OSHA and VPPPA Agree: Incentive Programs Must Not Discourage Injury Reporting

Dr. David Michaels, OSHA Assistant Secretary, recently issued a stern warning to companies using incentive programs based primarily on injury and illness numbers, saying that type of program would be enough to keep them out of the VPP until corrected. The admonishment was part of Dr. Michaels’ remarks at the VPPPA Conference in August.

A VPPPA press release this October echoed Dr. Michaels’ sentiments with VPPPA Executive Director R. Davis Layne, saying, “The association and its members disapprove of programs that discourage employees from reporting injuries because they want to receive a reward. Good incentive programs feature positive reinforcement for demonstrating safe work practices and taking active measures in hazard recognition, analysis and prevention."

The VPPPA press release also cautioned employers that “OSHA, as part of its National Emphasis Program on Recordkeeping, suggested that the existence of incentive programs may qualify for deliberate under-reporting, raising a recordkeeping violation from "other-than-serious" to the willful level."

You can read more about the Recordkeeping NEP, and recent changes in the scope of the investigation, in our blog post: Three Things to Know About the Updated OSHA Injury and Illness Recordkeeping NEP