In October 2018, OSHA released a memo that clarified some of the requirements and guidance surrounding its post-incident drug testing policies. The purpose of the memorandum is to clarify that OSHA does not prohibit workplace safety incentive programs or post-incident drug testing. In fact, it states that many employers who implement safety incentive programs and/or conduct post-incident drug testing do so to promote workplace safety and health. In addition, evidence that an employer consistently enforces legitimate work rules (whether or not an injury or illness is reported) demonstrates that the employer is serious about creating a culture of safety, not just the appearance of reducing injury rates.
In short, action taken under a safety incentive program or post-incident drug testing policy would only violate the original guidelines if the employer took the action to penalize an employee for reporting a work-related injury or illness rather than for the legitimate purpose of promoting workplace safety and health.
The memorandum may settle some employer concerns about the use of rate-based safety incentive programs, particularly where an employer ties a portion of a supervisor or manager bonus to the number of recordable work-related injuries or illnesses. The use of such incentives under the recent memorandum are not prohibited.
In the past, many of these safety programs gave everyone a reward for every 30 days the site went without a lost-time accident. This countdown to rewards was designed to raise awareness of safety and encourage peers to keep one another safe. Ideally, your coworker would remind you to put on your safety goggles to ensure proper protection and prevent any harm—but also because if you get hurt, everyone loses out on a reward.
The flip side of this type of incentive program is peer pressure to under-report workplace accidents or not report them at all. Managers and employees alike confirm this, no matter the industry. And that’s where OSHA’s concern lies.
In this post, we’ll focus on safety incentive programs and what OSHA guidance means for promoting or encouraging safe workplace behaviors. Additionally, companies must not uphold any policy that may encourage employees not to report incidents because they will ruin the chances of the entire company or team to receive recognition in the form of a company-paid for pizza party or other bonus or compensation. Safety incentive programs must hold a fine balance between encouraging positive behaviors, while still upholding the original compliance reporting guidelines that would not create an environment that – intentionally or unintentionally – discourages reporting.
1. An incentive program that rewards employees for identifying unsafe conditions in the workplace. One example of an incentive programs is one that rewards workers for reporting near-misses or safety hazards. According to OSHA, “Positive action taken under this type of program is always permissible.”
Another example rewards employees with a prize or bonus at the end of an injury-free month, or evaluates (and bonuses) managers based on their work unit’s lack of injuries. According to OSHA, these programs are also permissible, “as long as they are not implemented in a manner that discourages reporting.”
2. A training program for all employees to reinforce reporting rights and responsibilities and emphasizes the employer’s non-retaliation policy. This second precaution, a brief training on reporting illnesses and injuries, would be simple for employers to conduct and add to onboarding for new hires. OSHA recommends incentive programs that reward for employee participation in safety program activities and evaluations, completion of employee training, and safety walkthroughs and identification of hazards.
3. A mechanism for accurately evaluating employees’ willingness to report injuries and illnesses.” This could be a regularly scheduled, random questionnaire on employee willingness to report injuries and illnesses. You could also offer quizzes on best practices, and reward those who get a passing grade. This keeps safety top-of-mind and demonstrates that employees know how to avoid these injuries.
It’s also helpful to create an internal safety committee to lead these programs at your company. Committees are a positive way to reinforce the value of safety and get your team involved. Select members from all tiers of your workforce to review accident reports, conduct workplace inspections, make safety recommendations to managers and more. Not only will this get your team involved in safety, it will build a transparent culture of safety accountability.
Finally, to participate meaningfully in an incentive program, your employees must feel that their input is welcome, their voices will be heard, and they can access reporting mechanisms. Participation will be suppressed if language, education, or skill levels in the workplace are not considered, or if workers fear retaliation or discrimination for speaking up (for example, if investigations focus on blaming individuals rather than the underlying conditions that led to the incident or if reporting an incident or concern could jeopardize the award of incentive-based prizes, rewards, or bonuses).
According to OSHA, businesses spend almost $1 billion per week on costs associated with occupational injuries and illnesses, and those expenditures come straight out of company profits. If employers adopt these low-burden precautionary measures, they may bring back or now adopt safety programs that are popular and effective at reducing workplace injury rates.
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