Heard from quite a few of you regarding yesterday's blog.  Below is a comment from a reader who asked to be anonymous.

Hi Teddi:

Per your Blog yesterday I went to the Webinar.

After listening to the 1 hour Webinar I was struck with the sense that our National Safety Leader is a thoughtful, learned, respectful person.

I was also unsure of some of the serious issues that Dr. Michaels seems to have little if any answers:

-He is for accuracy in reporting injuries & illnesses but seemingly against using these records for disciplining.

-He is for incentive programs but all that were discussed he had problems with, like rewards which are good but cause under reporting of injuries & illnesses

-He is against using mod rates as contract award criteria.... in fact he said if your company has an excellent safety record & much better than your competitors you are suspect.... What!

-I'm not sure about this one.... seems to be against drug & alcohol post accident testing!

Three things I liked:

- For catching employees doing it right reward system

- Wants more employee input & interaction

- Believes the objective is to reduce injuries & illnesses in the workplace

Your followers can be your own judge by listening and noting any questions that they have that didn't get asked.

Here's my 2cents:

Dr. Micheals:

What do we do with workers that don't comply with safety rules?

What do we do with the employee that was asked three times in one day to wear their safety glasses?

What incentive program is appropriate?

You might be surprised to learn what OSHA thinks about safety incentive programs.

Dr. David Michaels, Assistant Secretary for the U.S. Department of Labor's Occupational Safety and Health Administration was the guest speaker on a webinar hosted by the American Society of Safety Engineers (ASSE) yesterday.  It was recorded and you can hear the entire talk.  There is no charge for this webinar.

Conversation with Dr. Michaels’ Link.

After listening to the recording, it became apparent that OSHA does not know what makes up a good incentive program.  Dr. Michaels did state that companies with incentive programs should reward employees for working safe, not punish employees or supervisors for injuries.  Taking something away (attendance at pizza party, bonus, raffle ticket, firing, etc.) for having an accident, actually discourages accident reporting and may get you into trouble with OSHA.   Programs where employees get penalized for having injuries are illegal (under Section 11c of the Act¹).  This would include programs that remove incentives from employees or supervisors for merely having or reporting injuries.

Be aware that OSHA frowns on terminating injured employees if the company appears to only discipline and/or punish employees when tied to unsafe acts leading to an injury.  A consistent disciplinary program is recommended.  Unsafe acts should documented and tied to an effective disciplinary program.  Don’t just act when there is an injury.

Companies with a long history of working accident free may also be discouraging accident reporting and OSHA may look at these companies to ensure that every incident is reported.

There was much discussion regarding OSHA 300 Log reporting.  OSHA uses the 300 Log to determine which companies are working unsafely and companies with lots of accidents may be targeted for an OSHA inspection.

Even though, OSHA uses the OSHA 300 Log to evaluate a company, it frowned on companie using the 300 log as part of their prequalification program.  For the record, my dad used to say, Do as I say, not as I do…I think this is what we are hearing here.  I didn’t like it then and I don’t like it now.

Companies with safety incentive policies may want to review their policies to ensure that they start moving in the same direction as OSHA.

¹(c) (1) No person shall discharge or in any manner discriminate against any employee because such employee has filed any complaint or instituted or caused to be instituted any proceeding under or related to this Act or has testified or is about to testify in any such proceeding or because of the exercise by such employee on behalf of himself or others of any right afforded by this Act.