OSHA Memo Warning about Improper Use of Safety Incentives and Discipline

Managing consequences such as incentives and punishment are thorny issues in safety. ADI has long held that monetary bonuses based on injury counts/rates are problematic for a number of reasons including the likelihood of generating underreporting and coverups. We have also held that overusing punishment for injuries has the same effect. Safety is an area that requires a thorough understanding of how consequences such as incentives and discipline affect the behavior of employees and employers. It is rarely as simple as it seems. In a March 12, 2012 memorandum from OSHA Deputy Assistant Secretary Richard Fairfax, Regional Administrators and Whistleblower Program Managers were warned to be on the lookout for several employer practices that may discourage reports of injuries, violating several OSHA regulations.

Regarding punishment practices specifically, OSHA is concerned that practices such as disciplining employees for getting injured regardless of the circumstances surrounding the injury, or for failing to report that injury in the time or manner prescribed by the employer, or for violating a rule in the course of getting injured if this is merely a pretext for discipline, will all discourage reporting of injuries. Similarly, if an employer has a safety incentive program in place that has such strong incentives that a reasonable worker might be dissuaded from reporting injuries for fear of losing that incentive for him-/herself or for a group of people, such practices would be considered “unlawful discrimination” against a worker’s right to report injuries and invite further scrutiny from OSHA investigators. Companies must be careful how they design consequence systems around safety.

On the surface, a bonus for no injuries sounds like a good idea, but trying to reward outcomes like this leaves the chain of behaviors unspecified. True, one way to get fewer injuries is by being safer in all your actions, but an easier way is to simply do things as usual and suppress reports of injuries. Another way is through luck. Neither of these latter 2 strategies help create a safer workplace. Similarly, when companies rely on punishment to do too much of the “heavy lifting” in managing safety, underreporting and coverups are common, and a safety culture where safety issues are openly and honestly discussed is out of reach. A successful safety program requires a sophisticated understanding of behavior and consequences.

See also Why Incentives and Safety Don't Mix


Posted by Cloyd Hyten, Ph.D.

Cloyd is a senior consultant and thought leader in the field of performance improvement. Dedicating more than 20 years to this work, Cloyd has also served on the Editorial Board of the Journal of Organizational Behavior Management, and served as President of the OBM Network. Outside of work, Cloyd enjoys history, food and football.