In November 2009, the federal Government Accountability Office (GAO) released a report on the accuracy—or, more precisely, the inaccuracy—of federal OSHA's injury and illness statistics. The GAO was not the first group to analyze OSHA's data collection and verification methods and find them wanting. Critics have long asserted that OSHA misses a substantial number of workplace injuries and illnesses that are never reported and that OSHA's audit procedures are inadequate.

In response to all of these criticisms, federal OSHA launched a National Emphasis Program on Feb. 19, 2010, that will allow it to closely scrutinize workplaces in certain industries that report unusually low numbers of injuries and illnesses.

One concern the GAO and other critics identified is employees' failure to report work-related injuries in the first place. Fear of losing promised incentives was one of the reasons commonly cited for this failure.

The Problem of Incentives

Safety incentive programs sound like a great idea to both workers and employers: If the number of injuries goes down, workers receive a premium. Common premiums include company hats and jackets, gift cards, steak dinners, and cash prizes. However, what starts out looking good to everyone soon starts to look bad to workers—and regulators, too. OSHA's new National Emphasis Program instructs inspectors to examine employers for policies and programs that discourage the reporting of workplace injuries and illnesses, including safety incentive programs.

How do safety incentive programs discourage reporting? In programs that directly link rewards to injury rates, workers can find themselves faced with an unhappy choice—report an injury that may require medical care, and cause themselves and their co-workers to lose a promised reward, or don't speak up and keep the reward. If the workers have the added disincentives of possible drug testing and discipline hanging over them, the effect of the program on reporting may be powerful indeed.

The end result—reduced injury reporting—may look attractive to employers, whose reported injury rates directly influence workers' compensation premiums and can also affect whether the employer will receive certain types of contracts. But the ultimate result of a poorly designed safety incentive program is the poisoning of the safety program and the employer's relationship with its workers. Incentives start to feel like "hush money" for covering up injuries, and pressure from fellow workers to keep quiet and not lose incentives can create feelings of resentment among the workforce.

And employers, who simply aren't hearing about fairly serious injuries (injuries requiring only first aid aren't recordable, after all), may be setting themselves up for a workplace fatality or major disaster. In other words, this type of safety incentive program may ultimately harm, rather than improve, your safety record.

Redesigning Your Incentive Program

It is possible to create a safety incentive program that enhances safety without suppressing reporting—one that won't draw regulators' hairy eyeball. Use these dos and don'ts to help create a safety incentive program that motivates workers to be truly safe:

Do:

• Make incentives part of a strong comprehensive safety program. Rewarding workers for using safety equipment won't be effective if the necessary equipment isn't readily available.


• Link incentives to desired safe behaviors, such as participating on safety committees, attending safety training programs, providing ideas that can be used to enhance workplace safety, attaining 100 percent compliance with safe work practices and procedures, and passing safety inspections and audits.


• Provide immediate rewards. Many safety incentives are given only at the end of a long waiting period, such as six months or a year. Instead, try rewarding workers immediately (for example, with a small gift card) when they identify a hazardous condition or are observed doing the right thing—such as locking out equipment and then testing it to see whether it is properly locked out.


• Put safety goals in writing and follow up by including them in performance reviews and rewarding workers who achieve their goals.

Don't:

• Link incentives directly to injury statistics. Workers may simply stop reporting injuries to keep their incentives. Avoid penalizing workers or groups of workers for reporting injuries and incidents.


• Play favorites. Some companies that reward workers for demonstrating "safe behaviors" soon find that the program is corrupted by supervisors and managers giving the rewards only to their pet workers. Just like programs that encourage injured workers to hide their injuries for the sake of the group's reward, programs that allow managers to play favorites can lead to resentment and noncompliance.