What does OSHA say about Safety Incentives Programs?

OSHA has had quite a bit to say about Safety Incentive Programs over the last few years.  And, although many people act as if it's a murky area for OSHA, what they are saying is really quite clear:

A Safety Incentive Program must incentivize safety!

That's seems pretty straightforward, right?  It's as if they shouldn't even have to say anything at all.  I mean, of course a Safety Incentive Program needs to incentivize safety.  What else would it do?

Herein lies the difficulties with such a program.  Many well-intentioned safety programs can actually do just the opposite of incentivizing safety.  They can actually dis-incentivize safety.  Let's look at the ways this can happen:

1. An employer punishes an employee, or a group of employees, that has reported an injury.  If you're like me you're thinking, "who would do that?"  Like me you're picturing someone being put into timeout or something.  In reality a punishment can be something as simple as withholding an achievement related bonus or reward.  This would actually be considered a punishment and I think we can all imagine this actually happening on a job-site.
2. An employee gets injured and is punished for not following the rules of the Safety Program.  This could theoretically be acceptable if the employer punished the employee(s) every single time the safety rules were not followed, but if the employer is only enforcing the punishments when someone gets hurt, which is much more likely, then it goes against the OSHA regulations.
3. An employer establishes a program that rewards employees that have not experienced any injuries. This is the one that trips everyone up because this is the one where everyone's intentions were good.  Unfortunately, however, by rewarding only the people that have not had any problems you're actually incentivizing everyone to keep quiet about the things that need to be improved.  

OSHA has also observed that the potential for unlawful discrimination under all of these policies may increase when management or supervisory bonuses are linked to lower reported injury rates. While OSHA appreciates employers using safety as a key management metric, they will bring down the hammer on a program that encourages discrimination against workers who report injuries.

The Bottom Line is that OSHA wants to see Safety Incentive Programs that promote everyone to be vigilantly looking for ways to improve safety and to speak up when they see opportunities to make their work environment safer.

For direct look at what OSHA has to say, read this memo on OSHA.gov https://www.osha.gov/as/opa/whistleblowermemo.html

For some help with your Safety Incentive Program, or to simply have us take a look at your program to get an opinion from us, please contact us at allcustomwear.com.