Reporting on the Society for Human Resource Management website, Roy Maurer wrote that Deputy Assistant Secretary of Labor Jordan Barab reiterated the agency's commitment to stand by the policy direction expressed in the memo:
(S)poke Nov. 15, 2012, before the National Advisory Committee on Occupational Safety and Health, a group tasked with measuring the effectiveness of OSHA’s strategies and programs. He said that “employers have explained their objections to the directive, but none of those reasons is that it doesn’t improve safety and health.” OSHA has asked these employers to provide statistics or studies to show that rate-based incentive programs improve safety and health, but none has, according to Barab.
This was one of four practices which OSHA addressed in a memo sent out to regional administrators and whistleblower program managers in the March of last year, warning that:
If employees do not feel free to report injuries or illnesses, the employer's entire workforce is put at risk. Employers do not learn of and correct dangerous conditions that have resulted in injuries, and injured employees may not receive the proper medical attention, or the workers' compensation benefits to which they are entitled. Ensuring that employees can report injuries or illnesses without fear of retaliation is therefore crucial to protecting worker safety and health.
The memo went on to caution that "if the incentive is great enough that its loss dissuades reasonable workers from reporting injuries, the program would result in the employer's failure to record injuries that it is required to record under Part 1904."
While some actions by OSHA aren't welcomed by safety professionals, this one is getting some support from safety professionals who are concerned that rewarding fewer safety incidents is working to discourage the reporting of incidents, thus masking the presence of workplace hazards and gloss over unsafe behaviors.
Here are some of the comments I found as I was doing background research on this issue:
Safety incentive programs simply don't provide the best outcome, and now that OSHA has targeted them, perhaps it's time to try a new tactic: one that focuses on the true realities of why employees come to work in the first place, and why they should want to be safe.
To be totally honest with you, I am not a fan of the “No injury, get a prize” kind of safety incentives. However, my question is how far is OSHA going to go with this and is it possible you could receive an OSHA citation because you track, measure, and share your work related injury rates with your employees?
The key to remember is that OSHA is not truly against safety incentive programs. It is against programs that discourage workers from reporting accidents or injuries.
In my experience, focusing on the outcomes, not the processes, makes safety compliance a matter of "when", not "if". It's also something I ran across in graduate school, when I was working all day and studying all night, when I read a research article written by John Kamp (It's time to drag behavioral safety into the Cognitive Era, Professional Safety, October 2001), a noted safety and risk management researcher. In this article, Kamp argued against the use of incident-based reporting systems and warned that "accident measures depend not only on how safely people work, but also on luck; in addition, accident reporting is easily biased when reward or punishment is made contingent upon them."
Effective root cause analysis calls upon those seeking to investigate and understand safety incidents to dig to find out the underlying causes of why something happened. It's not considered acceptable to simply ask what happened, but when safety programs reward or punish based upon the number of safety incidents, that's exactly what happens, so why approach overall safety programs differently?
Safety programs should encourage 100% participation in safety, including informed and attentive involvement in safety training and a commitment to work safely, as well as encourage safe behaviors by others. It shouldn't take an OSHA memo to make employers assess the effective functioning of their safety programs, but the agency's commitment to stand behind the policies outlined in this memo should caution employers to carefully assess their programs to avoid additional scrutiny from the agency.
Effective root cause analysis calls upon those seeking to investigate and understand safety incidents to dig to find out the underlying causes of why something happened. It's not considered acceptable to simply ask what happened, but when safety programs reward or punish based upon the number of safety incidents, that's exactly what happens, so why approach overall safety programs differently?
Safety programs should encourage 100% participation in safety, including informed and attentive involvement in safety training and a commitment to work safely, as well as encourage safe behaviors by others. It shouldn't take an OSHA memo to make employers assess the effective functioning of their safety programs, but the agency's commitment to stand behind the policies outlined in this memo should caution employers to carefully assess their programs to avoid additional scrutiny from the agency.
1 comments:
It certainly is a fine line. Safety programs offer an incentive to make the workplace better for employees. On the other hand, workers need to feel comfortable about reporting incidents and seeking the compensation they deserve.
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