At The Podium

Avoiding the hazards of workplace safety programs

Western Oklahoma Human Resources

According to the Bureau of Labor Statistics, the number of reported workplace injuries, illnesses and fatalities has steadily declined over the past decade. From an employer’s perspective, it would appear that all the time and money invested in workplace safety programs is working. So why is the Occupational Safety & Health Administration (OSHA) stepping up its efforts to scrutinize and criticize such programs?

Last year, OSHA issued an official memorandum which attacks employer safety incentive policies and other practices which it believes may discourage the reporting of work-related injuries and lead to unlawful discrimination and possible retaliation against workers who do report injuries. If OSHA’s intent was to aim a shot to kill safety incentive programs then it may have hit the bullseye.

In a presentation to the members of Western Oklahoma Human Resources, McAfee & Taft employment attorney Roberta Fields reviews the safety programs and policies targeted in OSHA’s memorandum, discusses the likely impact it will have on employer safety programs, and provides practical tips for improving workplace safety while avoiding undue governmental scrutiny.

Topics include:

  • An overview of Section 11(c) of the Occupational Safety and Health Act
  • Incentive programs which are likely to be targeted by OSHA inspectors
  • OSHA recommendations for rewarding efforts, not achievements (every participant gets a prize?)
  • How to properly discipline a worker who violates company safety rules
  • How to properly discipline a worker who does not report injuries as specified by company policy
  • How to evaluate the effectiveness of safety programs


June 13, 2013
City Hall
Elk City, Oklahoma