Page 22 - Occupational Health & Safety, January 2018

INCENTIVES
Changing Behaviors for the Better
This article has been developed from a conversation during the Incentive Marketing Association’s July 2017 annual Summit, when OH&S spoke with Sean Roark, CPIM, who was completing his term as president of IMA. He is a regular contributor to OH&S.
OH&S: We’ve been talking about OSHA’s guidelines regarding safety incentives. Without the strict guide- lines that OSHA proposes, how do they uncover and penalize fraudulent programs that are just meant to discourage reporting?
Sean Roark: A great phrase that I first learned from an historic American document is, “We hold these truths to be self-evident...” My professional research of best practices has shown me that if a pro- gram element is not ethically achieving the desired result at the highest moral level, the longer it is al- lowed to perpetuate, the more disastrous the after- effects will be when the truth is ultimately, and in my experience, inevitably, revealed. Refineries explode, mines cave in, workers have health issues. To be
clear, I’m not proposing that we sit back and wait for those horrible outcomes, but I strongly believe that if there is a good path and a disastrous path to be followed using something like outcome-based safety incentives, the role of the regulator is to prevent ac- cess to the disastrous path, not wall off the entire route and ignore the high positives because of the existence of a possible negative.
OH&S: Are you suggesting that there is over-regula- tion going on right now?
Roark: There is actually a new plunge into the regulatory climate to implement a no-outcome-based policy that has failed in the past. Here is a capsulated history, which I sourced courtesy of Steve Slagle, man- aging director of the Incentive Federation:
In 1999-2000, while creating what would become known as “The Ergonomics Rule,” OSHA began to challenge the efficacy of cer- tain types of safety incentive programs that focused on what is known as rate-based or outcome-based measurements. These pro-
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