Gamma-ray burst (GRB) observations at very high energies (VHE, E > 100 GeV) can impose tight constraints on some GRB emission models. Many GRB afterglow models predict a VHE component similar to that seen in blazars and plerions, in which the GRB spectral energy distribution has a double-peaked shape extending into the VHE regime. VHE emission coincident with delayed X-ray flare emission has also been predicted. GRB follow-up observations have had high priority in the observing program at the Whipple 10m Gamma-ray Telescope and GRBs will continue to be high priority targets as the next generation observatory, VERITAS, comes on-line. Upper limits on the VHE emission, at late times (>~4 hours), from seven GRBs observed with the Whipple Telescope are reported here.