Safety Recognition: OSHA Violation?

I recently wrote a HSE Press Journal article and provided some rules for effectively recognizing employees that can have a huge positive impact, not only on your safety culture, but your company’s long-term success.  Ironically, I received a great question from one of OSHAcademy’s students about effective safety recognition in their company.

Let’s take a look at his question and a closer look at my response, as it may help you and your company!

“I am currently a safety coordinator and I’m doing (OSHAcademy’s) safety supervision and leadership course and it talks about rewarding employees for good behavior. I have mentioned that to my supervisor and I was told that we are not permitted to do that and that it’s an OSHA violation now.  The reason being if you reward your employees, they are less likely to report injuries. If my information is incorrect, can you point me to the resource?” 

I can tell you rewarding employees for demonstrating safe proactive behaviors WILL NOT be considered a violation by OSHA.  I worked for Oregon OSHA for 16 years and I can tell you employers who did that were always encouraged to continue because it IS considered effective proactive safety recognition.

However, your supervisor is right… but, only if employees are being recognized or rewarded for the number of “accident-free” days.  That can actually result in a violation if OSHA determines doing so contributed to an accident.  Rewarding employees for the number of days without an accident (the result)  is actually rewarding them for not reporting (the behavior).

It’s important to understand that whether we realize it or not, we are ALWAYS recognizing others for a desired behavior.  The challenge is to understand the behavior we’re actually recognizing.  Here are two examples:

Effective:  Recognizing/rewarding employees for reporting hazards.  Recognizing employees on the spot when they are using safe procedures.  Rewarding employees for participating in safety committee activities, safety teams, safety inspections, safety program audits, etc.  The “good” safe behaviors being recognized in these examples are proactive and will help to prevent accidents.

Ineffective/possible violation:  Recognizing employees or departments for working XX days without a reported work-related accident.  The “good” but unsafe behavior being recognized in this example is NOT reporting injuries.  This behavior is reactive because it occurs after the fact (accident).  Also, there can be an enormous amount of pressure on employees not to report their injuries.   A student in a class I taught years ago told me a story about how her son did not report an amputated finger because he was afraid it would hurt his department’s safety record.  That’s how bad it can get.  He was rewarded by not reporting the injury.   Unfortunately, this is one of the most common recognition programs.  Don’t do it.

For more information on this important topic, please see OSHAcademy course 700 Safety Management Training.