Page 25 - Occupational Health & Safety, January 2018

est danger to losing that chilling effect would be if the rule were to be challenged and overturned in court. Don’t prosecute under the rule, and it can’t end up in court, the Big Chill perpetuates. Quod erat demonstrandum.
OH&S: So, what is the takeaway from all this to a safety professional? Roark: I can’t say what’s true for everyone, but here is the el- evator version of this whole issue, stipulating that you are in a tall
building and the elevator is stopping at every floor:
Design is the key. Frankly, this whole regulatory mess has evolved from flawed programs that mostly had the best inten- tions and assumed that the easy way out was to tie rewards to OSHA, workers’ comp, or other statutory reporting rates. In fact, for the most part, my understanding is that this practice evolved from the assumption that such reporting was an “impartial mea- surement” and reflected results arising from firmly defined and monitored rules by a third party. Have people tried to corrupt this practice? You bet. Does it sustain as a long-term policy? Nope. Sooner or later, I believe that the sheer momentum of habit and culture will reveal itself in something so disastrous that it can’t
be hidden.
OSHA makes no bones about how the OSHA culture views out-
come-based incentives. They view such incentives as discouraging reporting and deny any positive redemptive value in the practice. Here’s the crux of it: They make an arbitrary unilateral claim that all outcome-based incentives discourage reporting. They say it as a proclamation, and the inference is that it is a given that every ethical and intelligent person should know. Those of us listening to these pronouncements make our rebuttals, but from a smaller stage to an audience that is not nearly as broad. Then, turn to another pronouncement: “We will penalize anything that promotes under- reporting.” They don’t specify incentives, but anyone who reads the previous arbitrary assertion does not have to go very far to make a connection.
I am not urging everybody who reads this to throw in a bunch of outcome-based awards as if they were throwing tea in Boston harbor. I do suggest that you don’t succumb to broad-brush pro- nouncements that all such awards are unethical, and look to what outcome-basis, such as “no violations of SOP” or a celebration of a plant’s “Partnership for Success” can reward the shift of your em- ployees’ consciousness from “me” to “we” without any connection to what is recorded or reported under the OSHA standards.
OH&S: You mentioned ongoing projects at the beginning of this conversation. What would you pick as the primary ongoing chal- lenge as relates to viable and effective safety incentive programs?
Roark: The most obvious to me is continuing to educate our clients that a safety incentive program is not about the “stuff.” Some clients use gift cards, others merchandise, travel, or experiential awards. Oftentimes these elements are blended with recognition, in the form of plaques, certificates, company-wide “shout-outs,” or wearables and promotional products that proclaim that the wearer is part of a team, and a successful, caring team. The most funda- mental lesson that I convey to my clients, and the piece of informa- tion that seems to serve them best, is the fundamental understand- ing that it’s not the “stuff ” they give to their employees that create a safer workplace, but rather what the employees have to do to re-
ceive the “stuff.” Create a set of rules that teach and imprint best safety practices, and you can get an employee who would never change a habit if you paid them to follow the rules, in order to earn the points for the blender that they want to receive, and in doing so discover they have changed their habits, and consequently their company’s culture, towards safety.
We’re having this conversation on a Walt Disney property. I have examined and appreciate Disney’s ability to identify what their “guest” participants want to experience, define what their cor- porate goals are, and find what steps and standards they have to implement to deliver the desired experience to their target audi- ence, while achieving the endgame that they have defined as suc- cess. I suggest from this model, your readers can appreciate what the safety incentive professional does, following a similar process to design the program that fits your company’s unique needs.
Sean Roark is immediate past president of the Incentive Marketing Association, treasurer of the Incentive Federation, and chairman of the ASSE Downtown Houston chapter. He was the first person named as a Fellow of the IMA and also was in the initial class of inductees as a Fellow of the Promotional Products Association In- ternational, making him the only person to hold both honors. He is a Certified Professional of Incentive Management and a recognized authority on the topic of safety incentive program design and man- agement, and he has spoken on the topic across the United States and on four continents.
www.ohsonline.com
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