The Voluntary Protection Programs Participants’ Association, Inc. (VPPPA) has announced its support for the position of the OSHA that incentive programs must not encourage underreporting of injury and illnesses.
The question of the merit of incentive programs resurfaced when OSHA, as part of its National Emphasis Program on Recordkeeping, suggested that the existence of incentive programs may qualify for deliberate under-reporting, raising a recordkeeping violation from “other-than-serious” to the willful level.
“We have found that incentive programs based primarily on injury and illness numbers often have the effect of discouraging workers from reporting an injury or illness,” said OSHA Assistant Secretary Dr. David Michaels at the opening of the 26th Annual National VPPPA Conference in Orlando, Fla., in August. “We cannot tolerate programs that provide this kind of negative reinforcement and this type of program would keep a company out of the VPP until the program or practice is corrected.”
However, Voluntary Protection Programs (VPP) participants, just like all other worksites, are free to use an incentive program as long as it's the right kind of program, reinforcing positive behavior. Specific questions during inspections and onsite evaluations have been designed to determine whether some employers are under-reporting injuries and how incentive programs affect the reporting of injuries and illnesses.
“Incentive programs are a useful and common means to motivate people and strive for improvement,” said VPPPA Executive Director R. Davis Layne. “However, the association and its members disapprove of programs that discourage employees from reporting injuries because they want to receive a reward. Good incentive programs feature positive reinforcement for demonstrating safe work practices and taking active measures in hazard recognition, analysis and prevention.”
The nearly 2,100 VPPPA member sites primarily consist of worksites that have been approved, or are seeking approval, into VPP as administered by OSHA, state-plan OSHA and the Department of Energy.