September 6, 2017
U.S. Department of Labor
OSHA Docket Office Room N-3653
200 Constitution Avenue, NW
Washington D.C. 20210
Re: Docket No. OSHA -2017-0009
To Whom It May Concern:
The American College of Occupational and Environmental Medicine (ACOEM) is pleased to respond to the request for comments on the future direction of the U.S. Occupational Safety and Health Administration’s Voluntary Protection Programs (VPP). ACOEM is an organization of more than 4,000 occupational physicians and other health professionals dedicated to promoting optimal health and safety of workers, workplaces and environments.
The VPP represents a valuable program and should be retained. ACOEM has had experience with recognizing employers who document and improve their health and safety programs through our Corporate Health Achievement Awards (CHAA), and believes that a cooperative approach to planning and quality improvement pays large rewards. Of course, ACOEM expects that OSHA will also adequately fund compliance activities, even as it chooses to sustain or enhance VPP.
The Corporate Health Achievement Award (CHAA) recognizes organizations with exemplary health, safety, and environmental programs. Participating organizations submit a comprehensive application about their program and undergo a rigorous review by an expert panel to assess four key categories: Leadership and Management, Healthy Workers, Healthy Environment, and Healthy Organization. Awards have been given to deserving organizations in manufacturing and service sectors, including city health departments, federal agencies, and health care systems.
The CHAA application process gathers detailed, and useful, information about the corporate governance structure and management’s commitment to health and safety, and may have useful lessons for VPP. Additional information on CHAA is available on the ACOEM website at www.acoem.org.
ACOEM does not agree that past VPP awardees should no longer be eligible to participate. In our experience with CHAA since 1997, we have found that periodic renewal of an award status tends to sustain an employer’s gains in workplace health and safety. As our CHAA field staff have observed, when incentives are not maintained, some employers will “fall off the wagon.”
ACOEM is pleased to offer the following recommendations for OSHA’s consideration.
1) ACOEM encourages that the VPP recognition and review process place an emphasis on corporate programs that promote "Best Practices" in the work setting which focus on the overall health and life improvement options when incorporated into the one place where a worker may spend the majority of their waking hours, their work. Furthermore, realizing that lifestyle issues have created population risks from social ills such as obesity, the aging workforce, and deconditioning, we feel it is vital for the VPP program to place emphasis in its guidelines, on integrating present with future risk, utilizing the benefits of occupational and preventative medical resources.
2) For employers, whose workplaces fall within the scope of an OSHA standard requiring medical surveillance, ACOEM recommends that medical expertise and medical participation be documented as part of the management structure, and not simply as a service vendor. That is, ACOEM believes that for such employers, documentation that physicians with OEM expertise are part of the senior management.
3) ACOEM recommends that OSHA consider incorporating elements into the VPP application related to worker “well-being” or “workplace wellness.” In a 2011 paper titled Workplace Health Protection and Promotion: A New Pathway for a Healthier—and Safer—Workforce, Hymel, Loeppke, Baase, et al, described the integration of health protection and health promotion as a continuum, in which “health promotion interventions contribute dynamically to improved personal safety in addition to enhancing personal health, while occupational safety interventions contribute dynamically to improved personal health in addition to enhancing personal safety. The two factors, personal health and personal safety—each essential to a productive worker and to a productive workplace—are effectively combined in a symbiotic way that increases their impact on overall health and productivity. The whole becomes greater than the sum of its parts.” Stated simply, workplace health protection and promotion is the strategic and systematic integration of distinct environmental, health, and safety policies and programs into a continuum of activities.
Currently, most workplace health protection programs (i.e., safety and work environment) are separated from workplace health promotion (WHP) programs (i.e., wellness and disease management). The two are often housed in completely distinct organizational divisions with health protection often residing in non-health-oriented units and health promotion initiatives a function of human resources or benefits. These programs are usually run as distinct, separate activities, with minimal attempts at integration. This lack of integration prevents optimal resource utilization and impedes efforts to maximize the overall health and safety of the workforce.
Organizations, whether large or small, can engage in this new strategy by systematically integrating their health promotion safety and environmental programs, policies, and processes. Activities in corporate in workplace health protection and promotion are diverse and reflect a wide range of functions and goals. Examples include assessing worker health status, addressing personal health risks, the early recognition and treatment of injury or illness, job safety initiatives and efforts to create cultures of health and safety, disability prevention and return-to-work programs, emergency preparedness planning, and behavioral health and environmental safety initiatives. While these may appear to be diverse approaches, they are all aimed at the same thing: promoting overall health and preventing workplace injuries and illnesses.
In an effort to better understand how the environment for integrating health and safety in the workplace has changed over the last several years and to seek new ways of advancing the concept, ACOEM and UL hosted a summit meeting during the summer of 2014 that comprised experts from corporate, governmental, not-for-profit, educational, and research organizations. Over the course of 2 days, the 21-member group identified several key factors that, if addressed, could help create a more favorable environment for advancing the principles of health and safety integration in the United States: determining why health and safety integration is important and how it should be defined; formulating what should be measured to evaluate the impact of IHS programs; and describing how employers can systematically develop and implement IHS programs.
The VPP provides an opportunity for OSHA to provide employers with voluntary guidelines for integrating traditionally independent health protection and health promotion activities. The evidence shows that this will create synergy and enhance the over-all health and well-being of the workforce while decreasing the likelihood of workplace injuries and illnesses.
If you should have any questions or need additional information, please contact Patrick O’Connor, ACOEM’s Director of Government Affairs, at 703-351-6222. Thank you for your consideration.
Charles M. Yarborough III, MD, MPH, FACOEM