While safety incentive programs are often a part of a number of workplace environments throughout the country, the Occupational Safety and Health Adminstration (OSHA) issued guidelines negatively assessing some safety incentive programs for inadvertently disincentivizing reporting of accidents– which, per OSHA guidelines, is illegal. Companies involved in the production of safety incentive programs strongly disagree, making it important to examine both arguments to come to an informed conclusion.
OSHA’s Position: Many Safety Incentive Programs Actually Make Workplaces Less Safe
In March of 2012, OSHA issued a memorandum with guidelines for regional program administrators and whistleblower program managers on how to handle safety incentive programs. The major concern for OSHA was that certain reward-based safety incentive programs, whether at an individual or group level, unfairly penalize groups that report injuries (as they lose the related reward for maintaining a safety record). More importantly, OSHA’s position that this allowed for a form of workplace discrimination with immediate retaliation on the part of the employer against groups reporting injuries is illegal. Furthermore, OSHA gives recommendations to companies on how to run more effective safety incentive companies.
Safety Management Companies Speak Out on OSHA Memos: Is OSHA Wrong?
Joe Stevens of Bridge Management Consultants, a safety management firm with a national footprint, strongly disagrees with the wording in the memo. Effectively likening OSHA’s discrimination policy to enforced mediocrity, Stevens argues that incentive programs give employees the opportunity to lead proactively in promoting a safety culture. While agreeing with the memorandum that reward-based programs do more harm than good, Stevens posits that OSHA is not taking into account injuries prevented by safety incentive programs, as opposed to simply focusing on under reporting.
A Culture of Under-Reporting Injury
Stevens’ argument about non-serious injuries not posing a danger, however, is not something embraced in all injuries, particularly one where a safety culture isn’t esteemed highly. A National Institutes of Health report on unionized carpenters revealed the shocking truth that injury is often under-reported and that in fact reporting worker injuries is disincentivized in such environments. While the study does not address safety incentive programs at all, it does demonstrate that OSHA’s argument that under-reporting injury not only happens, but with surprising regularity.
A Smarter Way To Look At Safety Incentive Programs
A post about a recent client at Bridge Management’s website actually helps clarify the real value of these programs. After two years of using a safety management program and a 75% reduction in workplace injuries, management at a client company decided safety programs were no longer needed as they were “safe enough”. Bridge Management, in a short post, explained to the reader that a safety culture is not something you establish once, but a dynamic that has to be constant, not based on a set number of acceptable injuries, but creating a proactive climate where safety is a priority. Yet this position is similar to OSHA’s, which suggests that safety incentive programs incorporate practices which reward workers for identifying potential safety violations and promoting overall safety.
Ultimately, the real question is not whether safety incentives are good or bad (since it seems all sides agree that certain types of incentives are or aren’t), but what is being incentivized. Successful incentive programs can be created which do not create a negative atmosphere for reporting injuries and can improve the workplace. The alternative–whether using an incentive program to disincentivize reporting of injury or not having a safety culture in the workplace–is not only unethical, but often illegal.
