OSHA’s Surprising New Posture On Safety Incentive Plans
This article on safety incentive plans was written by our ept Safety Consultant Glen Dulac.
Always remember that a well-crafted safety incentive plan will bring dramatic results in moving your safety program from good to great. Studies show as much as a three to one return on investment, from a good incentive plan.
So, what kind of a tempest in a teapot has OSHA been brewing up to spoil your incentive plan?
Https://www.osha.gov/recordkeeping/finalrule_faq.html OSHA slipped it into the record-keeping rules, you can find it in the frequently asked questions.
And what does it say?
“ The rule does not prohibit incentive programs. However, EMPLOYERS must not create incentive programs that deter or discourage an employee from reporting an injury or illness. Incentive programs should encourage safe work practices and promote worker participation in safety-related activities.”
Please notice I fully capitalized EMPLOYERS. Hold that thought or read the last sentence of this article now. Let’s boil this down to key tangibles.
Incentive plans are not outlawed, but the wrong kind could get you fined by the OSHA guys. Never discriminate, all employees deserve equal pay, and an incentive is considered pay or compensation. Focus on activity standards, AKA leading indicators.
Examples would be:
- Participating on a safety inspection team
- Keeping ones work area clean, or
- Attending safety training.
Downplay big ticket monetary rewards given for reductions in accident frequency or reduction in experience modification.
In closing let me stress the following, OSHA has no scientific foundation for its position that monetary incentives lead to underreporting of injuries. There has been no major court case on this topic. Issues on incentives have been published as memos not as final rules.
State OSHA may differ from Federal OSHA. Any discussions about the delicate details of your incentive plan should be discussed in the presence of an attorney, so they will fall under the client-attorney privilege. This makes it very difficult for the OSHA octopus to get its tentacles on said communication.
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