Page 54 - Occupational Health & Safety, April 2017

INCENTIVES
For instance: in May 2016, OSHA amended 29 CFR 1904.35, which explicitly requires that a company provide reasonable procedures for employees to report work-related accidents and prohibits any form of retaliation against employees for making a report. This means you can’t say, “We will give you a point bonus if the company is accident free for a month.” There are, however, other effective ways to structure a program that are not retaliatory. For instance, you can incentivize employees to achieve certifications and train- ing that will result in a safer work environment, or you can create a program that incentivizes performance that does not tie back to reporting. Another example of an organization that might have an opinion about your safety incentive program is the labor union. Many unions tend to want to include anything that is given to an employee in their labor contracts. This can complicate the design process and can degrade program effectiveness. (In March 2017, the U.S. House of Representatives voted to overturn the OSHA rule, so at this writing it may be repealed.)
Distinguishing Compensation and Incentives
One comment that I often hear from client companies is “Safety is their job... why should I give them something for doing it?” This question requires you to make a very important distinction be- tween compensation and an incentive. Compensation is received by an employee for doing the job that he or she is required to do.
For instance, if someone works for a company that requires hard hats on their production floor, that employee is compensated to work on the floor wearing his hard hat. If he fails to do that, he fails to do his job, and that is a human resource issue.
However, it is different if you incentivize personnel for making hazard identifications with a hazard mitigation program. That in- centive can be used to drive employees toward finding hazards and fixing them. Incentives excel at motivating these important behav- iors. Incentives also show appreciation and gratitude or motivate people to go above and beyond their job requirements. It is very important that you look at the type of task that is being incentiv- ized to determine whether an incentive is even appropriate. In fact, if an incentive is given for simply meeting job requirements, it can often become viewed by the employee as compensation. This has two negative effects. First, it removes the appreciation and value inherent in the incentive. Second, if the employee, for some reason, does not receive that reward, he can often perceive it as losing com- pensation that he is owed, rather than a reward that he got for going above and beyond, thus having a net negative effect.
Cash vs. Rewards
Perhaps the most important consideration that you must make before starting a safety incentive program is “What will the re- ward be?” This is followed by “How will employees earn that re-
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