“Is Your Safety Incentive Program In Compliance With OSHA’s Interpretation?”

Video Courtesy of Comedy Central®

Safety incentive programs have long been used by organizations worldwide to promote safe working conditions and encourage safety at the workplace. But a recent memorandum by David Michaels, Assistant Secretary of Labor for the Occupational Safety and Health Administration (OSHA), states that “Section 11(c) of the OSH Act prohibits an employer from discriminating against an employee because the employee reports an injury or illness. Reporting a work-related injury or illness is a core employee right, and retaliating against a worker for reporting an injury or illness is illegal discrimination under section 11(c).”

This has raised a big question in the minds of Safety Managers whether to continue, modify or abandon their Safety Incentive Programs. After this memo, OSHA will be closely monitoring the safety programs that reward the lowest number of accidents reported. In a 2013 news article a former TVA Engineering Safety Manager was sentenced to 78 months in prison for deliberately falsifying workplace injury records to collect safety bonuses of over $2.5 million from the (TVA) Tennessee Valley Authority, a U.S. government corporation. There is a thin line between an effective incentive program and a misleading reward program which encourages workers to hide injuries.

Consider the following 10 tips to make your safety program OSHA compliant and more effective.

1. First, a safety program should be behavior-based rather than being injury-rate-based. It means employers should provide incentives to workers practicing safe operating procedures and practices instead of incentivizing schemes based on a number of accidents.
2. Reporting near miss, hazardous behavior should be focused which will prevent future occurrences of accidents. (Leading vs. Lagging Indicators)
3. Praise and recognize employees through top management in a timely manner and in front of others to acknowledge their safe behavior and encourage others to follow suit.
4. Avoid monetary reward for safety programs and use other awarding methods such as gift cards or certificates, days off, safety pins and recognition boards.
5. Reward employees for a wide variety of safety activities such as providing safety suggestions, guiding a co-worker with a safe operating procedure or identifying hazards or participating in Safety committees.
6. Involve employees in a dynamic safety program which encourages them to take part in periodic activities such as presenting tool box talks, teaching training classes and participating or performing safety audits.
7. Include workers in safety committees and meetings, and encourage them to think of ways to prevent accidents and perform root cause analysis. Open communication between managers and workers will ensure a safety conscious work environment.
8. Ensure management commitment by demonstrating that the organization’s leaders care about safety, by having leaders give presentations.
9. Establish safety as a core value of the company. Believe that all injuries are preventable, and near misses should be reported.
10. Allow employees to set safety goals for themselves. This will motivate them to ensure their own safety and work towards achieving them.

Adopting these suggestions will surely empower your safety program, minimizing incidents and at the same time prevent OSHA violations.

Just be sure to remain aware of the changing OSHA regulatory status under the new administration. Things may be changing rapidly soon.