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Initial Insights into OSHA’s Updated VPP Policies and Procedures Manual

Initial Insights into OSHA’s Updated VPP Policies and Procedures Manual

Understanding the Transition from Four to Seven Core Elements

17 July 2026

Yesterday, VPPPA Chairperson Terry Schulte sat down with Arlene Williams, Acting Director for OSHA’s Directorate of Cooperative and State Programs, to walk webinar attendees through the key changes proposed to the “Voluntary Protection Programs (VPP) Policies and Procedures Manual,” as outlined in OSHA directive CSP 03-01-005 (published June 16, 2026), as well as to answer questions fresh on the minds of those in the process of applying for or maintaining VPP status. 

The directive revises the VPP Safety and Health Management System (SHMS) requirements to align with the seven core elements in OSHA’s “Recommended Practices for Safety and Health Programs.” Formalizing the key principles of the “Recommended Practices” framework, the new directive marks an expansion of the 2008 directive’s requirements and a commitment to ensuring these sites continue to represent best in class safety practices.

As Williams clarified during the webinar: “While this is a change and is different, it really doesn’t change what you’re reporting—it more so changes how you’re reporting.” The purpose of VPP remains the same, and the core elements remain as an expectation of participation; the modified directive reorganizes and expands on those existing core pieces while implementing additional requirements that reflect safety best practices.

One of the main questions OSHA has received from worksites across the country since publicizing the proposed changes to VPP’s core elements has regarded the forms that evaluation teams should use to evaluate and document compliance with the requirements outlined in the new directive while awaiting the updated site-based participation report to be published. 

Williams advises that OSHA is “in the process of finalizing those forms and getting them through the clearance process.” “Until then,” she adds, “worksites should continue to use the existing forms that they are using. If you’ve already started a process as a part of your work, then you should continue to use those forms. When the new forms become effective, we will make sure that we make everyone aware and they will be effective going forward and not retroactive.”

One focus area of the new manual is its repeated emphasis that successful VPP sites must demonstrate meaningful employee participation, which is consistent with VPP’s origins as a cooperative management–employee partnership rather than a top-down compliance program. 

The manual likewise further emphasizes the necessity of evidence that the system actually produces safer workplaces, which takes into consideration factors such as low injury and illness rates, active hazard identification, and effective corrective actions. But it also places emphasis on qualitative criteria, such as site management’s commitment to maintaining a safe workplace environment—and a demonstrated interest in continuously improving that environment—as well as employee trust in that effort.

In addition to the expansion of core elements, OSHA has also outlined requirements for achieving a new pinnacle of VPP excellence through their recognition of Elite and Emeritus status. These higher levels of distinction will honor sites with long-standing track records of workplace safety excellence and commitment. Participation in this recognition category is optional. Sites at companies that obtain recognition at this level have shown a consistent commitment to VPP and have created strong relationships with OSHA. One purpose of the creation of these distinctions is to “ensure that these strong relationships continue.”

The new requirements, all this is to say, make CLEAR OSHA’s investment in further cementing VPP’s role as a marker of excellence—recognition that a worksite has proven its commitment to exceeding baseline requirements and reflecting best in class safety and health practices in the interest of promoting the wellbeing of its employees. 

While we at CLEAR have developed the only purpose-built, digital solution to supporting VPP processes using the existing four element-framework, we are also—like so many others—eagerly anticipating the finer details of the new requirements to become available to the public, at which time we will update our system to reflect OSHA’s changes to VPP’s updated site-based evaluation report and annual self-assessment, migrate client data into that updated system, and onboard our subscribers into the revamped platform. 

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