Our Marketing Manager and I have been traveling the Southeast for the past six months educating companies on the topic of “Eliminating the Controversy Over Safety Incentive Programs” at all of the major safety and health conferences. We knew the latest OSHA publication on tracking of workplace injuries and illnesses would be the final guidance on what is a compliant safety incentive program. The time was right to ensure everyone knew what was and was not acceptable in the eyes of OSHA. The turnout for our sessions far exceeded our initial projections, and the rooms were packed with company representatives looking for a definitive answer on how to establish a Compliant safety incentive program.
As you may have heard, the traditional style of incentivizing employees for zero recordable injuries and no lost time is now off the table. With OSHA’s final rule on record keeping, https://www.osha.gov/recordkeeping/finalrule/, this is no longer an option when it comes to compliance in their eyes. This traditional style of incentive program is thought to discourage workers from reporting or under reporting injuries or illnesses in the workplace. A results driven campaign has the best of intentions but has regularly shown its damaging side and it was time for OSHA to step up and specify what is compliant to ensure companies were following a path to success.
So what can I do for an Incentive Program and still remain compliant?
If you look at the FAQ’s page, https://www.osha.gov/recordkeeping/finalrule/finalrule_faq.html, you can see the question asked “Does the rule allow an employer to have an employee incentive program?” The answer you will find is yes, but a strong “However” follows in suit. To ensure the program does not follow in its traditional predecessors footsteps, the program must not deter or discourage an employee from reporting an injury or illness. The focus now must be on leading indicators and proactive behaviors; encouraging safe work and worker participation in safety related activities. We all want to see the same thing, NO INJURIES/ILLNESSES, and moving from this outdated injury-rate-based approach to a newly formed behavior based layout can bring about the same end-result if done correctly.
he big take away from this write up is that incentive programs, when done correctly, go far beyond basic law and are based on ethics of doing whatever is necessary to create a safer workplace. An incentive program must be built around the mindset of encouragement versus discouragement to achieve the results that you desire. Why invest in short term goals, when you can invest in long term sustainable results?