The Occupational Safety and Health Administration (OSHA) is VERY concerned that safety incentive and award programs encourage the under-reporting of injuries and illnesses. I know that seems silly but OSHA is concerned. Consider that:
- In 2012, OSHA Deputy Assistant Secretary Richard Fairfax issued a memo directing inspectors to scrutinize safety incentive programs. They will be looking for evidence of UNDER- REPORTING of injuries.
- OSHA continues to be engaged in ongoing communication that questions safety incentive programs.
- A 2012 Government Accountability Office (GAO) study focuses on improving incentive/disincentive policy and guidance to inspectors.
Even though many companies have been using incentive programs successfully—many for quite some time—to reduce accidents and injuries, OSHA has taken the position that there are inherent flaws in these programs. OSHA has even directed inspectors to look closely at incentive programs where questionable activities are suspected. A WORD TO THE WISE — NEVER FAIL TO REPORT, even if incentives are lost as a result.
Yet, when structured properly, incentive programs can play a very positive role in a safety program. The real question is how can you structure your program to achieve success while avoiding suspicions by OSHA inspectors that your program may not be above board? The answer is NEVER UNDER REPORT.