Originally posted April 25, 2013 by Eric Glass at UL’s Knowledge at Work website www.knowledgeatwork.com/is-your-employee-safety-incentive-program-as-obsolete-as-the-8-track/#.UbI47dVRIA

You may or may not be old enough to remember, but eight-track tapes were a technological wonder back in the ‘70s, and anyone who was cool had one.  At the time, it was hard to imagine this state-of-the-art audio technology could ever be replaced or improved upon.

That was then, this is now. The eight-track became obsolete when cassette tapes came along, only to be quickly replaced by CDs, and now by MP3 players and other digital media.

If you have an incentive program based on zero accidents or zero recordables, your safety and health incentive programs are no different than the eight-track tape.

The memorandum

Well-informed employers know that OSHA will be closely examining safety programs that promote a zero-accident and/or zero-recordable goal.

In June 2011, Dr. David Michaels, assistant secretary of labor for occupational safety and health, issued a memorandum stating that “a company whose incentive program has the potential to discourage worker reporting fails to meet the Voluntary Protection Programs (VPP) safety and health management system requirements.” While OSHA’s official position is that it would deny VPP participation if an incentive program discourages employees from reporting injuries, OSHA’s public and private comments since that time indicate the agency may view all such programs in a negative light.

To refresh your memory, I suggest you review a “game changing” memo issued in March 2012, especially item #4 (Employer Safety Incentive and Disincentive Policies and Practices)

Inspectors are coming

OSHA inspectors will be on the lookout for certain types of programs or practices including:

• Companies with a history of taking disciplinary action against employees who are injured on the job, regardless of the circumstances surrounding the injury.
• Incentive programs that discourage workers from reporting injuries.
• Disciplinary actions taken against employees who violate a safety rule or do not report within a certain timeframe.
• Oh, and inspectors will have new allies – namely, your employees – and their megaphone will be the whistleblower program.

Right intentions, wrong result

By design, all safety incentive programs are designed to promote and sustain a safe and healthy work environment.

ALL incentive programs start with good intentions.  They are implemented to improve an organization’s safety and health programs and build a teamwork mentality.  But, these programs can drift sideways very quickly, particularly when bonuses and/or promotions are involved.

Let’s be real. If you have a zero-accident year, do you ever wonder whether this is actually the case or if it is likely accidents were not reported? 

Say there is a financial incentive on the table and you sprain your ankle on the job, know that if you report the injury the incentive will go by the wayside. What would you do? 

For many employees, the financial incentive (mixed with co-worker peer pressure) is enough to suppress reporting. This silence could expose you and others to greater risk and could result in an OSHA citation and/or workers’ compensation late-reporting fine.

The new incentive program

The new age of safety leadership requires forward-thinking professionals who use leading indicators as a weapon of choice throughout their organization to, drive top-down accountability and improve quality and productivity across the board.

Observations & near misses: the true teacher

An incentive program based on reporting of observations and near misses produces more and better results than zero accident/recordable programs, because it acknowledges the reality  that injuries or incidents will occur. When used correctly, leading indicators identify breakdowns or weaknesses before they become a problem.

Here are just two of many ideas for leading indicator incentive programs:

• Establish goals for the number of observations reported: Be creative! This can be applied organization-wide, by department and at the employee level.
• Near-Miss Committee: This is a function outside the traditional safety committee. Typically a near-miss investigation only involves management. This approach encompasses other personnel, including employees who can assist with root-cause analysis and prevention.

These types of programs still give the employees an incentive to be attentive to safety. Companies that don’t adopt this new approach will remain stuck in the eight-track era.

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