I have comments and questions about OSHA’s March 12, 2012 memorandum with the subject line: “Employer Safety Incentives and Disincentive Policies and Practices.”

We know OSHA has been on a crusade to find evidence of under reporting, urged on by their liberal advocacy group supporters. Apparently they must not have found anything or we would have heard trumpeting in the press.

The Democrats when they run OSHA are famous for, during an election season, using an OSHA issue as a "bone" to throw to these liberal advocacy groups supporters of theirs who also use OSHA for their political agendas.  

The real scary part here can you imagine these radical, arbitrary positions being dictated out of nowhere when/if the left wing OSHA political leadership get I2P2 on the books?

The people most adversely affected by this kind of stuff are my safety professional colleagues. We are the first in the food chain when stuff rolls out of 200 Constitution Avenue — and I highly resent this impact on us.

We went through this in the latter part of the last Democratic OSHA administration. At least there we were dealing with the clear incentives —big prizes etc. I don't agree with those types of incentives but I also don't agree with making it a big deal from OSHA.  There are more important safety issues to focus on.

The worst part is that they have now classified performance measurements systems based on injuries as discriminatory. These sites will get the full shaming press release shouting employee discrimination. Sites with safety staff of any kind (it is a small number--perhaps 1 -2 % of the nominal 7.5 million work sites) are the sites that are more likely to have a safety management performance measurement system in place. And it is most likely to be based on injuries.  

So safety professionals work to get performance measurement included for safety similar to that for other management responsibilities and OSHA comes along and cuts the legs out from under safety professionals for their political agenda.  
 
I am on board conceptually with the leading indicator/lagging indicator concepts.  However, while leading indicators are good to influence action, the lagging indicator measures bottom line outcomes. My professional view is the a performance measurement system should be a mix of leading indicators and the bottom line lagging indicator.   Management team members can take all the leading indicator actions in the world but if injuries are still occurring, to reward performance based solely on leading indicators sends the wrong message.

And by the way, when OSHA switches to leading indicators for their measurement systems, I will pay attention to their lectures on what is acceptable to measure.