In late 2016 when OSHA rolled out its Improve Tracking of Workplace Injuries and Illnesses rule (aka the recordkeeping rule) we learned buried deep in the rule’s text is a line that carries the power to destroy pizza: the anti-retaliation provision.
The provision is brief: “You must not discharge or in any manner discriminate against any employee for reporting a work-related injury or illness.” Dozens of pages have interpreted that sentence and its counterpart, Section 11(c) of the OSH Act.
In a nutshell, if your safety incentive program causes an employee to think twice about reporting a hazard or injury, it’s probably illegal. The classic example: for every 100 days the facility experiences zero accidents, the employer will host a pizza party. John cuts his finger on day 81, but doesn’t want to be the reason the party is cancelled, so he wraps his finger in the bathroom and stays quiet. The pizza program discouraged John from reporting his cut, and that’s an OSHA violation.
But we need to motivate employees! We want to positively engage them in the safety process and what is more motivating and positive than pizza? The pizza can stay, but denying pizza after the filing of an accident report has to go.
Instead, revamp your program to reward employees for engaging in the process. For example, every time someone participates in the activities below, he/she receives a safety token. The more significant the engagement (the more serious the reported hazard), the more tokens that are awarded. Tokens are redeemable at the end of the year for prizes (think: Chuck E. Cheese’s). Alternatively, for every engagement, the employee’s name is entered into a quarterly drawing. The more significant the engagement (e.g., the more hours the voluntary participation requires), the more entries earned.
Another example: Vivian informs the safety team about loose floor tiles in the break room. Now, Vivian gets one token/entry. Lucille reports the eyewash station hasn’t been flushed in three weeks. For that, Lucille is going to get five tokens/entries. And we have Desmond who discretely alerts management that William has been using the reach truck despite not being certified. Desmond gets 10 tokens/entries.
Implementable suggestions: Let’s keep going here. Daryl provides the warehouse manager a coupon for new PPE he came across in an industry magazine. He gets 1 token/entry. Rick invents a color-coded chart to illustrate which employees are certified to drive which powered industrial truck. Give Rick 10 tokens/entries. Carol develops a driver check-in policy that prevents clogging at the loading docks. That’s worth 20 tokens/entries.
Voluntary participation: Zach volunteers to take attendance at the company fire drill (1 token/entry). Slater offers to redraft the monthly facility inspection checklist (10 tokens/entries). Kelly volunteers to lead the company safety team for one year (50 tokens/entries).
Safe behavior: Jerry squeegees a puddle of water off the warehouse floor (5 tokens/entries). Elaine cleans up all the warehouse aisles (10 tokens/entries). Kramer rearranges product and racking so the emergency exits have more than the required 28-inch clearance (20 tokens/entries).
In addition to the token or drawing systems, employers can host an event such as the Safety Olympics. Set aside one afternoon during the slow season and invite employees to demonstrate skills such as a pre- and post-trip vehicle inspection, cargo securement, backing a truck around orange cones, picking and loading product onto pallets, etc. Create scoresheets and choose three qualified judges to observe and rank each participant. Of course, the highest score wins a prize, but get creative! Who had a unique approach? Who took their time and was extra careful?
Hype this! Get marketing involved in your safety program. Take pictures. Highlight winners in the company newsletter. Ask senior management to blog about the safety incentive program, attend the Safety Olympics or prize drawing and be part of the prize. Take the winner out for pizza. See, you still get your pizza!