OHSA: Employer Safety Incentive and Disincentive Polices/Practices

bcoleman

Revamping our discipline policy regarding safety due to the recent memo put out by OSHA regarding safety and disciplinary action (specifcally being a possible deterant to ees reporting). Just wonding what others might be doing/have done if you have simular policy of discipline when an incident occurs?

Sharon McKnight SPHR

Revamping our discipline policy regarding safety due to the recent memo put out by OSHA regarding safety and disciplinary action (specifcally being a possible deterant to ees reporting). Just wonding what others might be doing/have done if you have simular policy of discipline when an incident occurs?

Your first post! Welcome to the Forum. :welcome:

Sharon

plhepner

We play a game called "Safety bingo" to reward employees for safe behavior. The jackpot starts at $25 and we draw a number each morning if there were no accidents requiring outside treatment at a medical facility. Using OSHA's guidelines allowing first aid at a facility coupled with the use of First Responders since we are outside of the three to four minute range of a medical facility for a major emergency, we are able to handle most incidents here at work. However, upon hearing a report that OSHA frowns upon "safety incentives", I hope it helps to share what I wrote as the following report for management:

"As we talked about after the luncheon, OSHA issued a memorandum on March 12th of this year to inform 'its field personnel to be on the lookout for incentive plans that award bonuses or prizes to supervisors or employees for having good safety records. OSHA feels that such plans may induce or pressure employees not to report recordable injuries for fear of losing incentive prizes or because of supervisory pressure not to compromise bonus entitlements.' So, just in case someone, sometime, somewhere down the line hops on this bandwagon, a few solid peace-of-mind strategies to counteract an hour-long conversation.

[Our company] is not discouraging the reporting of accidents. We still want staff to continue the current methodology; however, we want them to become accustomed to using the system of First Responders and 14 people’s ability to administer First Aid on the property rather than seek outside medical treatment for minor injuries. The goal is not to have a system of “preventing recordables” but rather reduce lost time (and wages) due to seeking treatment for an injury when, as I stated, most can be resolved with first aid here on the property.

A “recordable injury” is one that requires “medical treatment beyond first aid” [§1904.7(b)(1)(iv)] so then we look into “what is first aid”? “First Aid” may involve any of the following:

• Using a non-prescription medication
• Cleaning, flushing or soaking wounds on the surface of the skin
• Using wound coverings such as bandages, gauze, or steri-strips
• Hot or cold therapy
• Non-rigid means of support such as elastic bandages and wraps
• Removing foreign bodies from the eye using only irrigation or a cotton swab
• Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means
• Finger guards
• Drinking fluids for relief of heat stress
• All the above: [§1904.7(b)(5)(ii)(A-N)]

I’m sure you’ve already thought of how many injuries occur that can be resolved via first aid; hence, a non-recordable injury anyway. So, I know you knew all this but just in case someone makes a fuss or you hear “OSHA says you can’t do safety incentives anymore!!!”

bcoleman

Thanks so much! Your post was helpful. Sorry for the delayed response.

ACU Frank

That was an awesome response, PLHepner! I'm sorry I missed it when you posted it.