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The Definition of Voluntary Protection Programs (VPP)

OSHA's Voluntary Protection Programs (VPP) recognize employers and workers with effective safety and health management systems and injury and illness rates below their industry's national average.

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Voluntary Protection Programs (VPP) definition

Definition of Voluntary Protection Programs (VPP)

The Voluntary Protection Programs (VPP) are an OSHA recognition program for employers and workers who have built effective safety and health management systems and keep their injury and illness rates below the national average for their industry. Created in 1982, VPP is a cooperative program. Employers apply voluntarily, open their sites to a detailed OSHA review and agree to continuous improvement in exchange for recognition and exemption from programmed inspections.

VPP is not a regulation and does not change an employer's legal duties under the Occupational Safety and Health Act. Participants must still comply with all applicable OSHA standards. Many OSHA State Plans run their own VPP programs for employers under their jurisdiction.

OSHA's current rules for the program are set out in the VPP Policies and Procedures Manual, Directive CSP 03-01-005, which took effect on June 16, 2026.

VPP Recognition Levels

Star

The Star level is for worksites whose safety and health management system operates in a highly effective, self-sufficient way and meets all VPP requirements. Star sites must keep injury and illness rates below those published by the Bureau of Labor Statistics (BLS) for their industry. If a Star site's three-year rates rise above the national average, it must follow a two-year rate reduction plan approved by OSHA.

Merit

Merit is a stepping stone to Star. It is for employers whose systems show potential and commitment but need improvement. Merit sites set specific goals and must meet them within a set period to move up to Star.

Star Demonstration

The Demonstration program lets sites with Star-quality protection test alternatives to current VPP eligibility and performance requirements. Successful alternatives can lead to changes in VPP criteria.

Elite and Emeritus

The 2026 manual added two new distinctions. VPP Elite recognizes sites with 15 or more consecutive years of Star recognition that meet additional criteria. VPP Emeritus recognizes sites with 25 or more consecutive years of Star recognition.

Key Requirements

Safety and health management system

Under the 2026 manual, a participant's safety and health management system must include the seven core elements from OSHA's Recommended Practices for Safety and Health Programs (OSHA 3885 for general industry and OSHA 3886 for construction):

  • Management leadership.
  • Worker participation.
  • Hazard identification and assessment.
  • Hazard prevention and control.
  • Education and training.
  • Program evaluation and improvement.
  • Communication and coordination for host employers, contractors and staffing agencies.

Injury and illness rates

Applicants calculate their Total Case Incident Rate (TCIR) and Days Away, Restricted or Transferred (DART) rate, normally over the last three complete calendar years, and compare them to BLS national averages for their industry. Both rates are based on the OSHA 300 log, so accurate recordkeeping is essential.

Employee support

Applications must show the support of employees. At unionized sites, the applicant must provide evidence of support from the collective bargaining representatives, and if a union withdraws its support, the site no longer meets VPP requirements.

Annual self-evaluation

All participants must complete an annual self-evaluation of their safety and health management system and submit it to their OSHA Regional Office by February 15 each year. Applicants must complete at least one self-evaluation before approval.

How VPP Works

Application and on-site evaluation

After reviewing the written application, OSHA sends a team to the site. The on-site evaluation includes a records review, interviews with managers and workers, a walk-through of the facility and a closing meeting on findings. Teams include OSHA staff and may include Special Government Employees (SGEs), who are safety professionals from VPP sites trained by OSHA to serve on evaluation teams.

Ways to participate

  • Site-based: a fixed worksite, including certain long-term construction sites.
  • Mobile workforce: employers whose workers move between projects within a designated geographic area, such as construction contractors.
  • Corporate: a pathway for organizations with many sites. OSHA has noted that its corporate policy is being revised.

Benefits and limits

Approved sites are removed from OSHA's programmed inspection lists. They can still be inspected after complaints, fatalities, serious incidents or other events. Participants are re-evaluated on site periodically to keep their status.

Program direction

In 2025, the Department of Labor announced that OSHA would expand VPP as part of a broader self-audit initiative. The 2026 manual revision then aligned VPP with OSHA's recommended practices and added the Elite and Emeritus levels.

Example of Voluntary Protection Programs (VPP)

A chemical distribution center had kept its TCIR and DART rates below its industry average for several years and wanted outside recognition. Before applying, it ran its first annual self-evaluation against the seven core elements and found gaps in contractor coordination and in how worker suggestions were tracked.

After fixing those gaps, the site applied. The OSHA team interviewed dozens of workers, reviewed the 300 logs and toured the warehouse. It approved the site at the Merit level with two goals: formalize contractor safety orientation and improve follow-up on hazard reports. The site met both goals and later achieved Star status.

Frequently Asked Questions: Voluntary Protection Programs (VPP)

Is VPP mandatory?

No. VPP is voluntary. Employers apply because they want recognition and a cooperative relationship with OSHA.

Are VPP sites exempt from OSHA inspections?

They are removed from programmed inspection lists, but OSHA can still inspect them after complaints, fatalities, serious incidents and other unprogrammed events.

What injury rates are needed for VPP?

Star sites must keep their TCIR and DART rates below the BLS national averages for their industry. Sites with higher rates may qualify for Merit.

What changed in VPP in 2026?

Directive CSP 03-01-005, effective June 16, 2026, requires the seven core elements of OSHA's recommended practices and adds the Elite and Emeritus recognition levels.

Can construction companies join VPP?

Yes. Construction employers can take part through certain long-term site-based worksites or through the mobile workforce option.

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