August 4, 2010
Employers be warned! OSHA is scrutinizing safety incentive programs. Dr. Michaels, the Assistant Secretary of Labor in charge of OSHA, has set his sights on safety incentive plans that could be seen as discouraging workers to report work related injuries.
How far is OSHA going to go with this? I am not sure, but here is a quote from Dr. Michaels in a recent speech:
“We also disapprove of incentive programs that, for example, offer a pizza party or allow workers to enter a raffle for a new truck. These incentive programs can discourage employees from reporting injuries because they want to receive the reward.”
Could this also mean that even a sign at the front entrance of an establishment announcing the number of days worked without a lost time injury could be construed as “discouraging employees from reporting injuries”?
Michaels goes on to say:
“OSHA inspectors are now watching for these incentive programs and they will scrutinize them to ensure they aren’t discouraging workers from reporting injuries and illnesses.”
The current OSHA Recordkeeping National Emphasis Program requires the OSHA inspector to determine if the employer has any safety incentive programs, contests, or promotions. The inspectors are required to obtain a copy if there is a written policy. They are also directed to determine if the employer’s management participates in any bonus or incentive safety system and also obtain a copy of any written policy.
I would encourage all employers to scrutinize your safety incentive programs before your next OSHA visit. If there is even a hint that the program could discourage the employees from reporting a work related injury or illness, this may be the time to consider some changes. At a previous employer, I had at my discretion what we called “spot awards” where management could hand out nice prizes to employees who demonstrated positive attitudes and efforts to improve workplace safety for themselves as well as their coworkers. This program seemed to work well.
To be totally honest with you, I am not a fan of the “No injury, get a prize” kind of safety incentives. However, my question is how far is OSHA going to go with this and is it possible you could receive an OSHA citation because you track, measure, and share your work related injury rates with your employees?
What is an employer to do? Once again, OSHA remains somewhat silent on this topic. But Michaels did say in the same speech, “Good incentive programs feature positive reinforcement when workers demonstrate safe work practices, and when workers take active measures such as reporting close calls, abating hazards, and using their stop-work authority to prevent a workplace tragedy”.
So, if you are looking to modify your safety incentive programs, you should focus more on the actions/processes in place to achieve your injury reduction goals and not on the outcomes. Such as rewards for successful training participation, contributions to safety suggestion programs, assisting in safety inspections, and the like. No matter what you decide, be sure that your program could not be viewed as discouraging the reporting of workplace injuries or illnesses.
Written by Dwayne Towles Vice President of Advanced Safety & Health, LLC.