Page 96 - Occupational Health & Safety, September 2017

Employee Gifts & Incentives
Safety Incentives: It’s a Small World, After All
At the Incentive Marketing Association’s annual Summit, held in Orlando this July, OH&S was able to speak with Sean Roark, CPIM, who was just completing his term as president of IMA. We took the opportunity to catch up with Sean, who is a regular contributor to OH&S.
OH&S: Sean, have there been significant changes in the safety incentive landscape in the year that you’ve been president of IMA?
Sean Roark: Yes, several, and on many different levels. Some are ongoing, some will have huge long- term impact, and others have had an immediate ef- fect on how incentives support safety.
OH&S: What issue has had the most immediate impact?
Roark: I would definitely have to say, the recently implemented OSHA guidelines regarding safety incentives. As most folks in the industry already know, for many years now, OSHA has been very supportive of performance-based awards, such as identifying a potential hazard or volunteering to serve on a safety committee. They are, however, equally strong in their criticism of outcome-based incentives, such as rewarding a month, quarter, or year of exceptional safety by a group with a celebra- tion or reward.
OH&S: So is it your impression that OSHA does not agree that a low accident rate is a valid mea- surement of safety that justifies a reward?
Roark: I don’t want to appear overly critical of the agency as a whole; I have some good friends who genuinely are out to make the world a better, cer- tainly safer, place through their dedication to their jobs at OSHA. I believe that their talented staff can recognize, as most who have studied these pro- grams would agree, that these types of behavioral performance improvement programs consistently improve safety. The inclusion of outcome-based rewards is a very effective and ethical part of any behavioral modification incentive program, such as a safety incentive program. The proof of this is borne out by even a cursory evaluation of white pa- pers and actual program results. There is a wealth of empirical data reflecting the high success rate of similar outcome-based programs in diverse areas such health and wellness, customer service, and sales achievement incentive programs. OSHA pol- icy makers, however, do not share this conclusion.
OH&S: But as a government regulatory agency, part of their job is to be sure that the rules of play
keep the game honest. Have they always been un- happy with outcome-based incentive programs since Congress legislated the agency into being back in 1970?
Roark: Not really. For the first 25 years or so of its existence, OSHA policy had been favorable to- ward an aggressive safety incentive program to support positive behavioral change and promote participants in adopting best practices in safety and health, including celebrating and rewarding positive results by individuals and groups. Around the turn of the century, their policies started posi- tioning that any reward which recognized a terrific safety record (or other “accident-free” outcome) represented some sort of an agenda of hidden in- timidation by employers.
OH&S: What did that change in point of view by OSHA look like?
Roark: For example, an employer might want to say, “To celebrate everyone being safe for the whole year, we want to give each of you a nice gift!” OSHA took the much darker position that there was an implied threat. OSHA proposed that the message inferred in that scenario really was a subterfuge along these lines: “Here is a nice gift,” the employ- er would say in the OSHA scenario, dangling the sparkling reward gift or cash bonus in front of the employee, “but you will not get the gift if you file an accident report or do anything that reveals you did not have a perfect safety record. Oh, and one other thing,” the employer murmurs in a menacing tone, “if you report an accident, none of your friends you work with will get the shiny gift, and they will all blame you!”
They hold out that anything which rewards great outcomes is actually an implied bribe, with an inferred message that anyone who “plays ball” and doesn’t report an accident or injury will benefit by getting a reward of some kind. To use their ter- minology, it is “encouraging under-reporting.” This position completely disregards all of the indepen- dent studies that show that engaging an employee by showing gratitude and appreciation after the fact for excellent performance is one of the single great- est game changers in improving morale and chang- ing behaviors.
84 Occupational Health & Safety | SEPTEMBER 2017
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