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Pursuing OSHA 'Star' Status

PPL Corporation’s 109-MW Holtwood hydro project is the recipient of the highest safety recognition given in the Occupational Safety and Health Administration’s voluntary protection programs. The “Star” status acknowledges PPL’s efforts to go beyond minimum OSHA requirements to protect worker health and safety. PPL is working to achieve this recognition at all of its facilities.

By N. Christian Porse and M. Edward Ruth

PPL Corporation is proud of the fact that its 109-MW Holtwood hydroelectric project on the Susquehanna River south of Lancaster, Pa., is one of the first hydro facilities in the U.S. to achieve “Star” status under the Occupational Safety and Health Administration’s (OSHA) Voluntary Protection Programs (VPP). Star work sites are an elite group, with only about 1,400 of the more than 7 million work sites OSHA monitors having achieved that level of recognition under the VPP.

OSHA established its VPP to promote effective and comprehensive work site-based safety and health programs. Through the VPP, OSHA sets performance-based criteria for a managed safety and health system, invites sites to apply, and then assesses applicants against the criteria.

The first work site in the U.S. received VPP certification in 1982. Within the VPP, “Star” certification is the highest recognition. Other levels are “Merit” and “Demonstration.”

Holtwood earned Star certification in 2002. OSHA visits the site every three years for evaluation; OSHA renewed Star status for Holtwood in 2005.

Background on Holtwood

The Holtwood plant began generating electricity in 1910. By 1924, the plant was expanded to its present ten-unit configuration. The plant employs about 15 people. The plant included a coal-fired generating unit until 1999.

The 55-foot-high, 2,392-foot-long dam impounds 2,400-acre Lake Aldred, a popular boating and recreation area. In addition, the PPL-owned Holtwood Environmental Preserve provides lakeside recreational opportunities and facilities for camping, hiking, picnicking, boating, sightseeing, fishing, and hunting on more than 5,000 acres around the lake. A pair of bald eagles has nested on a PPL transmission tower near the dam for the past seven years, attracting visitors and wildlife enthusiasts to the dam and the wildlife preserve.

Through upgrades and a solid maintenance program, PPL has kept the Holtwood dam and power plant in excellent condition. Improvements include installing new turbine runners and main transformers, upgrading electrical systems and protection and control systems, generator rewinding, and replacing the governor hydraulic system.

Deciding to pursue Star status

OSHA created the VPP in the early 1980s. Work sites certified under the VPP generally experience 50 percent fewer lost workday injuries than average work sites in their industries. PPL was attracted to the VPP because going beyond compliance with industrial safety regulations has been part of the company’s way of doing business for many years.

The VPP fit well with PPL’s corporate safety policy, which states: “No job we do or service we perform is so urgent that we cannot take the time and use the necessary equipment to do it safely.” To this end, employees at each plant must learn from their safety experiences and the industry’s, and share that information with employees at other PPL plants to achieve continuous improvement. PPL controls about 12,000 MW of generating capacity in the U.S. Twenty of its 36 generating facilities are hydroelectric power plants, located in Pennsylvania, Montana, and Maine.

Getting certified

PPL started the VPP Star certification process at Holtwood in 1998 as a way to benchmark safety efforts against OSHA’s highest standards.

Personnel from the plant’s safety and health committee and from safety operations formed a team to work on the certification process. This team, in conjunction with other in-house safety pro- fessionals, inspected the site for physical hazards and OSHA compliance issues. Initially, Holtwood’s incidence rate (which included safety issues occurring prior to 1999) was too high to file an application for certification. While plant personnel corrected identified deficiencies and enhanced safety processes, the safety operations representative began compiling applicable documentation. This included: safety philosophy, safety manuals, safety statistics, site inspection forms, safety training programs, contractor guidelines and orientation programs, and other forms of safety information.


Employees at PPL’s 109-MW Holtwood hydro facility celebrate receiving certification as a “Star” work site under the Occupational Safety and Health Administration’s (OSHA) Voluntary Protection Programs. This certification has been given to only about 1,400 of the 7 million work sites OSHA monitors.
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For the VPP, OSHA focuses on leadership and employee involvement, hazard prevention and control, and work site analysis and training. OSHA wants to know the extent to which a site has safety programs, procedures, rules, and meetings that cover these areas. OSHA also wants to know the site’s track record regarding safety. PPL included all of this information in the 30-page application document. The company filed an application in 2002, and OSHA sent documents describing what to expect during the certification process.

After receiving the application, OSHA decides whether a site warrants an on-site interview. If an interview is not justified, OSHA provides information on areas requiring improvement.

During a site visit, an OSHA team of health and safety experts investigates the work site safety programs and gauges employees’ knowledge of and commitment to those programs. Successful certification of the site hinges on the interviews the OSHA team conducts with employees as well as physical inspection of the plant.

After spending two days at Holtwood in August 2002, three OSHA representatives concluded that results of the inspection and interviews were very positive.

Holtwood achieved VPP Star status in November 2002; OSHA representatives certified the status during a ceremony in May 2003. Achieving Star status is a tribute to the work of the PPL employees at Holtwood and the commitment that PPL shares with the International Brotherhood of Electrical Workers. The union and management share the commitment to maintain a safe working environment at PPL.

Recertification in 2005

After receiving Star status under the VPP, sites must submit a yearly safety report to OSHA. An OSHA team visits the site every three years to evaluate it for recertification. To be recertified, the site must continue to show improvement in its safety and health programs.

At Holtwood, PPL is working hard to improve safety programs and continue its strong safety record. For example, VPP team members are receiving hazard recognition training based on OSHA’s 30-hour general industry course. Team members also have been involved in developing job safety analyses to enhance safety awareness for several high-hazard work tasks such as intake trash screen cleaning, maintaining batteries, and entering hydroturbine wheel pits. Enhancing safety awareness has been an important factor for improvement. In fact, the plant went more than six years without an injury or safety mishap.

Beyond Holtwood

In addition to Holtwood, PPL has achieved VPP Star certification at several other facilities. For hydro facilities, PPL achieved Star status in 2005 at its 190-MW Kerr hydro project on the Flathead River in Montana.

PPL also has certified: five other non-hydro power plants in Pennsylvania and Montana; its corporate headquarters complex in Pennsylvania; and its testing, repair, and laboratory facility, also in Pennsylvania.

PPL is working toward VPP Star certification at all its facilities in the U.S.

Advice for others

Through its work to certify work sites under OSHA’s VPP, PPL learned several valuable lessons other project owners can apply:

– View safety as a team effort. You must forge a partnership between workers and management and ensure that workers are involved in every step of the VPP process. When workers and management collaborate, you overcome hurdles and achieve results.

– View OSHA as another partner in the safety process. You need to be aligned with OSHA’s mission and be in full compliance with all applicable OSHA standards.

– Provide good equipment and solid training. This is essential for your team to perform at its best. Take the time to ensure you have the safety programs, rules, procedures, equipment, and training necessary to make sure that everyone goes home safely every day.

– Never be complacent about safety. VPP Star status says that your safety processes are among the best. Now you have to show the perseverance, consistency, and attention to detail necessary to use them to achieve continuous improvement. Star status is not the end, but rather the beginning of performance that leads to safety excellence.

Messrs. Porse and Ruth may be reached at PPL Generation LLC, 482 Old Holtwood Road, Holtwood, PA 17532; (1) 717-284-6257; E-mail: ncporse@ pplweb.com or meruth@pplweb.com.

For more information on the Occupational Safety and Health Administration’s (OSHA) Voluntary Protection Programs (VPP), visit the website: www.osha.gov/dcsp/vpp/index.html. Or contact OSHA’s Office of Partnerships and Recognition at (1) 202-693-2213.

To contact the VPP manager at your OSHA regional office, visit www.osha. gov/dcsp/vpp/vpp_managers.html.

Chris Porse is site supervisor with PPL Holtwood LLC. Ed Ruth, senior safety and industrial hygiene specialist with PPL Safety Operations, is the corporate advisor to the team.


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