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

I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better.

Danny Province

EHS Professional

I have been to other training companies, but Lion’s material is much better and easier to understand.

Mark Abell

Regional Manager

The online course was well thought out and organized, with good interaction between the student and the course.

Larry Ybarra

Material Release Agent

The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again.

John Nekoloff

Environmental Compliance Manager

The instructor created a great learning environment.

Avinash Thummadi

CAD & Environmental Manager

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste Professional

Lion is at the top of the industry in compliance training. Course content and structure are updated frequently to make annual re-training enjoyable. I like that Lion has experts that I can contact for 1 year after the training.

Caroline Froning

Plant Chemist

Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.

Kimberly Arnao

Senior Director of EH&S

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

The definitive 10-step guide for new hazardous materials shipping managers. Quickly reference the major considerations and details that impact hazmat shipping compliance.

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.