Search

OSHA’s and Employer Safety Incentive Programs

Posted on 9/4/2012 by James Griffin

Q. Does OSHA prohibit the use of injury-free incentive programs?
 
A. There is no regulation in 29 CFR that prohibits the use of employer safety incentive programs. However, the concern over employer safety incentive programs has grown in recent discussions. One of the Occupational Safety and Health Administration’s (OSHA’s) rulemaking priorities is the development of an Injury and Illness Prevention Program requirement, or I2P2 for short. According to OSHA’s last Regulatory Agenda, an I2P2 program would involve planning, implementing, evaluating, and improving processes and activities that protect employee safety and health. While there is currently no date for releasing a proposed rule, the administration has been talking about the necessity to have a robust injury and illness reporting program.
 
Popularity of Safety Incentive Programs 
Safety incentive programs by employers are widespread. According to an April 2012 GAO report, 75% of manufacturers in the U.S. have a workplace safety incentive program. For OSHA, this issue of employer safety incentive programs centers around the injury and illness reporting requirements at 29 CFR 1904. Employees are required by the rule to report workplace injuries and illnesses to the employer [29 CFR 1904.35]. Underreporting will not only prevent an employer from taking steps to eliminate specific hazards, it may also create a false sense of a workplace’s safety and health program.
 
Provide Safety Incentives, Not Disincentives
The GAO has concluded that employer safety incentive programs “can provide disincentives for workers to report injuries and illnesses to their employers.” The April report recommended that OSHA shed more light on the effects of these incentive programs. OSHA issued a memorandum in which the Agency discussed the issues of employer safety incentive programs. In the memo, OSHA identified several policies and practices that might discourage reporting or even discriminate against employees who do report. Some examples in the memorandum included:
  • Employers who take disciplinary action against employees who are injured on the job, regardless of the circumstances
  • Entering employees who have not been injured into a drawing to win a prize
  • Awarding a team of employees a bonus if none of the team members have been injured during the specified timeframe
Making Incentive Programs Successful 
Before you go ahead and scrap your safety incentive program, remember that OSHA is not necessarily saying all incentive programs are bad or in violation of workplace safety law. Rather, you’ll want to get together with your management and legal team and carefully review your incentive and disciplinary programs to determine if their current structure inadvertently discourages or punishes employees from reporting injuries or illnesses that may have occurred in the workplace. In fact, in OSHA’s Voluntary Protection Program (VPP) guidance, there are numerous ideas for positive incentives. With appropriate tweaks, an incentive program may be an effective component to your workplace safety program.
 
Are you running a safe, successful incentive program, and have tips for a manager looking to start one? Share comments and tips below.
 

Tags: best, osha, practices

Find a Post

Compliance Archives

Lion - Quotes

Lion was very extensive. There was a lot of things that were covered that were actually pertaining to what I do and work with. Great Job. I will be coming back in three years!

Tony Petrik

Hazmat Shipping Professional

I chose Lion's online webinar because it is simple, effective, and easily accessible.

Jeremy Bost

Environmental Health & Safety Technician

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials.

John Troy

Environmental Specialist

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.

Bryce Parker

EHS Manager

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

Senior EHS Engineer

The instructor made the class very enjoyable and catered to the needs of our group.

Sarah Baker

Planner

The instructor took a rather drab set of topics and brought them to life with realistic real-life examples.

Tom Berndt

HSE Coordinator

Download Our Latest Whitepaper

What to do before, during, and after a RCRA hazardous waste inspection to defend your site from rising State and Federal penalties.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.