To all VPP sites:
As a follow up to my previous email this message was sent out by our Acting Assistant Secretary for OSHA regarding the GAO audit involving recordkeeping practices. A link to the entire GAO report is included.
Although I fully believe the vast majority of our sites’ recordkeeping policies could qualify as a best practice to share with others in industry, there are a few things I’d like for you to consider should they apply to your operation. Within a safety and health management system there are a number of areas where disincentives may appear as unintended consequences to our efforts to reduce injuries and illnesses among employees. Here are a few thoughts to consider –
Incentive programs – Incentive programs often focus on the lack of recordable injuries/illnesses to reward an individual, group, company, etc. The basic problem here is that employees/managers may be discouraged from reporting an injury because they don’t want to lose their incentive award; they’re pressured by piers or supervisors to avoid losing their incentive award; or most likely at a VPP site, they take pride in their excellent injury/illness record and don’t want to be responsible for breaking it.
I’m certainly not saying you can’t associate injury/illness rates with an incentive program, but what I am saying is that you have to take great pains to ensure employees/managers understand that not reporting an injury/illness isn’t tolerated. To what degree you have to take this approach often depends on the lucrativeness of your incentive program. An employee who won’t receive a ball cap at the end of the month because an injury occurred is probably less likely to avoid reporting than an employee/manager who will lose a chunk of a performance bonus. Similarly, a disciplinary policy which unnecessarily places blame on an employee for an injury or illness is likely to discourage that employee as well as coworkers from reporting other incidents.
If you’re going to use an incentive program I like to encourage sites to take a proactive approach to it. Reward employees/managers for doing the things necessary to avoid the injuries/illnesses in the first place like attending/participating in safety meetings, doing job observations, setting a positive example for others by wearing appropriate PPE, following safe work practices, reporting hazards, etc.
Another potential area of concern is your site’s contractor program. Each VPP site is required to evaluate a contractor before coming on site to perform work among other things. If your contractor program relies on a contractor’s injury/illness rates to determine/partially determine their suitability for work, a contractor will be less likely to report their injuries and/or illnesses, probably giving a less safety conscious company an advantage over a company performing work safely (such as VPP contractors!). Again, I’m not telling you to avoid using the rates as a determining factor, but encouraging you to rely more heavily on other factors and/or make a solid effort to verify a contractor is accurately reporting injuries and illnesses.
The following excerpt is from the GAO report –
According to stakeholders interviewed and the occupational health practitioners GAO surveyed, many factors affect the accuracy of employers’ injury and illness data, including disincentives that may discourage workers from reporting work-related injuries and illnesses to their employers and disincentives that may discourage employers from recording them. For example, workers may not report a work-related injury or illness because they fear job loss or other disciplinary action, or fear jeopardizing rewards based on having low injury and illness rates. In addition, employers may not record injuries or illnesses because they are afraid of increasing their workers’ compensation costs or jeopardizing their chances of winning contract bids for new work.
I hope this has been helpful and maybe even provoked some new thoughts/ideas regarding your programs. Please let me know if you have any questions.
Thank you for your time,
Region VI VPP Manager