Q: What is the OSHA Voluntary Protection Program (VPP)? Is it applicable to cleanrooms and other controlled environments?
A: Yes, the Voluntary Protection Program is applicable to cleanrooms and other controlled environments. The VPP recognizes operations that have implemented effective safety and health management systems and maintain injury and illness rates below the national average for their industry.
Companies with cleanrooms and/or controlled environments have implemented policies and procedures to protect the product, the cleanroom, and/or the controlled environment. These policies and procedures are based on industry standards such as the Institute of Environmental Sciences and Technology (IEST) recommended practices for contamination control, design, testing, engineering, and product reliability, or the ISO 14644 series of international standards for cleanrooms and controlled environments.
These companies have also implemented policies and procedures to ensure that product quality is consistently aligned with customer quality specifications for every batch lot of the product. These quality policies and procedures are often based on principles of Lean Six Sigma, Lean Manufacturing, and/or the ISO 9001 quality management standard. Compliance with the above standards enables the companies to meet other regulatory industry standards, such as the FDA Code of Federal Regulations, and USDA and EPA regulations.
It is a logical progression that companies with cleanrooms and/or controlled environments would establish and implement health and safety management programs to protect the people working in the cleanrooms and controlled environments. In light of shared goals regarding product quality, cleanroom/controlled environment integrity, and employee safety, a cross-functional working group is established with members with the above knowledge and skill sets. Consulting groups exist for each of the three disciplines listed above; however, when the procedures and policies are developed within an organization, implementation and maintenance are more successful because of the ownership, pride, dedication, and perseverance of the participants. Once the health and safety management program is implemented and proved to be effective, a company may apply for the VPP. Approval signifies OSHA’s official recognition of the outstanding efforts of employers and employees who have achieved exemplary occupational safety and health.
The basis for the VPP is in Section(2)(b)(1) of the Occupational Safety and Health Act of 1970, enacted “to assure so far as possible every man and woman in the Nation safe and healthful working conditions and to preserve our human resources 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.”
Beyond product protection
Organizations with cleanrooms and/or controlled environments are familiar with the requirements for protective apparel to protect the product from cross-contamination. An effective health and safety management program builds on this tenet by providing PPE that safeguards workers as well. This is just one example of perfecting an existing program to provide more safe and healthful working conditions.
The VPP has established performance-based criteria for a managed safety and health system. Companies apply for VPP certification. OSHA reviews the application and performs an on-site verification audit to provide documented evidence of compliance to the established criteria. Three levels of approval exist:
• Star. Recognition for employers and employees who demonstrate exemplary achievement in the prevention and control of occupational safety and health hazards, and in the development, implementation, and continuous improvement of their safety and health management system.
• Merit. Recognition for employers and employees who have developed and implemented good safety and health management systems but who must take additional steps to achieve Star quality.
• Demonstration. This program enables OSHA to test the efficacy of different approaches.
If your cleanroom and/or controlled environment company is a small business with limited corporate resources, you may also be eligible for OSHA’s SHARP program. The On-site Consultation Program’s Safety & Health Achievement Recognition Program (SHARP) recognizes small-business employers who operate an exemplary injury- and illness-prevention program. Acceptance into SHARP officially recognizes your business as a model for safety and health in your industry. When a company receives SHARP acceptance, OSHA exempts it from programmed inspections while the SHARP certification is valid, which is usually a two-year period.
Integrating quality and safety
Just as a cleanroom-management program is designed to protect the integrity of the cleanroom and/or controlled environment and the products manufactured there, and a quality management program is designed to assure the consistent high quality of the product, an effective health and safety management program is designed to protect the workers from all health and safety hazards in all company facilities.
The benefits of combining the three management programs are numerous. In addition to repeatedly producing high-quality products, companies will increase profitability by:
• Reducing worker compensation insurance premiums.
• Improving worker retention and reducing worker turnover.
• Reducing employee absences to keep production on schedule.
Integrated management creates a culture where a high-quality product is produced the first time, every time, and where a safe, hazard-free working environment is often transferred to employees’ homes. Such a culture boosts worker morale, improves communication throughout the organization, and attracts skillful workers because they realize that your organization is a “leader in their industry.” Empowered and engaged workers also contribute to profitability and often become ambassadors for the company within the community.
Product quality control, environment management, and employee safety programs individually achieve their required directives. However, when integrated, implemented, and maintained, a harmonized program creates a profitable, safe, and healthful work environment that consistently ensures high overall results.
Richard Gerlach, senior director of safety and health at Cintas Corp., states, “The OSHA Voluntary Protection Program provides companies with an opportunity to improve employee-partner ownership of their safety improvement process. Under the VPP program, front-line Cintas employee-partners work directly with management toward the common goal of eliminating workplace injuries. In addition to achieving safety excellence, our VPP locations have lower turnover, are more productive, and enjoy a higher level of partner engagement. I am proud of the fact that we now have 12 Cintas facilities that have earned VPP recognition for their high-performing safety culture.”
Jan Eudy is a technical resource for ESD, cleanroom, food, and healthcare garments and products. At Cintas, she directs the quality system and ISO registration for cleanrooms and supports validation and sterile services. She is President Emeritus and Fellow, Institute of Environmental Sciences and Technology.
This article appeared in the February 2013 issue of Controlled Environments.