Assistant Secretary of Labor For OSHA, John Henshaw, confirmed in a speech to the Voluntary Protection Programs Participants' Association (VPPPA) last week that OSHA is on-course to increase participation in the Voluntary Protection Program (VPP) from 800 participants two years ago, to 8,000 sites. Currently, there are 1,000 VPP sites.

VPP, started in 1982 during the Reagan administration, recognizes worksites,typically with injury and illness rates below average for their industry sector, that have safety and health programs with specific features that exceed OSHA standards.

As I reported last April, however, the Government Accountability Office has grave misgivings about OSHA's failure to evaluate the effectiveness of the program and the resources that would be needed to support such an expansion. The report points out that to certify a worksite as a VPP worksite requires a comprehensive on-site review that usually lasts 1 week and involves approximately three to five OSHA personnel. As OSHA's pie is not expected to grow substantially, GAO fears that the resources needed for such an expansion may come at the expense of enforcement.

But John Henshaw is a glass-half-full kind of guy:

In 2002, the 625 VPP participants under Federal jurisdiction had a total case incidence rate for injuries and illnesses that was 53% below their respective industry averages. Had they been at their national average, we estimate they would have experienced 10,532 more recordable injuries and illnesses, costing a total of 3 million dollars.

Now, if we maintain the same performance rate, which we must, the 8,000 VPP participants will result in an estimated 96,000 injuries and illnesses avoided, and 2.7 billion dollars saved.

Wow, not bad! 96,000 injuries and illnesses avoided as a direct result of the VPP program.

But not so fast, says GAO. Seems we've got a little cause-effect problem here. It turns out that despite Henshaw's rosy scenario, OSHA hasn't quite made the connection between participation in VPP and the reduced injury and illness rate. Maybe these companies were better than average before joining VPP. Although the agency has commissioned a study to conduct an evaluation of the changes in participating employers’ injury and illness rates resulting from the program, GAO is not confident that the study will develop useful results:

The evaluation, to be completed in September 2004, will evaluate the impact of VPP from the point at which employers decide to apply for VPP until they are designated a VPP site. It will also determine the impact of VPP on other worksites through participating employers’ outreach and mentoring efforts and provide data on dollars spent by VPP sites on safety and health programs and cost savings from reduced workers’ compensation costs. However, because VPP does not require applicants to provide data on their injury and illness rates for the years prior to participation, OSHA will still be unable to systematically assess whether improvements in their injury and illness rates resulted from program participation.

But hey, this is the Bush administration. Why let a little lack of evidence deter you from where you've already decided to go?