Is Your Safety Incentive Program Violating OSHA?

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. With recent news of jail sentence for falsification, an American court has sentenced a former engineering safety manager Walter Cardin 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.

10 steps is too much and a few steps are repetitive, should be reduced for visual appeal and ease of skimming

  1. Behavior-based rather than injury-rate-based. 

       a. Employers should provide incentives to workers practicing safe operating procedures and practices instead of incentivizing schemes based on the number of accidents.

     2. Reporting near misses 

       a. Hazardous or potentially hazardous behavior should be reported in order to gauge and prevent future occurrences of accidents.

    3. Positive Reinforcement 

        a. Openly Praise and recognize those upholding safety standards to acknowledge their safe behavior and encourage others to follow suit.

   4. Establish safety as a core value of the company 

         a. This requires committing to the idea that all injuries are preventable and the possibility of recording zero incidents is attainable and realistic. 

  5. Group alignment 

        a. Include groups of workers in safety committees and meetings, and encourage them to think of ways, as a unit, to prevent accidents and perform root cause analysis. Open communication between managers and workers will ensure a uniform safety conscious work environment.

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

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