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GAO tells OSHA to scrutinize incentive programs

May 10, 2012
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incentiveA new Government Accounting Office (GAO) report raises concerns about the effect of workplace safety incentive programs on accident and injury reporting, and recommends that OSHA add the issue to the field operations manuals used by its inspectors.

In “Workplace Safety and Health: Better OSHA Guidance Needed on Safety Incentive Programs,” the GAO compared rate-based incentive programs, which reward workers for achieving low rates of reported injuries or illnesses, and behavior-based programs, which reward workers for certain behaviors, such as recommending safety improvements. Of the approximately 25 percent of U.S. manufacturers with safety incentive programs or policies in 2010, 22 percent were rate-based programs and 14 percent were behavior-based.

Almost 70 percent of manufacturers also had demerit systems, which discipline workers for unsafe behaviors, and 56 percent had post-incident drug and alcohol testing policies. Most manufacturers had more than one safety incentive program or other workplace safety policy and more than 20 percent had several. Such programs and policies were more common among larger manufacturers.

The GAO found that rate-based programs may discourage reporting of injuries and illnesses. Additionally, certain workplace policies, such as post-incident drug and alcohol testing, may discourage workers from reporting injuries and illnesses.

”Researchers and workplace safety experts also noted that how safety is managed in the workplace, including employer practices such as fostering open communication about safety issues, may encourage reporting of injuries and illnesses.”

The United Steel Workers (USW) hailed the report for exposing what it called “the pervasive nature” of employer policies that discourage injury and illness reporting.

“The USW has long warned and campaigned against workplace programs and policies that discourage workers from reporting job injuries,” said USW International President Leo W. Gerard. “Such programs make employers’ injury rates look good while job hazards go unidentified and uncorrected. We’ve seen far too many tragedies and catastrophes in facilities where employers are playing these numbers games.”

Although OSHA is not required to regulate safety incentive programs, it does rely on employer injury and illness records to target its enforcement efforts. Assistant Secretary of OSHA Dr. David Michaels has warned employers about using rate-based incentive programs. That “limited action” is not enough, says the GAO.

“OSHA has cooperative programs that exempt employers with exemplary safety and health management systems from routine inspections,” according to the report.

The GAO says OSHA should implement criteria on safety incentive programs and other workplace safety policies across all of its cooperative programs such as the Voluntary Protection Programs (VPP) and Safety & Health Achievement Recognition Program (SHARP). The criteria should be consistent with the most recent VPP guidance memorandum that prohibits employers with safety incentive programs that focus on injury and illness rates from participating in the program.

To help OSHA inspectors consistently educate employers about the importance of safety culture, the Secretary of Labor should direct the Assistant Secretary of OSHA to add language about key elements of a positive safety culture—and the potential effect of different types of safety incentive programs and other workplace safety policies—to its field operations manual.”

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Tom Lawrence
May 17, 2012
First we have OSHA's rant on incentives, a couple of months ago, and now the GAO's rant. This coordinated attack smells of just another political agenda action. I am not into incentives myself but I know a number of safety professionals who are. They are serious about their work and attempt to apply incentives appropriately. In some cases, incentives are cultural and historical at a site and the safety professional does not want to pull those away. So why is OSHA/GAO after these safety professionals? And behold, we have new terms: Rate Based and Behavior Based incentives. Oh wow! Ultimately, everything we do is Rate Based, including OSHA's injury/illness data. It almost sounds like the real political agenda here is a war against post incident drug testing. According to the GAO, OSHA is knowledgeable on safety culture and will instruct employers about it. Really? Safety culture is highly site specific and you have to be a part of the site to really know the culture. Does OSHA/GAO not know that? The site specificity of safety culture is indeed one of the major issues arguing against the one size fits all OSHA I2P2 Standard. So what we have here from the GAO is waste of taxpayer's money on political agendas under the banner of safety.

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