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 provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!

Stephanie Weathers

SHE Specialist

The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course.

Jeffrey Tierno

Hazmat Shipping Professional

This is the best RCRA training I've experienced! I will be visiting Lion training again.

Cynthia L. Logsdon

Principal Environmental Engineer

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things.

Quatama Jackson

Waste Management Professional

Energetic/enthusiastic! Made training enjoyable, understandable and fun!

Amanda Walsh

Hazardous Waste Professional

Course instructor was better prepared and presented better than other trainers. Course manual and references were easier to use as well.

Marty Brownfield

Hazardous Waste Professional

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

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

Tom Berndt

HSE Coordinator

I like the consistency of Lion workshops. The materials are well put together and instructors are top notch!

Kevin Pylka

Permitting, Compliance & Environmental Manager

Download Our Latest Whitepaper

Shipping papers are a crucial part of safely shipping hazardous materials. See the top 5 mistakes shippers make on shipping papers, and how to avoid them.

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.