses. This would include a review of the OSHA 300 log that is required to be maintained.

I3. If there have been injury and/or illness trends, what courses of action have been taken? Are they adequate? I4. Does the site assess trends utilizing data from hazard reports or accident/ incident investigations to determine the potential for injuries and

I3. Both systems require actions be taken for negative trends.

I4. Both systems require analysis of trends. Corrective and Preventive actions must be

illnesses? If not, please explain. Section III: Hazard Prevention and Control A. Hazard Prevention and Control A1. Does the site select at least minimally effective controls to prevent exposing employees to hazards.

order to: c) identify opportunities for preventive action; d) identify opportunities for continual improvement; 4.3.1 Hazard identification, and determining controls 4.3.1 d) identified hazards originating outside the workplace capable of adversely affecting the health and safety of persons under the control of the organization within the workplace; e) hazards created in the vicinity of the workplace by work-related activities under the control of the organization; 4.4.6 Operational controls: The organization shall determine those operations and activities that are associated with the identified hazard(s) where the implementation of controls is necessary to manage the OH&S risk(s). This shall include the management of change. For those operations and activities, the organization shall implement and maintain: a) operational controls, as applicable to the organization and its activities; the organization shall integrate those operational controls into its overall OH&S management system;

taken.

A1. Both systems require control to prevent employee exposure to hazards. Management and auditors must evaluate the effectiveness of any controls.

A2. When the site selects hazard controls, does it follow the preferred hierarchy (engineering controls, administrative controls, work practice controls [e.g., lockout/tagout, bloodborne pathogens, and confined space programs], and personal protective equipment) to eliminate or control hazards? Please provide examples, such as how exposures to health hazards were controlled.

A2. Both systems require controls. VPP is more specific and gives examples of controls. OHSAS does not give specific information on what controls the organization must implement. However, an OHSAS system must consider all controls for H&S.

A3. Describe any administrative controls used at the site to limit employee exposure to hazards (for example, job rotation). A4. Do the work practice controls and administrative controls adequately address those hazards not covered by engineering or administrative controls? If not, please explain. A5. Are the work practice controls (e.g., lockout/tagout, bloodborne pathogens, and confined space programs) recommended by hazard analyses implemented at the site? If not, please explain. A6. Are follow-up studies (where appropriate) conducted to ensure that hazard controls were adequate? If not, please explain.

A3. OHSAS does not categorize controls as administrative, engineering, etc. like VPP. However, the organization should recognize the difference. A4. Management and auditors must assess the effectiveness of H&S controls. 4.4.6 For those operations and activities, the organization shall implement and maintain: a) operational controls, as applicable to the organization and its activities; the organization shall integrate those operational controls into its overall OH&S management system; 4.5.1 Performance measurement and monitoring: The organization shall establish, implement and maintain a procedure(s) to monitor and measure OH&S performance on a regular basis. This procedure(s) shall provide for: a) both qualitative and quantitative measures, appropriate to the needs of the organization; b) monitoring of the extent to which the organizations OH&S objectives are met; c) monitoring the effectiveness of controls (for health as well as for (safety); 4.4.6 The organization shall determine those operations and activities that are associated with the identified hazard(s) where the implementation of controls is necessary to manage the OH&S risk(s). For A5. Both systems require the implementation of controls to prevent accidents, injuries and illnesses. Management and auditors must evaluate the effectiveness of each control. A6. Both systems require the organization to monitor and measure the effectiveness of controls in preventing accidents, injuries and illnesses.

A7. Are hazard controls documented and addressed in appropriate procedures, safety and health rules, inspections, training, etc.? Provide examples.

A7. Both systems require procedures, and documented evidence for H&S Operational Controls.

A8. Are there written employee safety procedures including a disciplinary system? Describe the disciplinary system.

those operations and activities, the organization shall implement and maintain: a) operational controls, as applicable to the organization and its activities; the organization shall integrate those operational controls into its overall OH&S management system; 4.4.6 d) documented procedures, to cover situations where their absence could lead to deviations from the OH&S policy and the objectives;

A9. Has the disciplinary system been enforced equally for both management and employees, when appropriate? If not, please explain. A10. Does the site have minimally effective written procedures for emergencies (TED 3-16 3h)?

A11. Are emergency drills held at least annually?

4.4.2 The organization shall establish, implement and maintain a procedure(s) to make persons working under its control aware of: c) the potential consequences of departure from specified procedures. 4.4.7 Emergency preparedness and response: The organization shall establish, implement and maintain a procedure(s): a) to identify the potential for emergency situations; b) to respond to such emergency situations. The organization shall respond to actual emergency situations and prevent or mitigate associated adverse OH&S consequences. In planning its emergency response the organization shall take account of the needs of relevant interested parties, e.g. emergency services and neighbors. The organization shall periodically review and, where necessary, revise its emergency preparedness and response procedure(s), in particular, after periodical testing and after the occurrence of emergency situations 4.4.7 The organization shall periodically test its procedure(s) to respond to emergency situations

A8. Both systems require that employees are aware of the consequences of deviating from H&S policies, rules, and procedures. This should be in writing with evidence that all employees have received the proper instructions and warnings. A9. Both systems require evidence of any disciplinary actions taken. Management personnel are not exempt. A10. Both systems require a documented emergency response process.

A12. Does the site have a written preventative/predictive maintenance system? If not, please explain.

A13. Did the hazard identification and analysis (including manufacturers recommendations) identify hazards that could result if equipment is not maintained properly? If not, please explain. A14. Does the preventive maintenance system adequately detect hazardous failures before they occur? If not, please explain.

4.5.1 If equipment is required to monitor or measure performance, the organization shall establish and maintain procedures for the calibration and maintenance of such equipment, as appropriate. Records of calibration and maintenance activities and results shall be retained. j) the design of work areas, processes, installations, machinery/equipment, operating procedures and work organization, including their adaptation to human capabilities. b) controls related to purchased goods, equipment and services; If equipment is required to monitor or measure performance, the organization shall establish and maintain procedures for the calibration and maintenance of such equipment, as appropriate. Records of

A11. VPP requires the emergency response process be tested annually. OHSAS requires the process be tested periodically. A12. Both systems require procedures for maintenance of any equipment. OHSAS does not specify preventive maintenance.

A13. Both systems require the identification of all potential hazards and risk. It is during this process that the organizations must take lack of equipment maintenance into consideration. A14. Both systems require maintenance people to look for any potential hazards during their maintenance of equipment. All safety equipment (sprinklers, fire extinguishers, first aid kits, respirators, etc.) must be part of

calibration and maintenance activities and results shall be retained.

a maintenance program.

A15. How does the site select Personal Protective Equipment (PPE)?

When determining controls, or considering changes to existing controls, consideration shall be given to reducing the risks according to the following hierarchy: e) personal protective equipment.

A15. Both systems require the organization to have available and specify use of any PPE.

A16. Do employees understand the limitations and uses of PPE? If not, please explain. A17. Did the team observe employees using, storing, and maintaining PPE properly? If not, please explain. A18. Is the site covered by the Process Safety Management standard (29 CFR 1910.119)? If yes, please answer questions A19-A21 below. Additionally, please complete either onsite evaluation supplement A or B, and onsite evaluation supplement C. If not, skip to section B. A19. Which chemicals that trigger the Process Safety Management (PSM) standard are present? A20. Which process(es) were followed from beginning to end and used to verify answers to the questions asked in the PSM application supplement, the PSM Questionnaire, and/or the Dynamic Inspection Priority Lists? A21. Verify that contractor employees who perform maintenance, repair, turnaround, major renovation or specialty work on or adjacent to a covered process have received adequate training and demonstrate appropriate knowledge of hazards associated with PSM, such as non-routine tasks, process hazards, hot work, emergency evacuation procedures, etc.? Please explain. B. Occupational Health Care Program and Recordkeeping B1. Describe the occupational health care program (including availability of physician services, first aid, and CPR/AED) and special programs such as audiograms or other medical tests used. B2. How are licensed occupational health professionals used in the sites hazard identification and analysis, early recognition and treatment of illness and injury, and the system for limiting the severity of harm that might result from workplace illness or injury? Is this use appropriate? B3. Is the occupational health program adequate for the size and location of the site, as well as the nature of hazards found here? If not, please explain.

A16. Personnel required to wear PPE must be educated on the amount of protection they provide when used properly. A17. Auditors observation.

A18. OHSAS does not address specific hazards. The organization must identify any Hazardous Chemicals and the proper handling, storage, use, and disposal of these per OSHA Regulations A19. Specific to VPP A20. Specific to VPP

4.4.2 The organization shall ensure that any person(s) under its control performing tasks that can impact on OH&S is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records.

A21. Both systems require that contractor employees have adequate knowledge of hazards they may be exposed to or specific to their works and the appropriate actions that must be taken to mitigate the likelihood of occurrence.

B1. Specific to VPP. Also implied as part of an OHSAS Health management system.

B2. Specific to VPP.

B3. Specific to VPP. Management and auditors must determine the effectiveness of the health program(s).

Section IV: Safety and Health Training A. Safety and Health Training A1. What are the safety and health training requirements for managers, supervisors, employees, and contractors?

4.4.2 Competence, training and awareness 4.4.2 The organization shall ensure that any person(s) under its control performing tasks that can impact on OH&S is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records.

A1. Both systems require training of all people working for or on behalf of the company regarding the H&S system.

A2. Who delivers the training?

A3. How are the safety and health training needs for employees determined?

A4. Does the site provide minimally effective training to educate employees regarding the known hazards of the site and their controls? If not, please explain.

A5. What system is in place to ensure that all employees and contractors have received and understand the appropriate training?

A6. Who is trained in hazard identification and analysis?

A7. Is training in hazard identification and analysis adequate for the conditions and hazards of the site? If not, please explain. A8. Does management have a thorough understanding of the hazards of the site? Provide

4.4.2 The organization shall identify training needs associated with its OH&S risks and its OH&S management system. It shall provide training or take other action to meet these needs, evaluate the effectiveness of the training or action taken, and retain associated records. 4.4.2 The organization shall establish, implement and maintain a procedure(s) to make persons working under its control aware of: a) the OH&S consequences, actual or potential, of their work activities, their behavior, and the OH&S benefits of improved personal performance; b) their roles and responsibilities and importance in achieving conformity to the OH&S policy and procedures and to the requirements of the OH&S management system, including emergency preparedness and response requirements (see 4.4.7); c) the potential consequences of departure from specified procedures. Training procedures shall take into account differing levels of: a) responsibility, ability, language skills and literacy; and b) risk. 4.4.2 The organization shall ensure that any person(s) under its control performing tasks that can impact on OH&S is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records. 4.4.3.2 The organization shall establish, implement and maintain a procedure(s) for: a) the participation of workers by their: appropriate involvement in hazard identification, risk assessments and determination of controls

A2. Specific to VPP. However, trainers should be qualified based on their knowledge, skill, and education. A3. Both systems require the determining of training needs for all employees.

A4. Both systems require that training is effective. Evaluation of the effectiveness must be evidenced.

A5. Both systems require a training process and objective evidence that all people working for or on behalf of the company have received proper H&S training. A6. Specific to VPP. However, trainers must be qualified.

4.4.1 Top management shall take ultimate responsibility for Health and Safety and

A7. Management and auditors must determine the effectiveness of the hazard identification and analysis process. A8. Management must have a thorough understanding of any/all

examples that demonstrate their understanding.

the Health and Safety Management System.

hazards of the worksite.