Page 97 - Occupational Health & Safety, September 2017

OH&S: Is this just your point of view?
Roark: I reached my conclusions independently, but also find myself in the good company of some very smart people who are of the same mind. For example, the Incentive Federation, which takes point for the incentive industry on litigation, leg- islation, and lobbying on incentive matters. The IMA is one of the keystone members of the IF and recognize their stand to promote the goals of the safety industry, rather than subvert them. Many members of the Incentive Federation, and folks from IMA and other industry groups that have examined the Incentive Federation research on this, have reached similar conclusions to me.
George Delta, executive director and general counsel of the Incentive Federation, who has been involved at the very highest level of all of these developments for years longer than I have, summed up the apparent faulty logic used by OSHA to all of this very succinctly. Here’s what he said in a May 2016 letter to OSHA:
“Given the considerable benefits of well-designed safety incentive programs, there is no justification for OSHA to place a stigma all such programs merely because it believes that some programs might lead
to the underreporting of workplace injuries. Doing so is unwarranted, unjustified, unsupported by em- pirical (rather than anecdotal) evidence, and would not produce the result that OSHA desires—the re- duction of injuries in the workplace. If anything, eliminating or discouraging the use of well-designed safety incentive programs is likely to lead to a more dangerous workplace.”
OH&S: Are you saying that OSHA’s position is groundless? Roark: Regretfully, not entirely. My opinion is that their reac- tion is too broad. The fact is, there have been some bad pro- grams which were purely designed to discourage reporting, but that doesn’t mean that effectively designed safety incentive programs, even with outcome-based rewards, don’t work. Here’s a parallel: Everyone generally pays for things they want using cash. It would be an extreme over-response to suggest that no one should cash because of the acknowledged fact that there are counterfeiters out there; instead, we design controls and safe- guards to ensure that with reasonable precautions, cash is a safe and effective business tool.
Untitled-7 1
8/7/17 2:35 PM
www.ohsonline.com
SEPTEMBER 2017 | Occupational Health & Safety 85
Circle 66 on card.