SafetyNewsAlert.comAre safety incentive programs now red flags for OSHA inspectors?

Are safety incentive programs now red flags for OSHA inspectors?

October 7, 2009 by Fred Hosier
Posted in: Compliance, In this week's e-newsletter, Injuries, inspections, Latest News & Views, OSHA news, What do you think?


It’s long been a subject of debate among safety pros: Do safety incentive programs reduce injuries, or do they encourage workers not to report when they get hurt? It seems OSHA has weighed in on the issue, buried within a directive for its inspectors.

Last week, OSHA announced a National Emphasis Program (NEP) on recordkeeping.

The agency wants to find out whether the nation’s workplace injury rate is really at its lowest point ever as reported by the Bureau of Labor Statistics (BLS).

BLS uses reports issued by employers to tabulate the injury rate.

OSHA’s targets in this NEP: Facilities in high-injury industries that have much lower-than-average injuries. The theory: Some of these employers are under-reporting injuries.

OSHA told it’s inspectors on this NEP to ask employees about their company’s safety incentive programs, specifically if they may discourage reporting of injuries. The inspectors will interview a minimum of 10 employees, more if the facility has over 100 workers.

Inspectors have been told to obtain copies of these incentive programs and note their existence in their reports.

While the guidelines say most recordkeeping violations uncovered through this NEP will be classified as “other-than-serious” violations, the citations may also be raised to the willful level when inspectors can document deliberate under-reporting.

Existence of incentive programs may be used to back up raising a recordkeeping violation to the willful level.

What’s your theory on safety incentive programs? How can a company develop an incentive program that reduces injuries yet doesn’t discourage reporting of incidents? Let us know what you think in the Comments Box below.

Our current Quick Poll asks about safety incentive programs. You can take our Quick Poll on our home page.

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22 Responses to “Are safety incentive programs now red flags for OSHA inspectors?”

  1. Bill Butler Says:

    True safety incentives are a positive reinforcement of the safety culture. Be careful as to how you set incentive programs up. We have set up a program for “On the spot” recognition for above and beyond safety actions. Seems to be working on our construction site with 20 contractors and over 70 workers.

  2. Jason B Says:

    Having a blanket requirement that if everyone stays safe, everyone wins, invites peer pressure and fear of being the one who causes everyone else to lose their incentive. Do we really need to be offering “bribes” to employees to stay safe? Incentive program or not, staying safe should be every employees #1 priority.

  3. Michael Kay Says:

    We have had in effect an employee incentive program for a little over 2 years now. Since the inplimentation of the program we have reduced our overall WC dollards by 70% in just one year. What needs to be understood about these programs is that it’s not the monetary part that gives you the success. What gives you the success is fact that all your employees see for the first time that you are out there visiable taking a strong stance in the true welfare of the employees. They actually see that everyone, inclusing top management is involved. This alone is where the success comes from. Lastly, you make sure that the reward isn’t so huge that it becomes worth hiding an injury for. A couple of hundred dollars these days will not be so much that an employee will hide an injury so severe they need clinical treatment. This has truly worked for us and I believe it can make a positive difference for any company willing to take the time and impliment the program properly.

  4. DaveB Says:

    I think incentive programs are a great tool when used properly. The issue is how to use them.

    Random incentives like Harley-Davidson gift cert, dinner for two, or a paid day off can be a great motivator to do the correct thing. Supervisors should reward safe practices like wearing PPE, following safety procedures, reporting hazards, or developing safe solutions. When the employees wearing proper PPE and following safety procedures get all the free stuff, it doesn’t take long for the other employees to join in.

    A few important tips:
    - Employees have preferences - one type of gift usually will not satisfy all employees.
    - Gifts must have value - a sticker saying “I worked safe today!” is not an incentive.
    - Incentive program must not penalize for failure - discipline employees for unsafe acts according to established procedure, but always allow employees to be rewarded when appropriate.
    - Rewards based on number of days without injury only stops employees from reporting injuries.
    - If an employee becomes ineligible for an incentive, they have no incentive to work safely.

  5. Safety Sam Says:

    My first workplace when I became a safety manager was a VPP site, and the subject of discussion in VPP at the time was incentive plans. I developed a plan then to base incentives on employee participation instead of simply ‘not getting hurt’. I made a list of things that I wanted to get done, and then presented that to the employee safety committee with the mandate to base getting the incentives on getting this stuff done. It was hugely successful, and took away any edge that OSHA might have had in using our incentive plan against us. I am now 2 workplaces down the road from there, and this still works as well now as it did 12 years ago. Just have to be imaginative and know what you want.

    Sam

  6. Sara Says:

    We have had a safety incentive program since I’ve been employed here nearly 2 year ago. I know it started in 2006 or before and works pretty good. Employees earn points by doing certain things and can buy items off of a site with their points. However, our company has been evaluating the program and is noticing that the employees earning the most points are the ones being injured and vice versa. It is not discouraging our employees from reporting injuries but it is rewarding employees for doing specific tasks and duties, not for staying uninjured. Anyone with any ideas on a better program would be greatly appreciated.

  7. Mark Greer Says:

    The company I work for base the incentive program on a quarters; requirements are completing a Behavioral Based Safety observation once a month, sign-in & understand the weekly Tailgate Safety meeting, don’t cause or contribute to any type of incident & no write-ups for anything for the entire quarter. This focus is on all aspects of an employee’s job, not just health & safety.

  8. john Says:

    OSHA needs to focus on the companies that are flying well below the radar (those are the red flags)… It seems when companies try something new or something at all they become the target/victims — and when they don’t have anything at all, they are left alone. Go figure..

    Something is better than nothing when trying -right?? Eventually, the company will figure it out when they are hit with the aftermath of it all. What should the foucs be? Underreporting or those who are not reporting at all???

  9. Tim Hess Says:

    The answer to the question is simple.
    (1) Base the incentive on behavior (individual and collective) - not injury reports
    (2) Structure a supervisor’s performance review so that a failure to make a required injury report is a negative.

  10. Alex Says:

    We have a program were team members have the chance to earn a percentage or their pay every six months based on proactive activities reported to and recorded and audited by the safety department. Measurements include number of near misses reported, job/task observations, area inspections, both by team members from line workers to senior management, safety team meetings, completion of compliance and awareness training, and monthly safety topics. We have involved everybody in the corporation and shifted the focus from the reacting to accidents to the identification and correction of conditions and behaviors that lead to accidents.

  11. Cheryl Says:

    I hope inspectors are also looking at policies that discipline employees when they report an accident. My husband worked for 20 years at a large oil company where workers hid their injuries not because they wouldn’t get the $25 gift card for going 30 days without a recordable but because they would be disciplined or fired if they got hurt. If someone got hurt, then the company stance was you must of been doing something wrong or not following the proper procedure. So guess what? Nobody reported injuries, not matter how minor. It was outrageous.

  12. Deanna Schabel Says:

    I feel that recognition is always important for moral in the workplace. If you take that away, they will not have any reason to strive for implementing the current rules in place. Give them a reason to do better and work smarter. It is OK to implement more safety ideas but don’t take away safety incentives!

  13. Tim Hess Says:

    Bill,

    Can you give an example of an “above and beyond” action?

  14. Jeff Stachowiak Says:

    I believe OSHA is simply looking at any incentive or disincentive program where workers are rewarded or penalized for not having or having accidents. Any program that would prevent workers from reporting any and all injuries is suspect.

    Incentive programs work if the program incentivises the participation in safety and/or training.

    For instance if you have safety meeting once a week or month you might reward people for participating in them or putting one on, or you might reward people for taking a particular training session. YOu might reward truck drivers for completing their daily vehicle checks, etc.

  15. Terry Says:

    First, to those of you who say incentives are like offering bribes to be safe, or it’s their job to be safe, etc. Employees are no different than children. You need positive reinforcement along with an incentive program that is fair and does not encourage under-reporting of injuries. This is of course a fine line to follow and yes, you’re going to mess up here and there but if you remain vigalent in your monitoring of the program and continue with a good training program and reinforcement you’ll be ok.
    We’re a fairly large construction firm and use a monetary incentive program where eveyone on a jobsite will get 20 cents on the hour when the job starts. No recordable injuries for 30 days then up it goes to 40 cents an hour for each employee. This goes on to 1.00 per hour added to the employee’s check if they remain safe. We have the same plan for our equipment incentive not to destroy or damage our equipment. An employee can earn around 160.00 to 180.00 a month extra in a separate check. This is a great incentive plan but needs to be closely monitored. There are some things we don’t like with it that we’ve observed this year but again, an incentive program must be adjusted and changed on a frequent basis if need be.
    Each month our Senior Personnel go around to the jobs for the first Toolbox Safety Talk of the month and gives each employee their Safety/Equipment Incentive Check marked in red on the outside of the envelope. Employees love this attention and are really grateful for the recognition. If the job does have a recordable injury their are a number of things we do but for expediency we drop the employee’s incentive back to 20 cents on the hour and then they start to accumulate the money all over again. I found the check needed to be separate and marked Safety/Equipment Incentive Check after I did an audit and found out 99 percent of employees had no idea why their was extra money in their regular paycheck.
    Just a thought. You will always have good and bad incentive programs. OSHA’s stance on this…who cares anymore. I worked for Federal OSHA 13 years and the private sector for 22 years and let me tell you OSHA will never know what its like to be in the private sector or how the private sector works or what it takes to actually run a safety program. To them its all about enforcement and inspection numbers. Good luck all of you because it is a nightmare.

  16. M M Says:

    If they get insentives for safety and your safety has very much improved, those little things that people cry about so much is not really a very big deal. I would say 90% of the people these days do not really need to go to the doctor over a small injury. If a small injury happens at home they would go on with life, but if it happens in the work place in is a major thing. People should get incentives for being safe on the job. If anyone has noticed that when incentive was given out your injury level went way down, why is this? Safety is just common sence, the best safety person is yourself.

  17. BC Says:

    The solution is to reward behavior that leads to incident reduction, not reward the lack of injuries. That’s how you avoid under reporting. There can be no mistake. Actions such as an employee finding a hazard creating a solution and helping resolve it, should be rewarded. If we had more employees like that, we would experience less injury. If a tree stump sits there all day long and never gets injured, should it be rewarded. What exactly is the behavior we are trying to encourage.

  18. Cheryl Says:

    Terry I would suspect an incentive program that rewards $$ and is progressive would definately be an incentive not to report an injury. I’m not surprised its working so well. I would think that is the kind of incentive program that OSHA would be on the look out for but with your background w/OSHA it must be OK.

    We use a point reward system based on many different safety areas. We reward for no loss time injury on a quarterly basis, spotting a near miss, scores on a safety audit, safety training etc. The points are then used to purchase items from a catalog. It does work well for us.

  19. M M Says:

    If your in a make belive land like BC that may work. But this is the real world. An employee should always look for hazards and report, but it is up to the managers to make sure the work place is safe before any employee does any work. If there is a hazard in the shop, that means the manager is not doing his or her job. What it sounds like is BC wants others to do his or her job. Do the job correct the first time then your employees will be safe respect you and concentrate on the job they get paid for.

  20. Wendy DC the Wary Says:

    I’ve been hesitant to put an incentive program in place because of under-reporting. So great, now OSHA’s ready to smack us for doing it? Wow.
    We’re a Human Services agency, with direct care, residential, manufacturing, clinics, case management, child welfare, and other departments, so not sure even how to put a program in place. It’s taken years to get people to understand that they have to report injuries in a timely manner, we have active safety committees, but there are always stragglers. Now we’re looking at another company with a different culture joining us, how does everyone else keep up with incentive programs?

  21. David Bradford Says:

    FACT: As long as incentive plans link incentives (especially $) to number-of-injuries, the incentive to not report injuries will always exist. How “strong” that incentive will be will vary, but the incentive will be there none-the-less.

    What to do? Base your incentive plan upon new numbers that count (or account for) employee actions best described as “safe” for specific jobs and tasks (e.g. steps in a JSA or JHA).

    The inescapable fact remains that the true number of accidents and injuries must necessarily decrease when the real number of “safe” actions are occurring more and more often. Take-away: Always link your incentives to success (safe actions) and resist the temptation to tie them to failure (injuries). As long as we safety professionals permit others to force us to measure safety success in terms of minimized failure, our incentive systems will be doomed to promote “low numbers” and punish the reporting behavior of those unfortunate enough to experience an occupational injury or illness.

  22. Tom Jolliff Says:

    One of my clients realized after a couple years that employees were showing up at their “safety parties” to simply collect the cash that was being given away, with no thought or after thought to the intent of the incentive.
    As a result, the general manager decided to retool their approach from rewarding “accident-free” employess/departments to positively reinforcing “behavior.” They also made the supervisors responsible for rewarding positive safety behavior, and for ensuring the employees were working safely. This became part of their performance review.
    Reinforcing positive behavior was the key to helping them build and engrain a culture of safety throughout their organization. It also helped the supervisors better understand that they play a huge part in the success of the company’s safety and health program.


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