skip to main content

This Thursday, November 22, people across the United States will be celebrating Thanksgiving. Many businesses will be closed, and many of us will be taking stock of the people we’re thankful for.

Our employees work hard for us year round, and our safety performance depends on them. We should certainly be thankful for their efforts and dedication, but the ways we express our gratitude (or fail to) can actually make the difference between a good EHS culture and a poor one, and can have a big impact our safety performance.

Before we pass the turkey this Thanksgiving, let’s take a moment to look at the ways we express our thanks to employees, and its effect on our EHS performance. We’ll also consider the question of whether our employees even know we’re thankful for them, and the difference that can make.

Who Wants Pizza? Maybe Not You

The old standby for rewarding employee safety performance is the pizza lunch. You’ve probably seen one, and maybe even enjoyed a slice or two yourself at one time. Basically, it works like this: A company location or department goes a certain number of days without a recordable injury – let’s say, a full year. Once the big day comes, the boss buys pizza for everyone and the celebration begins! Similar incentives might include the boss taking the whole department out to a baseball game or giving employees a paid day off. Whatever the reward, it’s a popular method that seems to be an effective way of recognizing positive safety performance. Who could see anything wrong with that?

OSHA, for one. The Agency has previously expressed criticism of incentive programs they believe may discourage employee injury reporting, and have scrutinized programs that reward employees for a lack of injuries. For example, a 2012 OSHA memorandum states, “…some employers establish programs that unintentionally or intentionally provide employees an incentive to not report injuries. For example, an employer might enter all employees who have not been injured in the previous year in a drawing to win a prize, or a team of employees might be awarded a bonus if no one from the team is injured over some period of time.”

OSHA maintained in the 2012 memo that such incentive programs may be discriminatory, because they withhold an incentive as the result of employees reporting injuries. Based on that interpretation, such programs would violate anti-retaliation provisions within the Recordkeeping Standard. They also state that such policies might discourage reporting, since employees know that a recordable injury means no pizza lunch or other reward, and they don’t want to be the one who “ruins it for everyone else.”

OSHA noted that there are “better ways to encourage safe work practices,” including rewards for workers serving on safety and health committees, or for suggestions of ways to improve safety and health – both of which would be proactive measures that would not deter reporting. The agency also incorporated similar statements regarding safety incentive programs and anti-retaliation into its 2016 final rule “Improve Tracking of Workplace Injuries and Illnesses,” a.k.a. the Electronic Reporting Rule.

If you’ve followed the controversy surrounding OSHA’s stance on pizza lunch-type incentive programs, you might know of a recent memorandum that some see as walking back OSHA’s earlier policy stance. The memo, titled as a “clarification,” states OSHA’s belief that “incentive programs can be an important tool to promote workplace safety and health” and notes that some programs reward workers for reporting near misses or hazards,” and that these kinds of programs are “always permissible.” They go on to observe that some companies use “rate-based” programs that reward employees with a prize or bonus at the end of an injury-free period, or evaluate managers based on their department’s lack of reported injuries.

OSHA’s following statements here, as usual, are very precise: “Rate-based incentive programs are also permissible under 1904.35(b)(1)(iv) as long as they are not implemented in a manner that discourages reporting. (emphasis mine). Thus, if an employer takes a negative action against an employee under a rate-based incentive program, such as withholding a prize or bonus because of a reported injury, OSHA would not cite the employer under 1904.35 (b)(1)(iv) as long as the employer has implemented adequate precautions to ensure that employees feel free to report an injury or illness (emphasis mine).” They go on to say that “a statement that employees are encouraged to report and will not face retaliation may not, by itself, be adequate to ensure that employees actually feel free to report.”

I’ve encountered quite a bit of discussion regarding this new memo, and speculation on how much of a reversal it is (or isn’t) of OSHA’s previous position. I’m not going to get too far into the weeds on sorting that out here – after all, Thanksgiving dinner is almost ready! For now, let me make two simple points.

First, OSHA’s new memo still frames rate-based programs like pizza lunches as in some ways less preferable to more proactivity-based programs. In the new memo, programs that reward safety improvement suggestions or reporting of hazards are always permissible, while rate-based programs can be permissible as long as the employer meets certain criteria. Further statements indicate that just saying “We don’t discourage reporting” won’t cut it. In such a case, an employer who uses rate-based programs would potentially have the burden of proving that they’re not discouraging reporting. I’d suggest this is not entirely different from OSHA’s previous positions.

Second, the concern about whether OSHA does or doesn’t now “approve” of rate-based incentives like pizza lunches might miss the point, and may not actually be the most important question. A much better question, in my opinion, is whether rate-based incentives even work in the first place. The growing consensus is that they do not.

Would You Rather Lag or Lead?

In industry terms, a “lagging indicator” is a metric that measures some aspect of safety performance after the fact. Injury rates are the classic example of a lagging indicator, because the injuries have obviously already happened. They are reactive in nature, and focused on the past. The pizza lunch incentive program rewards employees based on lagging indicators.

“Leading indicators,” on the other hand, are proactive in nature, and their use is intended to affect future safety performance. Reporting of near-misses (a.k.a. “near hits,” or “close calls”), hazards, and safety improvement suggestions are good examples of leading indicators, as are tracking of numbers of safety meetings or workplace safety inspections. These metrics are based on recurring, hopefully culturally ingrained activities that focus on future progress toward your goals. As we’ve seen, many employers prefer to reward completion of these kinds of activities.

You should absolutely track both leading and lagging indicators to get a more complete picture of your safety performance, but in terms of reinforcing or rewarding actions, you should focus on employee participation in leading indicators.

The reason is simple: It works well. Industry consultant Bill Sims, Jr. has discussed the success of rewarding leading indicators in his book Green Beans & Ice Cream and in his public talks, including a recent speech at the 2018 National Safety Council (NSC) Congress & Expo in Houston. In his talk, he discussed implementation of a program to reward employees for leading indicator activities such as reporting of unsafe conditions and suggestions for improvement at a branch of a company that had one of the worst safety performances of all its locations. The results? Sims stated that in the first six months of the pilot program, injuries and unsafe driving behavior fell by 41 percent, and the branch became one of the safest within the company.

Rewarding lagging indicators, like low injury rates, is far less effective. In fact, the branch mentioned above had primarily incentivized employees based on injury rates while they were slogging through their poor safety performance period. This result is consistent with many other findings. For instance, a review of employee recognition programs by Cal/OSHA reported that more than three-quarters of health practitioners believed workers sometimes avoided reporting work-related injuries and illnesses as a result of programs that rewarded low injury rates.

There’s another important reason why such programs often fail other than simple deterrence of reporting. Positive reinforcement is an aspect of behavioral science which seeks to make desired behaviors more likely and undesired behaviors less likely. Safety culture is, at its heart, about driving the right kinds of behavior and making them more likely to happen in the future. It’s a lot harder to do that on the basis of injury rates, because by definition, you’re talking about the past – the behaviors that led to your injury rate have already happened and are not open to reinforcement.

Under these types of incentive programs, you’re also basing rewards on factors that are out of many employee’s control. After all, an employee can’t always control whether another employee works safely, yet all employees receive rewards (pizza) or punishments (no pizza) because of factors that may not be related to their personal behavioral choices. That doesn’t seem like a great strategy, does it?

It’s much better to reinforce the behaviors that affect future performance by giving meaningful incentives when that behavior occurs. Of course, the true test that the reinforcement worked is that the desired safe behavior continues even when no one is around to make sure that it does.

Tips for Rewarding Employees

OK, so we’ve seen that rewarding leading indicator activities is better than rewarding lagging indicator activities, and we’ll hold off on that next pizza order for now. What else can we do to make recognition of our employees more meaningful and more effective?

Here are several tips to consider.

1) Be specific. Make sure that when you recognize desired behavior, you make your employee aware of the specific reasons for the recognition. Someone is unlikely to repeat behavior if they don’t know what behavior actually resulted in the recognition. This principle applies to deincentivizing undesired behavior too, by the way. I once worked for a manager who told our department that unspecified people had recently claimed that we had been unhelpful toward their department, although the details of how we’d supposedly been unhelpful were left unstated. But we needed to make sure we did better from now on, OK? This wasn’t the clearest reinforcement I could’ve asked for. (Spoiler alert: I don’t work there anymore).

2) Give them what they want, not what you want. Reward your employees, and praise them, but do so in the ways they most appreciate and are most comfortable with. You may really like pizza. You might eat it every day, think about eating it before you fall asleep, and dream about eating it the whole night through. But that doesn’t mean your employees feel the same way about it, and therefore, it doesn’t mean it will be an effective reward for them. The same goes for that book on management strategies you might be thinking of giving them, or that coffee mug branded with the company logo. Employees wind up getting lots of gifts they don’t particularly want, and might actually feel resentment about their lack of choice.

This applies to non-material rewards, too. You might think it’s a good idea to publicly praise one of your employees who’s shown exceptional safety awareness in her behavior, perhaps in her department meeting while her coworkers surround her. She might feel very differently. Singling out an employee for that kind of public recognition can make her feel uncomfortable – like a “teacher’s pet,” while also causing resentment among her coworkers. You’d actually be punishing the very behavior you intended to express gratitude for.

The good news is that there’s a way to know what kinds of tokens of appreciation your employees most enjoy. Just ask them.

3) Don’t wait until Thanksgiving! Positive reinforcement only works if the reinforcement promptly follows the behavior you’re trying to encourage. If an employee or group of employees demonstrates great safety awareness, make them know you appreciate it now. Whether your way of expressing thanks is nonmaterial, like verbal feedback, or material like a gift card or prize, don’t wait until next week or even tomorrow. Follow through as quickly as you can. The reinforcement will work better and the employee will not only appreciate it more, but more clearly recognize the specific behavior that led to the recognition.

It’s a sad truth that many employees feel unappreciated, and have good reasons to feel that way. I’ve talked to many employees over the years who felt that management didn’t care much about them, and a common complaint is that they constantly hear about the times they make mistakes, but almost never hear recognition of good performance.

In fact, many employees never get any positive recognition whatsoever. In his book 1001 Ways to Recognize Employees, Bob Nelson reveals that 68% of workers he interviewed had not even received a simple “thank you” from their boss in the six months prior to the interview. Nelson also points out that most of the employees he surveyed ranked positive feedback from their boss as the best motivator, while the bosses he surveyed didn’t believe that positive feedback mattered. The one thing employees wanted most was a “thank you” – something that costs no money and not even much time. Unfortunately, that was the very thing their bosses denied them, on the apparent belief that it wouldn’t make a difference.

We sometimes get ourselves worked up about how complex it seems to thank our employees. We might sometimes feel like no matter what we do, it won’t be “right,” either because employees will find fault with it or because a regulatory agency like OSHA will find fault with it. What I’m suggesting here is to table all of that for now, and get back to the heart of why it’s important to thank our employees in the first place.

It’s important to thank employees because it’s important that they feel appreciated. We can all reflect on times we felt unappreciated. Now, contrast those with times we felt properly recognized, and understand what a difference it can make. Remember that if it matters to recognize our employees, it also matters that we do it right. It means that we should reinforce behaviors (leading indicators) rather than after-the-fact metrics (lagging indicators), because it simply works better. It also means giving them the kind of recognition they themselves want, in a way that makes it easy for them to see the link between the specific behavior they demonstrated and the reward they were given.

Expressing gratitude well is just another facet of communication, and of building sound working relationships. If we do it well, we’ll have happier workers and a stronger business culture and EHS culture, and that’s something we can all be thankful for.

 Let VelocityEHS Help!

A good way to make sure your employees can actively participate in your EHS culture is to make it very easy for them to do so. At VelocityEHS, we’ve designed each of our software solutions with this core principle in mind.

Check out our solutions page to find out how we can help you create a more engaged and inclusive EHS culture by making it easier for you and your workers to perform tasks such as Audits & Inspections, Risk Analysis, Incident Management and much more. Our Safety Meetings solution will even help you schedule and manage your safety team meetings, making it easier for you to receive and follow-up on feedback from your employees and recognize the ideas that improve your workplace safety performance.

In addition, our Chemical Management solutions provide you with a fast, easy way to manage your chemical inventory and SDS library, and our award-winning Mobile App puts powerful chemical management tools and Right-to-Know SDS access into the hands of each and every one of your workers, empowering them to make your workplace safer and more sustainable.

Please feel free to contact us to learn more about how we can help you reach your EHS and sustainability goals. From VelocityEHS, we wish all of you a safe and happy holiday.