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April 22, 2012

OSHA Inspectors Advised To Review Safety Incentive Programs

Days Without Accident SignYour next OSHA visit just might include a review of your safety incentive program - because OSHA has noticed that some safety practices and incentive programs could discourage workers from reporting injuries, and thus violate whistleblower and recordkeeping rules.

A March memo advises field compliance officers and whistleblower staff about common policies with the most potential for discrimination. OSHA has also observed that the potential for unlawful discrimination under these policies may increase when management or supervisory bonuses are linked to lower reported injury rates.
Inspectors have been instructed to pay close attention to situations where:
  • Employers establish programs that unintentionally or intentionally provide employees an incentive to not report injuries. For example, an employer might enter all employees who have not been injured in the previous year in a drawing to win a prize, or a team of employees might be awarded a bonus if no one from the team is injured over some period of time.
  • Employers have a policy of taking disciplinary action against employees who are injured on the job, regardless of the circumstances surrounding the injury.
  • An employee who reports an injury or illness is disciplined, and the stated reason is that the employee has violated an employer rule about the time or manner for reporting injuries and illnesses.
  • An employee reports an injury, and the employer imposes discipline on the ground that the injury resulted from the violation of a safety rule by the employee.
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