The term “bloody pocket syndrome” has been around for a long time, but there is still plenty of debate about how to prevent it. Bloody pocket syndrome refers to employees hiding their injuries (such as shoving an injured hand into a pocket to conceal it from a supervisor) to avoid missing out on a prize or other incentive. The behavior demonstrates what can happen when workplace safety incentive programs go awry, putting pressure on employees to keep workplace injuries to themselves.

The issue was a favorite of former OSHA head Dr. David Michaels, who spearheaded the effort to address the role of workplace incentive programs in underreporting employee injuries. In fact, under Michaels’ leadership, OSHA’s 2016 Final Rule to Improve Tracking of Workplace Injuries and Illnesses practically removed workplace safety incentive programs from the safety manager’s arsenal. OSHA argued, “Such programs might be well-intentioned efforts by employers to encourage their workers to use safe practices. However, if the programs are not structured carefully, they have the potential to discourage reporting of work-related injuries and illnesses without improving workplace safety.” (81 FR 29623)  

But wait…

In 2018, OSHA reversed course. An agency memorandum placed workplace incentive programs back on the table, stating that the agency expressly did not prohibit them. The memo clarified that OSHA would not cite an employer who took a negative action against an employee under a rate-based incentive program, such as withholding a prize or a bonus because of a reported injury, “as long as the employer has implemented adequate precautions to ensure that employees feel free to report an injury or illness.” (OSHA 2018)

But just because OSHA allows rate-based incentive programs, are they a good idea? Let’s look at a few of these programs to see how you might implement effective safety incentive programs and avoid ineffective or even harmful programs.

The good

Good workplace safety incentive programs go beyond rewarding employees for not being injured. They encourage safe behavior, hazard awareness and recognition, and cooperation. They lead to better attendance for safety training sessions, more employee involvement in safety issues, and an increase in teamwork.

The best programs take positive steps to create a workplace culture that emphasizes safety, not just injury and illness rates. This includes training employees on their reporting rights and responsibilities and emphasizing the organization’s non-retaliation policy. It also means having a mechanism in place for accurately evaluating employees’ willingness to report injuries and illnesses.

Examples

• A monthly drawing for a $25 gift card to a home improvement retailer for maintaining a clean shop floor.
• Entering all employees who provide safety suggestions into a drawing for a prize. Giving gift cards to employees whose suggestions were implemented.
• Celebrating a certain number of reported near misses with a company cookout.
• Providing employee recognition certificates and mentions on the company intranet for completing training sessions.
• Handing out small prizes for reporting a potential hazard.
• Printing up company T-shirts for serving on the Safety Committee.

The bad

Avoid bad incentive programs with good planning. Know ahead of time what you plan to accomplish with any reward. Do you want to encourage a certain behavior? Increase safety training attendance? Poorly designed and executed safety incentive programs can keep you from accomplishing those goals and stunt your safety program.

Examples

• Not recognizing every person who meets the criteria for a prize. If you’re relying on supervisors handing out prizes for safe behavior, make sure they are rewarding all instances of safe behavior. If one worker gets a prize, but someone working right new to him doesn’t, that can create feelings of resentment. Similarly, if everyone meets the goal of conducting safety audits, or attending voluntary training, make sure everyone gets rewarded.
• Making one person’s reward reliant on another’s. Having a few group goals may work out fine, but making a large prize depend on no one being injured means peer pressure may cause employees to hide injuries or unsafe acts.
• Using an all-or-nothing approach. Recognize the effort. Maybe your employees didn’t reach the goal to report 50 safety observations, but they did manage to report 40 observations. And avoid setting safety goals that are so lofty that no one can achieve them.
• Rewards based on games of chance. Safety bingo or PPE lotto might sound like fun, but what if a person with a bad attitude or poor safety record wins?

The ugly

Ineffective safety incentive programs can drive down reporting and keep you from understanding the whole safety picture at your facility. Worse yet, poor safety incentive programs can lead to truly bad outcomes. In June 2019, the U.S. Chemical Safety Board (CSB) released its report into the investigation of a chemical plant disaster involving the release of methyl mercaptan which killed four workers and seriously injured two others. Among several other serious safety, the CSB identified the company’s employee incentive program as part of the company’s safety weaknesses. The Board said the company’s bonus structure “may have disincentivized workers from reporting injuries, incidents, and near misses.”

As the CSB emphasized, “ensuring that employees can report injuries or incidents in accordance with regulations, without fear of discrimination, retaliation, or other adverse consequence is central to protecting worker safety and health, and aiding accident prevention.” (CSB 2019)

References:

1. Occupational Safety and Health Administration. 2016. Final rule. “Improve Tracking of Workplace Injuries and Illnesses.” 81 FR 29623. May 12, 2016. https://www.federalregister.gov/d/2016-10443

2. Occupational Safety and Health Administration. 2018. Clarification of OSHA's Position on Workplace Safety Incentive Programs and Post-Incident Drug Testing Under 29 C.F.R. §1904.35(b)(1)(iv). October 11, 2018. https://www.osha.gov/laws-regs/standardinterpretations/2018-10-11

3. U.S. Chemical Safety and Hazard Investigation Board, Investigation Report. 2019. Toxic Chemical Release at the DuPont La Porte Chemical Facility. No. 2015-01-I-TX. June 2019. https://www.csb.gov/dupont-la-porte-facility-toxic-chemical-release-/