Here are comments from Davis Layne, executive director of the Voluntary Protection Programs Participants’ Association, Inc., presented to OSHA officials at the OSHA Listening Session, March 4, 2010, Washington, DC:

“While enforcement only addresses one of the objectives of the OSH Act, the Voluntary Protection Program was established on the foundation of cooperation between employer and employee to establish a safe workplace.

“VPP is more than a recognition program. It builds on the cooperation between management, labor and the government in a joint effort to go above and beyond OSHA standards to protect workers from unaddressed, inadequately addressed and emerging hazards.

“Unlike enforcement, VPP is a safety and health management system that addresses real problems in real time, leading the way for more current safety and health program standards.

“For instance, VPP addresses ergonomics as a recognized hazard in the workplace and also fulfills the requirements of recordkeeping as focused upon in OSHA’s current National Emphasis Program.

“Furthermore, acting as a force-multiplier, VPP frees up resources for OSHA as VPP site representatives become ambassadors for safety and health excellence, engaging in outreach and training so that other sites can improve their safety and health as well.

“VPP works! Our members tell us that, previous administrations tell us that, the GAO report that was critical of the oversight of the program tells us that and both Secretary Solis and Assistant Secretary Michaels have publicly declared that they see the value of VPP.

“Furthermore, in talking about the future of OSHA and the need for a more progressive, dynamic partnership where industry takes the lead and helps develop higher standards, what we are really talking about is VPP.

“VPP is a win-win program. Government benefits by protecting the American workforce, saving money and fulfilling the mission of OSHA. Employers benefit from lower injury and illness rates, saving money and increasing productivity, making them more competitive in the global market.

“On April 26, 2007, in a statement to the subcommittee on employment and workplace safety, U.S. Senate Committee on Health, Education, Labor & Pensions, David Michaels himself stated:

“’OSHA enforcement does not appear to be effective in further reducing injury rates.’ Michaels continued, ‘In all of its voluntary programs, like the Voluntary Protection Programs (VPP) and its ‘alliances,’ OSHA emphasizes the importance of employers providing a safe workplace, not merely meeting the specific requirements on all of OSHA’s rules. This is as it should be, and, more than anything else, this is the message that should go to all employers.’

“We can all agree with the fundamental importance of enforcement, but also know its limitations.

“If we all recognize the exponential impact VPP and other cooperative programs have on workplace safety and health, why take funding away from VPP to put into enforcement?

“With a $10 million increase for enforcement in the proposed FY2011 budget, this is not a question of scarce resources but an issue of policy.

“Two of the three stakeholders – management and labor – are committed to this partnership and are working vigorously toward continuous improvement in occupational safety and health, living the vision of a new OSHA as described by this administration.

“The third partner seems to be pulling out, which is an entirely different message being sent to employers and workers.

“With VPP benefiting workers, companies and the agency, how is pulling the administration’s support and direct funding a sound decision that makes good economic sense?”