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OSHA’s Voluntary Protection Program (VPP) historically required a 4-element Safety and Health Management System (SHMS). In June 2026, OSHA updated the VPP framework to align with its current 7-element Safety and Health Management System model, which is based on OSHA’s Recommended Practices for Safety and Health Programs. [safetyandh…gazine.com], [ihmm.org]

Old VPP Model (4 Elements)

  1. Management Leadership and Employee Involvement
  2. Worksite Analysis
  3. Hazard Prevention and Control
  4. Safety and Health Training [in.gov]

New VPP Model (7 Elements)

  1. Management Leadership
  2. Worker Participation
  3. Hazard Identification and Assessment
  4. Hazard Prevention and Control
  5. Education and Training
  6. Program Evaluation and Improvement
  7. Communication and Coordination (host employers, contractors, staffing agencies) [safetyandh…gazine.com], [ihmm.org]

What Changed?

1. Management Leadership and Employee Involvement Split Into Two Elements

Old: One combined element.

New:

  • Management Leadership
  • Worker Participation

OSHA is emphasizing that leadership commitment and worker engagement are equally important and should be evaluated separately. [ihmm.org], [safetyandh…gazine.com]

2. Worksite Analysis Became Hazard Identification and Assessment

Old: Focused on inspections, hazard analysis, and recognition.

New: More explicit emphasis on:

  • Identifying hazards
  • Assessing risk
  • Continuous monitoring
  • Risk-based decision-making

This aligns VPP more closely with modern safety management systems such as ISO 45001. [ihmm.org], [safetyandh…gazine.com]

3. Safety and Health Training Expanded

Old: Safety and Health Training

New: Education and Training

The change broadens expectations to include:

  • Competency development
  • Leadership training
  • Worker education
  • Contractor education

Not just compliance training. [ihmm.org], [safetyandh…gazine.com]

4. Program Evaluation and Improvement Added

This is a completely new standalone element.

OSHA now expects organizations to demonstrate:

  • Formal program reviews
  • Performance metrics
  • Internal audits
  • Corrective actions
  • Continuous improvement processes

Organizations already using QAPI, Kaizen, or PDCA methodologies will have an advantage here. [ihmm.org], [safetyandh…gazine.com]

5. Communication and Coordination Added

Another new standalone element.

Focuses on:

  • Contractors
  • Temporary staffing agencies
  • Vendor coordination
  • Multi-employer worksites
  • Information sharing and hazard communication

This is especially important where multiple employers or contractors work on the same site.

 

 

 

 

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