OSHA’s SHARP and VPP Programs: An Interview with Mark Hurliman of Oregon OSHA

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If you’re interested in learning more about OSHA’s Consultative programs for safety management and safety excellence, you’ve come to the right article. This is an interview with Mark Hurliman, the VPP and SHARP Program Coordinator with Oregon OSHA, and Mark’s going to explain to all of us the basics of the VPP and SHARP programs for all employers in the US (federal and state plans).

There’s a lot to learn, so let’s more waste any more of your time. We’ve got a video of the discussion below for you. Plus, if you’d like to read instead, we typed up a transcript–just click the MORE button.

Introduction to Mark Hurliman, VPP, and SHARP

Convergence Training: Hi there, everybody. This is Jeff Dalto, Senior Learning & Development Specialist with Convergence Training, doing another one of our semi-regular webinar/interview/podcast series, and today we have an exciting guest.

We have Mark Hurliman, who is the VPP and SHARP Program Coordinator with Oregon OSHA, and he’s going to talk with us about OSHA Consulting Services and in particular VPP and SHARP.

Mark, hello, thanks for joining us, and I wonder if you could tell us a little bit about yourself.

Mark Hurliman: Thank you, Jeff. I guess I’m a safety professional–I’ve got a little bit more than 28 years in the field. I’ve been with Oregon OSHA now since 1990, first as a compliance officer and then as a consultant, and I’m a Program Coordinator now, I was a Program Manager for a number of years. They changed my title and gave me a raise and called me a coordinator.

I was raised on a dairy farm, I’ve been in construction as a laborer, a framer, a roofer, a commercial fisherman, truck driver, bridge builder, logger, heavy equipment operator, and a mill worker.

I’m certified through the National Safety Management Society as a certified safety and health manager, I’ve been that since 2003, and in Oregon I’ve been managing the voluntary compliance programs since 1996.

I manage the day-to-day operations of the VPP (or Voluntary Protection Program) and I assist Oregon OSHA consultants and the consultation management team with day-to-day operations of SHARP (Safety and Health Achievement Recognition Program).

If I could, I’d like to take just a minute to tell you I work for Oregon OSHA, not federal OSHA. In 1970, president Nixon signed the OSH Act, superceding all occupational safety and health programs in the nation and mandating that Americans should have a safe and healthy place to work. The Act allowed individual states to enact their own state-run programs as long as they would meet or exceed OSHA requirements, and in 1973 Oregon passed the Oregon Safe Employment Act and became the second state in the union to have a federally approved state plan.

So as we talk today, I’m going to talk a little bit about OSHA, meaning federal OSHA, but also about Oregon OSHA.

Another thing that I’d like to clarify up front, if I could, is that the Safety and Health Achievement Recognition Program (SHARP) is a consultation program that exists in all 50 states, and that the Voluntary Protection Program (VPP) is an enforcement program that also exists in all states. Both programs are run by OSHA or the state plans in their respective states. The programs are parallel, but they’re not connected.

The other thing I want to be clear about, and we’ll talk about it throughout this interview, is that SHARP and VPP are not the same thing as the VPPPA and the SHARP Alliance–people tend to confuse them.

So the VPPPA, the Voluntary Protection Program Participants Association, is a national, non-profit, 501(c)(3) charitable organization. It’s member-based, with a network of more than 2,300 companies or worksites that have achieved or are striving for occupational safety and health excellence.

In Oregon, the Oregon SHARP Alliance is also a member-based, non-profit organization comprised of Oregon employers who currently are part of SHARP or VPP or are working toward SHARP or VPP, and then other companies that are just interested in promoting safety and health at the workplace.

These are not the programs–they are organizations developed to promote the programs and assist companies in participating in the programs.

OSHA’s Consultative Programs

Convergence Training: OK, great, Mark. Thank you very much. A nice explanation of some of the other programs, a distinction between federal OSHA and Oregon OSHA, and also the organizations that are promoting these programs.

I wonder if you can tell us in general terms about OSHA’s Cooperative Programs–the names of several specific OSHA or Oregon OSHA cooperative programs, and the ones you work with most closely, which you’ve already touched on a bit already.

Mark Hurliman: OSHA’s cooperative programs include their Alliance Program, which is working with industry groups to prevent workplace fatalities, injuries, and illnesses. They have their consultation program, providing consultative assistance to employers who request them. They have partnerships providing stakeholders with avenues to improve safety and health while working with OSHA in a non-adversarial way. And then they have the VPP.

There are a couple more, but those are the MAIN ones.

OSHA considers SHARP to be a consultation-funded program, OK, and VPP to be an enforcement-funded program. So they don’t count SHARP as a quote-unquote stand-alone cooperative program, it’s within the consultation program.

In Oregon, I oversee both programs, SHARP and VPP, with the mindset that both of these programs are really about helping employers learn how to better manage workplace health and safety.

Convergence Training: OK, so there were three terms you called out and I wondered if you could define them within the umbrella of OSHA: (1) enforcement, (2) cooperative, and (3) consultative.

Mark Hurliman: So, OSHA is first and foremost a regulatory agency. The enforcement staff, that’s what they do. Consultation is a little bit newer. And what was the third one?

Convergence Training: Cooperative.

Mark Hurliman: Cooperative programs are something that, I won’t say is really new, but it’s part of OSHA’s trying to be kinder and gentler, we’ll put it that way.

Consultative Programs for State-Plan States and Federal OSHA States

Convergence Training: Alright, alright. One of my prepared questions was to ask if the SHARP and VPP programs you’re in charge of for Oregon OSHA are essentially the same for federal OSHA as well.

Mark Hurliman: Pretty much, yeah.

As a state plan, Oregon OSHA has to be as effective as OSHA. We do that in a number of ways, and we actually exceed them in many areas.

Our SHARP program operates slightly differently than the federal program, but we think in a good way. We’ve had more companies get into SHARP than almost any other state. In 2005, after we had been doing SHARP for about ten years, we saw the number of SHARP companies continually rising, and seeing that we only had a finite number of consultants, we decided that the SHARP program, if it was TRULY about employers becoming self-sufficient, that we needed to point an end-point to it. So, with the support of SHARP companies and the SHARP Alliance, we started to graduate companies from SHARP. Oregon is, so far, the only state in the nation that is graduating our participants after a set time in the program. In fact, just over half of Oregon’s VPP sites are SHARP graduates. Our program is not VASTLY different than the federal program–there are just some minor nuances.

Our VPP program is based on the federal VPP program. The differences there are mainly in how the programs are administered. We don’t have to worry about quite as much bureaucracy as federal OSHA does, so in a lot of ways our program is not as bogged down with approval and direction being shared between the regional and national offices. In Oregon, the administration is just a lot smaller. We still work closely with OSHA’s Region X and with OSHA’s national office. The expectations, aims, and qualifications of the program are virtually the same. I regularly meet with my counterparts regionally and nationally to ensure that we do stay similar. When they update their program, we follow suit and update ours accordingly. However, we also follow the Oregon Initiated Rules, which in most cases are more stringent than the federal program.

The most important thing I can say about either SHARP or VPP is that it’s really vital to contact your local regulatory agency up front, let them know that you’re interested in the program, and follow their direction. There will be minor differences jurisdictionally, from state-to-state, but the overall programs are really pretty similar.

A Four-Pronged Approach to Safety Management

Convergence Training: Alright, great, really good, Mark, thank you.

So before we dive deep and get detailed explanations of both SHARP and VPP, I have two general questions for you about both, partly based on the fact that I’ve seen you speak at conferences touching on these topics and also because I’ve reviewed some of the PowerPoint stacks you use to explain them.

I wonder if you could quickly explain to us what you call OSHA’s “four-pronged approach” for safety and safety management–I wonder if you could explain how these programs fit into that and really what that four-pronged approach is?

Mark Hurliman: OK. First of all, the four-pronged approach is my terminology for what I see as Oregon OSHA’s approach, in that we have basically four focus areas.

The Oregon OSHA administrator Michael Wood feels that the voluntary programs are an important part of OSHA’s balanced approach to workplace safety and health.

The first prong is our enforcement staff. Oregon OSHA, much like federal OSHA, is first and foremost a regulatory agency. It is our enforcement staff who serve as the regulators. A compliance officer’s job is to ensure to the extent possible a safe and healthful workplace for every worker in Oregon.

Our second prong is our standards and technical resources staff. They are the ones who develop, review, revise, interpret, and help publish the rules, and help Oregon OSHA staff and the general public understand the rules.

The next prong would be our training, education, and conferences staff, who provides internal staff and the general public with training and continuing education opportunities.

And the final prong is consultation, providing no-cost, consultative services to employers who request them. Consultation works with employers and their employees to enable those organizations to better understand and better manage workplace health and safety.

Three Phases of Safety Management Maturity

Convergence Training: Alright, great, thanks.

And earlier you mentioned that these programs are to help people with their safety management and safety management systems. I wondered if you could tell people out there who may not know those terms what “safety management” and “safety management systems” are and then, in addition, you talk three phases of safety management maturity.

Mark Hurliman: When I talk about safety maturity, I’m over-generalizing. But basically, over my history, I have seen three major and fairly distinct categories…maybe “maturity levels” isn’t a great way to put it…but different categories of employers.

In the first or most immature phase, the employer typically will believe that safety happens. It’s really not managed. They feel that safety is beyond their control. Workplaces with this kind of an attitude tend to de-value employees. They assume that workers are careless. They assume that accidents just happen. There tends to be very little safety accountability. Safety is not planned, and people tend to be blamed. And there’s not a lot of trust that the organization will do the right thing.

The second phase, or the next-most mature phase, is kind of that safety is required. They tend to have strict policies. Safety is mandated and discipline is used to keep it that way. These companies tend to have a lot of written rules and a lot of policies. They are still somewhat reactive when it comes to safety. These are the companies that are most likely to start using consultation, and a lot of times the first thing they’ll ask us is “Can you come out and OSHA-proof us?”

The third and most mature phase are the companies that have determined basically that safe is how we do it. They generally have a voluntary approach; safety is a shared responsibility with employees and leaders owning safety for themselves and for each other; safety is integrated into the business, it tends to be very proactive, collaborative, and self-corrective.

I’ve had a lot of companies ask me, basically, where their companies fit. And it’s really not an exact science. I would guess based on my experience that only 5-10 percent of companies fall into the first phase. In this day and age, very few people think that accidents just happen in a vacuum, and they really have no control over safety, but there are still a few.

The vast majority of companies are going to fall into the middle. They understand that safety is important, they understand that safety needs to be managed. You tend to see lots and lots of programs, policies, procedures, but the culture is not always where it needs to be.

I believe that very few, probably less than one percent, are in that most mature phase. Out of nearly 14 million employers in the country, only about 2,500 are in VPP and not quite that many are in SHARP. So we’ve got 14 million employers and less than 5,000 companies in these two programs. I am not saying that members of SHARP and VPP are the only companies that can get into this highest category, BUT all of the SHARP companies and all of the VPP companies certainly are in that upper echelon.

I have long felt and said that VPP companies are the best of the best and SHARP companies are the rest of the best. These processes help companies to better learn how to manage health and safety by helping them learn to incorporate certain safety and health principles into how they do business.

Both of these programs are voluntary, meaning nobody has to do it but anybody can do it. They’re not connected–you know, OSHA designed VPP back in 1982 from a compliance standpoint. SHARP came from a consultation standpoint. SHARP started in 1985 in Oregon and in 1996 on a national level. The programs are both designed to work differently, but they both encourage self-sufficiency in managing workplace health and safety.

In my mind, I think of SHARP as VPP’s little brother. A company can do only SHARP, or they can do only VPP, or a company can do SHARP and then VPP. But going from VPP to SHARP would be going backwards. So I don’t recommend that. But for many companies, I do recommend starting with SHARP, working through that process, and then moving into VPP.

More about SHARP

Convergence Training: I didn’t know that. OK, great intro to both of those programs. Next, then, let’s take a bit of a deep dive into “the best of the rest,” which is the SHARP program. What can you tell us, how can you sum up SHARP to us? What would you like us to know?

Mark Hurliman: The idea for SHARP came from a 1994 OSHCON meeting, and OSHCON is occupational safety and health consultation, nationwide. And the basic premise of the meeting was “OK, this VPP thing is working and working well for bigger companies, why can’t we design something similar for smaller companies who could use OSHA consultative services to help them get to a measurable level of self-sufficiency?”

Side note: This OSHCON website explains OSHCON this way:

The National Association of Occupational Safety and Health Consultation Programs, also known as OSHCON, is a professional resource for the OSHA Consultation programs and the small employers they serve. OSHCON’s membership consists of OSHA Consultation program management from every U.S. state and territory.

To better understand what OSHCON is all about, it’s important to see the “big picture” as it applies to the OSHA Consultation programs. The OSH Act of 1970 created the onsite consultation programs to help small businesses better understand OSHA regulations and find feasible compliance solutions. Because small businesses frequently lack the expertise and resources necessary to properly identify and remedy serious safety and health problems in their workplaces, the free, confidential help provided by OSHA-funded consultation programs are tremendously important to the ultimate goal of protecting America’s workers. The onsite consultation programs operate independently from OSHA enforcement and are facilitated via cooperative grants between OSHA and one designated agency in each state, all operating under the federal regulation 29 CFR 1908.

So SHARP is really designed for smaller companies–less than 250 at a site, less than 500 corporate-wide. To make use of Oregon OSHA consultation to help them learn how to better manage health and safety. Now, if you’re not in Oregon, it could be a state consultation plan elsewhere, or if that state is a federal program state, those are generally run through a college in that state.

So the consultants will come in at your request, evaluate your safety and health management programs by assessing 58 individual items, or attributes, we call them, that fit into several different elements of an effective safety and health management system.

An effective safety and health management system is going to have these major elements: (1) management leadership; (2) employee participation; (3) a system of hazard identification and assessment; (4) a system that lets us control and prevent hazards; (5) a system of safety and health training; (6) and a system that allows us to evaluate our program and continually improve it.

The consultants will also assess your communication and your coordination with other applicable employers you might be working with–contracted employees or temporary employees or other employers or employees who are sharing the same worksite. If those cases are going on, then there needs to be some good communication and coordination.

The consultants, though, at the end of this 58-item assessment, are able to let you know what your strengths are and what your weaknesses are. Then they help you to develop an action plan to use your strength to improve on your weaknesses.

The SHARP program quite literally is a series of consultations where we come in and health you improve your safety and health processes incrementally to a point where we can say “Yes, you’re a SHARP employer.” Once an employer is certified as SHARP, in Oregon then we have a year to maintain and improve, consultation will come back annually to re-assess and re-evaluate, and if the SHARP employer is found to be still improving, then they’re awarded SHARP for another year, and this time they get an exemption from the routine scheduled inspections. After four years, in SHARP, in Oregon, employers can graduate from the program. They will get one final, three-year exemption.

So there are two major differences between Oregon’s program and the SHARP programs with other states. First,the exemption in Oregon is earned, it is not given. You have to be SHARP for a full year, and qualify for SHARP again for the next year, before you are given the exemption. Federal OSHA and some of the other states will actually give you the exemption just for saying that you’re willing to try. Federal OSHA grants exemptions based on the company saying they want to work toward SHARP, and we don’t do that. Oregon tends to be a tough state, we have high standards, and we expect you to meet or beat those standards in order to qualify for SHARP or for VPP. As one of our former administrators used to say, “We upped our standards, now up yours.”

Convergence Training: OK, so that’s good. Mark, I’ve got one quick follow-up for you about the SHARP program before we move on to VPP.

You mentioned it’s primarily intended for smaller companies, but you also mentioned it’s available for employers to use as the “baby brother” program and then graduating and completing VPP later.

Are big companies allowed in for that circumstances? Or is there a size cap?

Mark Hurliman: In the federal states, there’s a cap: 250 employees and smaller site-wide, 500 employees and smaller corporate wide. In Oregon, we have developed what we call the partnership process, for SHARP partners, where a bigger company, a multi-site company, can enter into a partnership agreement with us, where we teach them a little bit on how to do SHARP and we help them, but we expect them to take much more of a leadership role. So we train some of their staff, their staff then evaluates their sites and gets them to a point where they can make the recommendation to us.

We’ve had varying levels of success with the process; we’ve improved it over the years based on what we’ve learned, and it’s working fairly well. It works in certain industries better than it does in others, and we’re learning as we go.

More about VPP

Convergence Training: OK, that’s good–continual improvement.

So if that was SHARP, the best of the rest, and VPP is the best of the best, what do you want us to know about VPP?

Mark Hurliman: OK. Well, VPP has been around since 1982. It is the nation’s premiere safety and health management recognition program. The ANSI Z10, the OHSAS 18001, and the ISO 450001 were all based in large part on the success of VPP, and they incorporate most if not all of the elements of VPP.

Side note: Read more on ANSI Z10, OHSAS 18001, ISO 45001, and similar safety and health management standards. You can also read our Introduction to the ISO 45001 Safety and Health Management Standard.

At its heart, VPP is a program that leads to enhanced worker safety and health by promoting excellence and continuous improvement in safety & health management. VPP requires a cooperative approach between labor, management, and government by promoting excellence and continuous improvement. VPP is built on major elements of management leadership and employee involvement, worksite analysis, hazard prevention & control, and safety and health training. VPP has been described as a road map, or a guide, to an enhanced way of doing business or a stable operation.

You apply for VPP by submitting an application. That application gets reviewed to see if those things that can be documented are there and if you look like you could be qualified. If not, we ask for more information or ask you to withdraw and try again with some coaching. But if we find that you’re ready, we can accept your application and we will schedule a week-long, pre-approval, onsite assessment, during which we come in and review your programs, your policies, your procedures, your injury and illness records, interview employees, observe work practices and work conditions.

And at the end of that audit, we let you know where you stand. We CAN give you up to 90 days to fix or improve some things, but at the end of that 90-day deferral, you would be qualified as a VPP Star site or a VPP Merit site.

Basically, your application tells us how good you think you are, and then we come in and tell you if you’re really as good as you thought you were.

Convergence Training: Great. So, if that’s SHARP and VPP, what would be your “elevator pitch” I guess to an employer? How can these programs help employers and why should they consider applying?

The Benefits of VPP & SHARP

Mark Hurliman: That’s a good question.

I think the simple answer is that these two programs help management and employees become synchronized in safety. Everybody has the same shared goal, and everybody can work toward that shared goal. Everybody starts then to take on ownership of safety, and everyone starts to take on the responsibility for their safety as well as their coworker’s safety.

Once you get all the horses pulling in the same direction, things start moving and momentum starts building. That in turn translates into an improved safety culture, which positively affects the rest of the business.

Much like any worthwhile endeavor, the end result isn’t really as important as the journey. The process of obtaining SHARP or obtaining VPP is going to prompt your company to change, to stretch, to improve in a myriad of ways. The strategies, techniques, and processes that you learn in obtaining SHARP and VPP are successful strategies, techniques, and processes. These successful techniques get repeated because they work, because they bring you success, and then repeated techniques start to become habits. So success breeds more success, and the improvements made in safety then start to foster improvements in productivity, in quality, in team work, in job satisfaction.

And that, I think, is the reason these programs are successful. Companies get more improvements out of the programs than they were expecting going in because the reasons they get better at safety translate directly into the reasons they get better at doing what they do.

At the end of the day, both SHARP and VPP enable your company to have a positive culture change, which then enables you to do everything else better. If a company wants to be recognized for its efforts in providing and maintaining a safe place of employment, these two programs are the OSHA programs that do that.

Side note: Check out this article on Safety & Operational Learning.

Where to Learn More about VPP and SHARP

Convergence Training: I love that. I love how you were talking about breaking down silos and, I’ve been doing a lot of work trying to figure out how “Safety” can contribute to the development of a learning organization, so it looks like you’re on the same path on that.

Side note: Check out this article on Safety and the Learning Organization.

So how can people and employers learn more about SHARP and VPP? They’ve heard this webinar and they’re all fired up–what can they do next?

Mark Hurliman: The simplest way, I think, is just going online and researching either SHARP or VPP. I strongly encourage companies to look to their own jurisdictions first-for example, if you’re in Arizona, call them in Arizona, don’t call me (in Oregon)…you’re going to get better information from them.

Try to talk with and try to mentor with local VPP and/or SHARP companies. If you’re in Oregon, simply type in osha.oregon.gov, click on “Consultative Help,” and then you can look directly at the SHARP program or the VPP program.

If you’re in an OSHA state, you would just type in osha.gov and then search for either SHARP or VPP.

If you’re in another state-plan state, just depending on which state it is, go to your jurisdiction’s web page and look there.

Another place to learn and to get more help is through the associations for each program. The VPPPA is a huge national organization, they’ve got ten different regional sub-groups that are all about trying to help companies get into VPP.

The Oregon SHARP Alliance, sharpalliance.org will take you there, is another member association of SHARP companies and VPP companies in Oregon who are dedicated to helping other companies achieve SHARP and/or VPP. When the SHARP Alliance started in 2000, they were just SHARP companies. But by 2010, they looked at their membership and

Jeff Dalto, Senior Learning & Performance Improvement Manager
Jeff is a learning designer and performance improvement specialist with more than 20 years in learning and development, 15+ of which have been spent working in manufacturing, industrial, and architecture, engineering & construction training. Jeff has worked side-by-side with more than 50 companies as they implemented online training. Jeff is an advocate for using evidence-based training practices and is currently completing a Masters degree in Organizational Performance and Workplace Learning from Boise State University. He writes the Vector Solutions | Convergence Training blog and invites you to connect with him on LinkedIn.

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