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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

April 2012: 

Workplace Safety and Health: 

Better OSHA Guidance Needed on Safety Incentive Programs: 

GAO-12-329: 

GAO Highlights: 

Highlights of GAO-12-329, a report to congressional requesters. 

Why GAO Did This Study: 

OSHA relies on employer injury and illness records to target its 
enforcement efforts. Questions have been raised as to whether some 
safety incentive programs and other workplace safety policies may 
discourage workers' reporting of injuries and illnesses. GAO examined 
(1) what is known about the effect of workplace safety incentive 
programs and other workplace safety policies on injury and illness 
reporting, (2) the prevalence of safety incentive programs as well as 
other policies that may affect reporting, and (3) actions OSHA has 
taken to address how safety incentive programs and other policies may 
affect injury and illness reporting. GAO reviewed academic literature, 
federal laws, regulations, and OSHA guidance; surveyed a nationally 
representative sample of manufacturing worksites; and interviewed 
federal and state occupational safety and health officials, union and 
employer representatives, and researchers. 

What GAO Found: 

Little research exists on the effect of workplace safety incentive 
programs and other workplace safety policies on workers' reporting of 
injuries and illnesses, but several experts identified a link between 
certain types of programs and policies and reporting. Researchers 
distinguish between rate-based safety incentive programs, which reward 
workers for achieving low rates of reported injuries or illnesses, and 
behavior-based programs, which reward workers for certain behaviors, 
such as recommending safety improvements. Of the six studies GAO 
identified that assessed the effect of safety incentive programs, two 
analyzed the potential effect on workers’ reporting of injuries or 
illnesses, but they concluded that there was no relationship between 
the programs and injury and illness reporting. Experts and industry 
officials, however, suggest that rate-based programs may discourage 
reporting of injuries and illnesses. Experts and industry officials 
also reported that certain workplace polices, such as post-incident 
drug and alcohol testing, may discourage workers from reporting 
injuries and illnesses. Researchers and workplace safety experts also 
noted that how safety is managed in the workplace, including employer 
practices such as fostering open communication about safety issues, 
may encourage reporting of injuries and illnesses. 

Figure: The Two Types of Safety Incentive Programs: 

[Refer to PDF for image: illustration] 

Rate-based programs: 
Reward workers who had few or no reported injuries or illnesses during 
a set time period. 

Behavior-based programs: 
Reward workers for behaviors such as reporting near-miss incidents or 
recommending safety improvements. 
   
Source: GAO analysis of workplace safety literature. 

[End of figure] 

In 2010, from its survey, GAO estimated that 25 percent of U.S. 
manufacturers had safety incentive programs, and most had other 
workplace safety policies that, according to experts and industry 
officials, may affect injury and illness reporting. GAO estimated that 
22 percent of manufacturers had rate-based safety incentive programs, 
and 14 percent had behavior-based programs. Almost 70 percent of 
manufacturers also had demerit systems, which discipline workers for 
unsafe behaviors, and 56 percent had post-incident drug and alcohol 
testing policies according to GAO’s estimates. Most manufacturers had 
more than one safety incentive program or other workplace safety 
policy and more than 20 percent had several. Such programs and 
policies were more common among larger manufacturers. 

Although the Occupational Safety and Health Administration (OSHA) is 
not required to regulate safety incentive programs, it has taken 
limited action to address the potential effect of such programs and 
other workplace safety policies on injury and illness reporting. These 
programs and policies, however, are not addressed in key guidance such 
as OSHA's field operations manual for inspectors. OSHA has cooperative 
programs that exempt employers with exemplary safety and health 
management systems from routine inspections. One such program 
prohibits participants from having rate-based safety incentive 
programs, but guidance on OSHA’s other cooperative programs does not 
address safety incentive programs. Similarly, OSHA inspectors and 
outreach specialists provide information to employers about the 
potential benefits and risks of safety incentive programs, but the 
guidance provided to inspectors in its field operations manual does 
not address these programs. 

What GAO Recommends: 

GAO recommends that OSHA provide guidance about safety incentive 
programs and other workplace safety policies consistently across the 
agency's cooperative programs, and add language about safety incentive 
programs and other workplace safety policies to the guidance provided 
to inspectors in its field operations manual. OSHA agreed with the 
recommendations, and noted its plans to address them. 

View [hyperlink, http://www.gao.gov/products/GAO-12-329]. For more 
information, contact Revae Moran at (202) 512-7215 or moranr@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Safety Incentive Programs and Policies May Affect Injury and Illness 
Reporting: 

Three-Quarters of U.S. Manufacturers Had Safety Incentive Programs or 
Other Workplace Safety Policies: 

OSHA Has Taken Limited Actions to Address Safety Incentive Programs 
and Other Workplace Safety Policies: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: Studies on the Effect of Safety Incentive Programs, 
Workplace Safety Policies, and Safety Culture on Workplace Safety: 

Appendix III: Questionnaire Used for GAO's Survey of Manufacturing 
Worksites: 

Appendix IV: Comments from the Department of Labor: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: Studies on the Effect of Safety Incentive Programs on 
Workplace Safety: 

Figures: 

Figure 1: The Two Types of Safety Incentive Programs: 

Figure 2: Manufacturers with Safety Incentive Programs and Other 
Policies, by Type, 2010: 

Figure 3: U.S. Manufacturers with Only One Program or Other Workplace 
Safety Policy, Compared with Manufacturers with Multiple Programs or 
Other Policies, 2010: 

Figure 4: Manufacturers with Safety Incentive Programs and Other 
Workplace Safety Policies, by Size, 2010: 

Abbreviations: 

BLS: Bureau of Labor Statistics: 

Labor: Department of Labor: 

OSH Act: Occupational Safety and Health Act of 1970: 

OSHA: Occupational Safety and Health Administration: 

SHARP: Safety & Health Achievement Recognition Program: 

VPP: Voluntary Protection Programs: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

April 9, 2012: 

Congressional Requesters: 

In March 2005, 15 workers died and 180 others were injured during an 
explosion at the BP Texas City refinery. The refinery had a safety 
incentive program that tied workers' bonuses to achieving low rates of 
injuries and illnesses. A January 2007 study conducted by an 
independent panel after the explosion found, among other issues, that 
workers feared reprisals for reporting potentially risky conditions at 
the refinery.[Footnote 1] In October 2009, we reported that safety 
incentive programs can provide disincentives for workers to report 
injuries and illnesses to their employers.[Footnote 2] 

The Department of Labor's (Labor) Occupational Safety and Health 
Administration (OSHA) uses employer data on occupational injuries and 
illnesses to, among other purposes, target its efforts in enforcing 
workplace safety and health regulations, including selecting worksites 
for inspection. OSHA relies on workers to report work-related injuries 
and illnesses to their employers, and on employers to accurately 
record and report this information to OSHA. Accurate injury and 
illness data also help employers and others identify patterns of work-
related injuries and illnesses and try to prevent them. For example, 
many insurance companies use employers' injury and illness rates among 
other factors to set their workers' compensation insurance premium 
rates. 

According to some workplace safety and health experts, certain safety 
incentive programs and other workplace safety policies may discourage 
workers from reporting workplace injuries and illnesses. Because of 
ongoing concerns that injuries and illnesses are not always reported, 
you asked us to examine the following questions: (1) What is known 
about the effect of workplace safety incentive programs and other 
workplace safety policies on injury and illness reporting? (2) How 
prevalent are workplace safety incentive programs, as well as other 
workplace safety policies that may affect injury and illness 
reporting? (3) What actions has OSHA taken to address how workplace 
safety incentive programs and other policies may affect injury and 
illness reporting? 

To learn what is known about the effect of safety incentive programs 
and other workplace safety policies on injury and illness reporting, 
[Footnote 3] we interviewed OSHA and state occupational safety and 
health agency officials, union and employer representatives, and 
researchers; and identified and analyzed 26 studies that appeared in 
peer-reviewed journals from 2001 to 2011. To describe the prevalence 
of workplace safety incentive programs and other policies, we surveyed 
a nationally representative sample of manufacturing worksites about 
their safety incentive programs and workplace safety policies and 
analyzed the results.[Footnote 4] To identify the actions OSHA has 
taken to address safety incentive programs and policies that may 
affect injury and illness reporting, we reviewed relevant federal 
laws, regulations, and OSHA program guidance; analyzed OSHA inspection 
data; and interviewed OSHA and state occupational safety and health 
agency officials and experts. 

We conducted this performance audit from September 2010 to April 2012 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. For more 
information on our scope and methodology, see appendix I. 

Background: 

OSHA administers the Occupational Safety and Health Act of 1970 (OSH 
Act), which was enacted to assure so far as possible safe and 
healthful working conditions for the nation's workers.[Footnote 5] 
OSHA helps ensure the safety and health of 106 million private sector 
workers at approximately 8.7 million worksites in the United States by 
operating over 80 area offices that report to 1 of 10 regional 
offices. OSHA sets occupational safety and health standards and is 
responsible for enforcing them. The agency directly enforces these 
standards in about half the states; the remaining states have been 
granted authority by OSHA to set and enforce their own workplace 
safety and health standards under a state plan approved by OSHA. 
[Footnote 6] 

OSHA's Recordkeeping Requirements: 

The OSH Act and OSHA's regulations generally require employers to 
prepare and maintain records of work-related injuries and illnesses 
sustained by their workers and make them available to OSHA upon 
request.[Footnote 7] These requirements are referred to as OSHA's 
recordkeeping requirements. OSHA has established definitions and 
guidelines to assist employers in determining which injuries and 
illnesses must be recorded.[Footnote 8] Employers are required to 
maintain a log of recordable injuries and illnesses incurred at each 
worksite. OSHA requires employers to post summaries of these injury 
and illness logs annually at each worksite and provide them to OSHA if 
requested. In addition, under a section of the OSH Act referred to as 
the whistleblower protection provision, employers are prohibited from 
retaliating against employees for taking certain protected actions, 
including reporting work-related injuries or illnesses, and OSHA is 
responsible for investigating workers' complaints of retaliation. 
[Footnote 9] 

To help ensure compliance with federal occupational safety and health 
standards and OSHA's recordkeeping requirements, OSHA conducts 
enforcement activities such as on-site inspections of worksites. OSHA 
conducts these inspections in response to fatalities, serious 
injuries, complaints from workers, and referrals. In addition, OSHA 
targets industries and employers with a high number of workplace 
injuries and illnesses for inspection. When inspecting worksites, OSHA 
inspectors identify hazards that could lead to workers' injuries or 
illnesses, review worksites' injury and illness records, evaluate 
employers' safety and health management systems, and meet with 
employers and worker representatives to discuss their findings and 
possible courses of action to correct hazards and improve their 
systems. Employers that fail to comply with the safety and health 
standards may face sanctions, such as paying penalties for violations. 
In its field operations manual, OSHA provides guidance to inspectors, 
employers, and workers on compliance with safety and health standards, 
inspections, and penalty assessments. 

OSHA Cooperative Programs, Outreach, and Training: 

To help employers comply with safety and health standards and 
recordkeeping requirements, OSHA supplements its enforcement efforts 
with voluntary cooperative programs, outreach, and training in which 
OSHA invites employers to collaborate with the agency and uses a 
variety of methods to encourage employers to adopt practices designed 
to foster safer and healthier working conditions. For example, OSHA's 
Voluntary Protection Programs (VPP) recognize employers with exemplary 
safety and health systems and relatively low injury and illness rates, 
and exempts them from routine inspections.[Footnote 10] Small 
employers that request on-site consultation services may be recognized 
through OSHA's Safety & Health Achievement Recognition Program 
(SHARP), which exempts those with exemplary safety and health 
management systems from routine inspections for up to 3 years. 
[Footnote 11] 

OSHA also trains employers and workers on how to comply with its 
standards and other regulations by, for example, providing online 
materials and reaching out directly to employer and worker groups. For 
example, each OSHA area office typically has one outreach specialist 
who serves as a resource to a variety of groups including businesses, 
trade associations, unions, and community groups.[Footnote 12] 
Outreach specialists provide information on OSHA's cooperative 
programs, training resources, and tools available on the agency's 
website. In addition, during inspections, OSHA's inspectors provide 
information to employers on the strengths and weaknesses of their 
safety and health management systems. 

Workplace Safety and Health Management Systems: 

OSHA encourages employers to take a multifaceted approach to 
preventing and controlling hazards and creating an effective safety 
and health management system or a positive safety culture.[Footnote 
13] According to OSHA, the four elements of an effective safety and 
health management system are as follows: 

(1) Management commitment and employee involvement: 

Employers should develop a safety and health policy, communicate it to 
all employees, and demonstrate commitment to it by, for example, 
instilling accountability for safety and health and ensuring an open 
exchange of information about safety issues. Employees should be 
involved in safety-and health-related activities such as accident 
investigations. 

(2) Worksite analysis: 

Employers should have a thorough understanding of all hazardous 
situations to which employees may be exposed, as well as the ability 
to recognize and correct these hazards. Accurate injury and illness 
records can be used to identify and prevent work-related injuries and 
illnesses. 

(3) Hazard prevention and control: 

Employers should have clear procedures for preventing and controlling 
hazards identified through worksite analysis, such as a hazard 
tracking system and a written system for monitoring and maintaining 
workplace equipment. 

(4) Safety and health training: 

Training is necessary to reinforce and complement management's 
commitment to safety and health and to ensure that all employees 
understand how to avoid exposure to hazards. 

Safety Incentive Programs: 

As part of their safety and health management systems, many employers 
use safety incentive programs to encourage safety in the workplace. 
These programs provide workers with rewards for achieving certain 
safety goals. Examples of these rewards include cash, meals, tangible 
goods, and public recognition. Employers can provide such rewards on 
the basis of individual or group performance depending on the 
program's design. 

There are two types of safety incentive programs: rate-based programs, 
which reward workers for achieving low rates of reported injuries or 
illnesses, and behavior-based programs, which reward workers for 
certain behaviors such as recommending safety improvements (see fig. 
1). Rate-based programs provide workers or groups of workers with 
rewards such as bonuses and prizes for having no or a low number of 
work-related injuries and illnesses during a specified period. For 
example, an employer's rate-based program may reward workers with $100 
bonuses for having no reported work-related injuries or illnesses in a 
given year. Behavior-based programs provide workers or groups of 
workers with rewards for demonstrating safe behaviors but are not tied 
to low injury and illness rates. For example, an employer's behavior-
based program may reward workers with gift cards for identifying 
hazardous conditions and suggesting safety improvements. Some experts 
we interviewed used the term behavior-based safety programs to 
describe an approach to workplace safety that focuses on worker 
behavior as the cause of work-related injuries and illnesses. However, 
in this report, we use the term behavior-based program to define a 
type of safety incentive program that is a component of an employer's 
safety and health management system. These systems may include other 
workplace safety policies such as demerit systems that discipline 
workers for failing to follow safety procedures. 

Figure 1: The Two Types of Safety Incentive Programs: 

[Refer to PDF for image: illustration] 

Rate-based programs: 
Reward workers who had few or no reported injuries or illnesses during 
a set time period. 

Behavior-based programs: 
Reward workers for behaviors such as reporting near-miss incidents or 
recommending safety improvements. 
   
Source: GAO analysis of workplace safety literature. 

[End of figure] 

Other Workplace Safety Policies: 

Employers' safety and health management systems often include other 
workplace safety policies. For example, some employers require the 
participation of frontline workers and management in safety committees 
to help foster communication and address safety-related issues and 
encourage workers to promptly report injuries or illnesses and address 
safety hazards. Other workplace safety policies are designed to 
prevent injuries and illnesses by holding workers accountable for 
using safe work practices. Demerit systems discipline workers for 
unsafe work practices such as failing to follow safety procedures. For 
example, some employers have policies that discipline workers for not 
wearing protective gear or for other unsafe practices linked to 
reported injuries. In addition, some employers have drug and alcohol 
testing policies, which provide for the testing of workers (1) prior 
to employment, (2) at random intervals for some or all workers, (3) at 
scheduled times for all workers, (4) when there is evidence that 
suggests a worker may have used drugs or alcohol, or (5) after a 
workplace incident, such as an injury, occurs. 

Safety Incentive Programs and Policies May Affect Injury and Illness 
Reporting: 

Research on the Effect of Safety Incentive Programs Is Inconclusive, 
but Several Experts Agree Certain Programs and Policies May Discourage 
Reporting: 

Little conclusive academic research exists on whether safety incentive 
programs and other workplace safety policies affect workers' injury 
and illness reporting, but several experts stated that rate-based 
programs may discourage injury and illness reporting. Of the 26 
studies of workplace safety we reviewed, we identified 6 that 
evaluated the effect of safety incentive programs on workplace safety, 
but only 2 of these studies specifically evaluated the programs' 
effect on reporting of injuries.[Footnote 14] Each of the six studies, 
however, had methodological limitations that prevent generalizing the 
effects of these programs on injury and illness reporting for all 
workers.[Footnote 15] 

The six studies that evaluated safety incentive programs reached 
different conclusions about their effect on workplace safety. Three 
studies--including the two that specifically evaluated the programs' 
effect on reporting of injuries--focused on one type of safety 
incentive program and found that their effect on workplace safety was 
inconclusive or that the programs had no effect. For example, one 
study in which nurses were surveyed to determine how often injuries 
and illnesses were reported in their workplaces found that rate-based 
safety incentive programs had no effect on injury reporting.[Footnote 
16] This study relied on perceptions about injury reporting which may 
differ from actual reporting due to, for example, faulty memories, and 
thus its results are not definitive.[Footnote 17] The three studies 
that did not focus on only one type of safety incentive program found 
that the programs reduced injuries; however, these studies did not 
quantify the programs' effect on injury and illness reporting. The 
authors of these studies acknowledged that, when the programs provide 
incentives for not reporting an injury--such as providing a monetary 
reward for having a low injury and illness rate--workers may 
underreport injuries. For example, the authors of one study noted that 
workers may "intentionally fail to report injuries in an effort to 
preserve potential bonuses for their work groups."[Footnote 18] 
Information on the six studies is summarized in table 1. 

Table 1: Studies on the Effect of Safety Incentive Programs on 
Workplace Safety: 

Study author(s) (publication year): Brown et. al. (2005)[A]; 
Dependent measure(s): Reporting of injuries; 
Effect of rate-based programs: No effect; 
Effect of behavior-based programs: Not studied; 
Acknowledgment of potential for underreporting: Yes. 

Study author(s) (publication year): Lauver and Lester (2007)[A]; 
Dependent measure(s): Reported and unreported injuries and near misses; 
Effect of rate-based programs: Not studied; 
Effect of behavior-based programs: No effect; 
Acknowledgment of potential for underreporting: Yes. 

Study author(s) (publication year): Ludwig et. al. (2001); 
Dependent measure(s): Use of safe practices; 
Effect of rate-based programs: Not studied; 
Effect of behavior-based programs: Inconclusive; 
Acknowledgment of potential for underreporting: Not applicable. 

Study author(s) (publication year): Alavosius et. al. (2009); 
Dependent measure(s): Injury rate; 
Effect of rate-based programs: Injury rate reduction[B]; 
Acknowledgment of potential for underreporting: Yes. 

Study author(s) (publication year): Gangwar and Goodrum (2005); 
Dependent measure(s): Injury rate; 
Effect of rate-based programs: Injury rate reduction[B,C]; 
Acknowledgment of potential for underreporting: Yes. 

Study author(s) (publication year): Hinze (2002); 
Dependent measure(s): Injury rate; 
Effect of rate-based programs: No effect; 
Effect of behavior-based programs: Injury rate reduction; 
Acknowledgment of potential for underreporting: Yes. 

Source: GAO analysis. 

[A] The study analyzed workers' perceptions of reporting behavior 
which may differ from actual reporting behavior; therefore, the 
results are not definitive. 

[B] The authors combined rate-based and behavior-based safety 
incentive programs in their analysis; therefore, the effect of each 
type of program on workplace safety could not be determined. 

[C] Injury rate reductions were short-term and occurred a few years 
after the safety programs were implemented. 

[End of table] 

In addition to reviewing existing studies, we interviewed over 50 
experts and industry officials from academia, employer associations, a 
law firm, a consulting firm, unions, and state and federal safety and 
health agencies to obtain their opinions about the effect of safety 
incentive programs and other workplace safety policies on injury and 
illness reporting. Several of them told us that an unintended 
consequence of rate-based programs may be discouraging workers from 
reporting injuries and illnesses. For example, when workers' injuries 
are relatively minor or easy to hide, and if the rewards provided 
under the program are relatively large, workers may not report their 
injuries to preserve their rewards. Potential underreporting of 
injuries and illnesses is even greater when an incentive creates peer 
pressure on workers to not report injuries. For example, when all 
workers on a team get a reward only if no one on the team has an 
injury, there may be pressure on all members of the team to not report 
injuries. According to some experts we interviewed, it is difficult to 
quantify the effect safety incentive programs may have on injury and 
illness reporting partly because researchers do not have access to 
workers' medical records. Without such access, workers who do not 
report their injuries cannot be identified and this information cannot 
be used to explore whether workers' decisions to not report their 
injuries were linked to their employers' safety incentive programs. 

Several experts and industry officials we interviewed also mentioned 
that, along with safety incentive programs, some workplace safety 
policies may discourage workers from reporting injuries and illnesses. 
For example, policies that punish workers for unsafe practices that 
are linked to injuries may--depending on the nature of the injury and 
the policy--inhibit them from reporting injuries. Such policies 
include demerit systems that have consequences for workers who report 
injuries or illnesses, such as giving workers warnings, demotions, or 
terminating them for recurrences. However, some employers use demerit 
systems to discipline workers who engage in unsafe practices such as 
not wearing protective gear, and such demerit systems may have no 
effect on workers' reporting of injuries and illnesses. According to 
officials from a union, workplace safety policies that single out 
workers who report injuries or illnesses by, for example, requiring 
them to wear identifying clothes such as an orange vest, may also 
discourage them from reporting. In addition, according to several 
experts, policies that require drug and alcohol testing after an 
injury is reported--compared to those that are applied on a routine 
basis to all workers--may deter workers from reporting injuries. 
[Footnote 19] We found only one study that evaluated the effect of 
these other workplace safety policies mentioned by experts and 
industry officials as having a potentially adverse effect on injury 
and illness reporting. This study evaluated the effect of post-
incident drug testing on injury and illness reporting and found 
evidence that such testing may discourage reporting of relatively 
minor injuries that are easy to hide.[Footnote 20] 

How Employers Manage Safety Can Affect Injury and Illness Reporting: 

While some safety incentive programs and other workplace safety 
policies may discourage injury and illness reporting, research we 
reviewed indicated that how employers manage safety has a greater 
influence on workers' actions, including whether they are likely to 
report injuries and illnesses, than any one program or policy. Among 
the 26 studies we reviewed, most found that employers that promote a 
positive safety culture may encourage workers to use safe behaviors, 
report injuries and illnesses, or reduce the incidence of injuries and 
illnesses. We identified 21 studies that evaluated the effect of an 
employer's safety culture on workplace safety.[Footnote 21] Of these 
studies, 16 indicated that having a good safety culture has a positive 
effect on workers' use of safe behaviors, injury and illness rates, or 
reporting of injuries and illnesses, and 5 indicated that a good 
safety culture had a mixed or inconclusive effect. 

According to the studies we reviewed, workplaces with a positive 
safety culture placed a strong emphasis on safety by, for example, 
encouraging open communication about safety issues, placing a high 
priority on safety training, and having procedures that prevented 
breakdowns in workplace safety. Some researchers concluded that in 
such environments, workers felt that they could report injuries and 
illnesses without fear of reprisal or blame from management or fellow 
workers. Of the four studies we reviewed that evaluated the effect of 
a positive safety culture on reporting of work-related injuries or 
accidents,[Footnote 22] three found that having a positive safety 
culture increased the likelihood of injury and illness reporting. 
[Footnote 23] Policies that help employers create a positive safety 
culture and keep workers safe and healthy were generally perceived as 
being proactive versus reactive. For example, employers with proactive 
policies that require workers to report near-miss incidents to help 
identify hazards and other safety concerns before an injury takes 
place were more likely to have a positive effect on injury and illness 
reporting. 

In contrast, according to the studies we reviewed, workplaces with a 
negative safety culture do not place a strong emphasis on safety. 
These employers do not encourage open communication about safety 
issues or prioritize safety training. According to two experts we 
interviewed, some employer safety programs focus on workers' behaviors 
as the cause of work-related injuries and illnesses, and have policies 
that discipline workers for failing to follow safety procedures. As a 
result, workers in these environments may be less likely to report 
injuries or illnesses because, if they lack safety training, 
communication is poor, or they are not encouraged to report injuries 
and illness, they may not know how to report them, or may fear being 
disciplined. 

Three-Quarters of U.S. Manufacturers Had Safety Incentive Programs or 
Other Workplace Safety Policies: 

According to our survey, in 2010, an estimated 116,000 of about 
153,000 manufacturers in the United States (75 percent) had safety 
incentive programs or had other workplace safety policies that, 
according to several experts, may affect workers' reporting of 
injuries and illnesses.[Footnote 24] However, we estimated that safety 
incentive programs were less prevalent than other workplace safety 
policies, such as demerit systems, that discipline workers for unsafe 
work practices.[Footnote 25] We also estimated that a quarter of 
manufacturers had some type of safety incentive program and most had a 
demerit system or post-incident drug and alcohol testing policy. 
Demerit systems were the most common policy reported, followed by post-
incident drug and alcohol testing policies (see figure 2).[Footnote 26] 

Figure 2: Manufacturers with Safety Incentive Programs and Other 
Policies, by Type, 2010: 

[Refer to PDF for image: vertical bar graph] 

Type: Rate-based programs; 
Survey Results in Percentages: 22%; 
Upper Bound 95% confidence interval: 26.7%; 
Lower Bound 95% confidence interval: 17.7%. 

Type: Behavior-based programs; 
Survey Results in Percentages: 14%; 
Upper Bound 95% confidence interval: 17.6%; 
Lower Bound 95% confidence interval: 10.5%. 

Type: Post-incident drug and alcohol testing policies; 
Survey Results in Percentages: 56%; 
Upper Bound 95% confidence interval: 62.8%; 
Lower Bound 95% confidence interval: 49%. 

Type: Demerit systems; 
Survey Results in Percentages: 69%; 
Upper Bound 95% confidence interval: 75.6%; 
Lower Bound 95% confidence interval: 62.2%. 

Source: GAO analysis of survey data. 

[End of figure] 

Very few manufacturers had only one type of safety incentive program, 
and few had only one type of other workplace safety policy.[Footnote 
27] Most manufacturers had more than one safety incentive program or 
other workplace safety policy, and more than 20 percent had several, 
according to our estimates.[Footnote 28] For example, one manufacturer 
who participated in our survey had a program that rewarded workers 
with a luncheon for having no injuries that resulted in lost time on 
the job, and provided a separate reward to the worker who submitted 
the best safety suggestion during the month. Manufacturers with 
multiple types of programs or policies were more than twice as likely 
to have a demerit system or conduct post-incident drug and alcohol 
testing than they were to have a rate-based or behavior-based program 
(see figure 3).[Footnote 29] 

Figure 3: U.S. Manufacturers with Only One Program or Other Workplace 
Safety Policy, Compared with Manufacturers with Multiple Programs or 
Other Policies, 2010: 

[Refer to PDF for image: vertical bar graph] 

Type: Rate-based programs; 

Only one type of safety incentive program or other workplace safety 
policy: 0; 
Upper bound 95% confidence interval: 1%; 
Lower bound 95% confidence interval: 0; 
At least one additional type of safety incentive program or other 
workplace safety policy: 22%; 
Upper bound 95% confidence interval: 26.2%; 
Lower bound 95% confidence interval: 17.3%. 

Type: Behavior-based programs; 

Only one type of safety incentive program or other workplace safety 
policy: 0; 
Upper bound 95% confidence interval: 1%; 
Lower bound 95% confidence interval: 0; 
At least one additional type of safety incentive program or other 
workplace safety policy: 13%; 
Upper bound 95% confidence interval: 17%; 
Lower bound 95% confidence interval: 10.1%. 

Type: Post-incident drug and alcohol testing policies; 

Only one type of safety incentive program or other workplace safety 
policy: 6%; 
Upper bound 95% confidence interval: 9.2%; 
Lower bound 95% confidence interval: 3.7%; 
At least one additional type of safety incentive program or other 
workplace safety policy: 49%; 
Upper bound 95% confidence interval: 55.5%; 
Lower bound 95% confidence interval: 42.4%. 

Type: Demerit systems; 

Only one type of safety incentive program or other workplace safety 
policy: 17%; 
Upper bound 95% confidence interval: 22.7%; 
Lower bound 95% confidence interval: 11.6%. 

At least one additional type of safety incentive program or other 
workplace safety policy: 50%; 
Upper bound 95% confidence interval: 57.1%; 
Lower bound 95% confidence interval: 43.8%. 

Source: GAO analysis of survey data. 

[End of figure] 

Large manufacturers were more likely to have safety incentive programs 
and demerit systems than smaller manufacturers.[Footnote 30] We 
estimated that large manufacturers were more than three times as 
likely to have safety incentive programs compared with small 
manufacturers. Although safety incentive programs and other workplace 
safety policies were less common among small manufacturers, most small 
manufacturers had demerit systems and many had post-incident drug and 
alcohol testing policies (see figure 4).[Footnote 31] 

Figure 4: Manufacturers with Safety Incentive Programs and Other 
Workplace Safety Policies, by Size, 2010: 

[Refer to PDF for image: vertical bar graph] 

Type: Rate-based programs; 

Small manufacturers (11 to 49 workers): 12%; 
Lower Bound 95% confidence interval: 7.2%; 
Upper Bound 95% confidence interval: 19.6%; 
Medium manufacturers (50 to 249 workers): 37%; 
Upper Bound 95% confidence interval: 43.1%; 
Lower Bound 95% confidence interval: 29.9%; 
Large manufacturers (250 or more workers): 45%; 
Upper Bound 95% confidence interval: 52.3%; 
Lower Bound 95% confidence interval: 37.6%. 

Type: Behavior-based programs; 

Small manufacturers (11 to 49 workers): 7%; 
Lower Bound 95% confidence interval: 3%; 
Upper Bound 95% confidence interval: 12.3%; 
Medium manufacturers (50 to 249 workers): 22%; 
Upper Bound 95% confidence interval: 27.9%; 
Lower Bound 95% confidence interval: 16.7%; 
Large manufacturers (250 or more workers): 40%; 
Upper Bound 95% confidence interval: 46.7%; 
Lower Bound 95% confidence interval: 32.3%. 

Type: Post-incident drug and alcohol testing policies; 

Small manufacturers (11 to 49 workers): 44%; 
Lower Bound 95% confidence interval: 34.3%; 
Upper Bound 95% confidence interval: 54.1%; 
Medium manufacturers (50 to 249 workers): 75%; 
Upper Bound 95% confidence interval: 81%; 
Lower Bound 95% confidence interval: 69.7%; 
Large manufacturers (250 or more workers): 74%; 
Upper Bound 95% confidence interval: 81.7%; 
Lower Bound 95% confidence interval: 67.1%. 

Type: Demerit systems; 

Small manufacturers (11 to 49 workers): 59%; 
Lower Bound 95% confidence interval: 48.3%; 
Upper Bound 95% confidence interval: 68.7%; 
Medium manufacturers (50 to 249 workers): 85%; 
Upper Bound 95% confidence interval: 89.4%; 
Lower Bound 95% confidence interval: 79.4%; 
Large manufacturers (250 or more workers): 89%; 
Upper Bound 95% confidence interval: 94.6;% 
Lower Bound 95% confidence interval: 81%. 

Source: GAO analysis of survey data. 

[End of figure] 

Companies sometimes request information on manufacturers' injury and 
illness rates before signing a contract with them to manufacture 
goods. According to some workplace safety experts, such contractors 
may feel pressure to lower injury and illness rates to avoid the risk 
of losing bids for contracted work. Manufacturers whose injury and 
illness rates were requested by potential contracting companies were 
more than twice as likely to have rate-based safety incentive programs 
than manufacturers whose rates were not requested.[Footnote 32] We 
estimated that 31 percent of U.S. manufacturers performed contractual 
work in 2010.[Footnote 33] Contracting companies requested injury and 
illness rate data from nearly a third of these manufacturers prior to 
signing a contract with them.[Footnote 34] Thirty-eight percent of 
these manufacturers that had their injury and illness rates requested 
reported having rate-based programs in 2010. In contrast, 13 percent 
of the manufacturers that had did not have their injury and illness 
data requested by potential contracting companies prior to signing a 
contract reported having rate-based programs in 2010. 

U.S. manufacturers provided incentives to workers for a variety of 
safety goals and behaviors. Nearly three-quarters of manufacturers 
with rate-based programs, according to our estimates, rewarded workers 
for having no reported injuries and illnesses.[Footnote 35] Forty 
percent rewarded workers for having a low number or rate of injuries 
and illnesses during a specific time period, and 23 percent of them 
rewarded workers for reducing the number or rate of reported injuries 
and illnesses.[Footnote 36] Nearly 70 percent of manufacturers with 
behavior-based programs rewarded workers for recommending workplace 
safety improvements and 37 percent rewarded them for wearing 
protective gear.[Footnote 37] 

The criteria for providing rewards differed between rate-based and 
behavior-based programs, but the types of rewards manufacturers 
provided and the types of workers targeted by both of these safety 
incentive programs were similar. For both types of programs, monetary 
awards, meals, and other non-monetary awards, such as gift cards, were 
more commonly offered than time off work or a token of recognition, 
such as a plaque.[Footnote 38] Manufacturers used safety incentive 
programs to target various levels of workers and worker groups, 
including entire workplaces, work teams such as department or shifts, 
supervisors, and frontline workers. However, the percentage of 
manufacturers that rewarded individual frontline workers through 
either rate-based or behavior-based safety incentive programs was 
twice as high as those that rewarded supervisors.[Footnote 39] 

OSHA Has Taken Limited Actions to Address Safety Incentive Programs 
and Other Workplace Safety Policies: 

OSHA's Enforcement Efforts Address Safety Incentive Programs and Other 
Workplace Safety Policies to a Limited Extent: 

OSHA can use its enforcement authority to address certain aspects of 
safety incentive programs and other workplace safety policies, but the 
effectiveness of these activities is limited. Although the OSH Act 
does not mandate that OSHA regulate safety incentive programs, OSHA 
officials told us the agency could potentially issue a regulation to 
address safety incentive programs and other workplace safety policies. 
However, OSHA has not done so because, according to OSHA officials, it 
has focused its regulatory resources on other priorities such as 
projects that address exposure to serious safety and health hazards. 
[Footnote 40] Some of OSHA's enforcement tools can be used to address 
certain aspects of safety incentive programs and other workplace 
safety policies, but these tools are not designed to systematically 
address these programs. For example, a worker may file a whistleblower 
protection complaint if the worker reports an injury and, under the 
rules of the employer's safety incentive program, is subsequently 
excluded from receiving a reward, such as a bonus. However, such 
claims may only address the adverse action experienced by an 
individual worker and not address the potential overall negative 
impact a safety incentive program may have on the workplace.[Footnote 
41] 

Under its recordkeeping regulations, OSHA can address recordkeeping 
violations that occur as a result of safety incentive programs and 
other workplace safety policies, but it cannot address potential 
disincentives to injury and illness reporting associated with the 
policies. For example, OSHA can cite employers for failing to properly 
record injuries or illnesses under its recordkeeping 
regulations,[Footnote 42] but the relationship between a safety 
incentive program and potential underreporting of injuries and 
illnesses is not directly addressed in these requirements. To find 
evidence of underreporting, inspectors must interview workers, review 
their medical records, and compare these records to employers' injury 
and illness logs to determine whether an injury or illness occurred 
but was not reflected on the log. 

OSHA has explored the potential effect of safety incentive programs 
and other workplace safety policies on injury and illness reporting 
through its recordkeeping enforcement initiative, which was 
established to determine the accuracy of employers' injury and illness 
logs and identify and correct any mistakes or omissions. OSHA began 
this program in September 2009, and in February 2010 established a 
goal of auditing injury and illness records at approximately 350 
worksites nationwide over a 2-year period. Inspectors compared 
employers' injury and illness logs to workers' medical records, and 
interviewed workers, managers, recordkeepers, and first-aid providers. 
As part of these audits, OSHA directed inspectors to consider the 
effect of safety incentive programs or other workplace safety policies 
on injury and illness reporting, and when recordkeeping violations 
were found, in assessing the severity of the violation. For example, 
according to OSHA officials, if inspectors found underreporting of 
injuries and illnesses and concluded that a safety incentive program 
was a contributing factor, the inspector could classify the violation 
as willful, which carries an increased penalty.[Footnote 43] However, 
the guidance provided to inspectors did not specify how this 
assessment should be done and, in our interviews with OSHA area office 
officials we found that OSHA inspectors inconsistently considered 
safety incentive programs when reviewing employers' injury and illness 
records. For example, one area office official said that the penalty 
assessment for a recordkeeping violation would be the same regardless 
of the existence of a safety incentive program. In addition, because 
OSHA did not select a nationally representative sample of worksites 
for these inspections, OSHA cannot use the results to determine the 
effect of safety incentive programs and other workplace safety 
policies on injury and illness reporting nationwide.[Footnote 44] 

OSHA Has Guidance on Safety Incentive Programs for One of Its 
Cooperative Programs but Has Not Adopted Similar Guidance for Other 
Efforts: 

OSHA has developed policy guidance on safety incentive programs for 
the VPP, but the guidance for its other cooperative programs and for 
its enforcement efforts does not address safety incentive programs or 
other workplace safety policies. For example, OSHA's guidance on its 
SHARP program, a voluntary cooperative program that focuses on smaller 
employers, does not address safety incentive programs. Similarly, 
OSHA's field operations manual does not provide guidance to its 
inspectors for addressing safety incentive programs during inspections. 

In June 2011, OSHA issued a policy memorandum for the VPP program that 
contains specific criteria for safety incentive programs, including 
the types of programs that are encouraged for VPP sites and those that 
are prohibited. Programs that promote accurate injury and illness 
reporting are encouraged, while participants in the VPP are now 
prohibited from having safety incentive programs that focus on the 
number of injuries and illnesses, such as rate-based programs that 
reward workers for achieving low injury and illness rates. This policy 
memorandum does not address other workplace safety policies that might 
impact injury and illness reporting. OSHA officials are required to 
ensure current VPP participants are in compliance with this policy 
when participants are reevaluated to determine whether they will be 
allowed to continue to participate in the program, but the new policy 
is not included in the VPP manual. Officials from one regional office 
estimated that almost 20 percent of its VPP participants have safety 
incentive programs that are not in compliance with this new policy. 

In addition to providing guidance on its voluntary cooperative 
programs, OSHA often provides safety information to employers during 
its on-site inspections. In its guidance on conducting inspections, 
OSHA's field operations manual outlines the educational duties that 
inspectors have as part of the inspection process. For example, 
inspectors are expected to discuss the strengths and weaknesses of the 
employers' safety and health management system and advise the employer 
of the benefits of effective systems during the closing conference of 
the inspection. However, the field operations manual does not make any 
references to safety incentive programs or other workplace safety 
policies. 

Other OSHA resources lack guidance about safety incentive programs and 
other workplace safety policies. Outreach specialists and materials 
available on OSHA's website are additional sources of information that 
can educate employers and workers about how safety incentive programs 
and other workplace safety policies may affect a workplace's safety 
and health management system. Although outreach specialists each 
develop materials and approaches for addressing the needs of employers 
in their particular geographic area, each has an opportunity to 
discuss the potential risks and benefits of safety incentive programs 
and the potential impact of workplace safety policies on injury and 
illness reporting during discussions about recordkeeping, safety and 
health management systems, and OSHA's cooperative programs, among 
other topics. In addition, many resources are available to employers 
through OSHA's website, including fact sheets about recordkeeping and 
best practices, such as the Effective Workplace Safety and Health 
Management Systems fact sheet. This fact sheet and several others do 
not discuss safety incentive programs or other workplace safety 
policies, although some do address aspects of a positive safety 
culture. 

Conclusions: 

Safety incentive programs exist in the context of a workplace's safety 
culture. Some types of programs, particularly those that are tied to 
low injury and illness rates, may discourage injury or illness 
reporting. However, the same programs in workplaces with positive 
safety cultures may have no effect with regard to reporting. 
Similarly, some workplace safety policies, such as those that punish 
workers in some way for reporting injuries or illnesses, may 
discourage workers from reporting injuries and illnesses, especially 
when implemented in a workplace with a negative safety culture. 

Because OSHA relies heavily on accurate injury and illness reporting 
in tailoring its programs and allocating its finite enforcement 
resources, it is important for the agency to assess the impact of 
safety incentive programs and certain workplace safety policies on 
injury and illness reporting, particularly given their prevalence. 
Without accurate data, employers engaged in hazardous activities can 
avoid inspections and may be allowed to participate in voluntary 
programs that reward employers with exemplary safety and health 
management systems by exempting them from routine inspections. 

OSHA can encourage employers to create positive safety cultures and 
avoid safety incentive programs and workplace safety policies that may 
have a negative effect on injury and illness reporting. However, 
because safety incentive programs and certain workplace safety 
policies are not addressed in OSHA guidance, including its field 
operations manual, OSHA inspectors may not consider these programs and 
policies during worksite inspections, even as they observe key aspects 
of the workplace's safety culture. As a result, inspectors may miss 
opportunities to educate employers about the benefits of promoting a 
positive safety culture and avoiding prevalent programs and policies 
that can discourage accurate reporting of injuries and illnesses. In 
addition, in the absence of consistent guidance on the potential 
benefits and risks of some safety incentive programs and workplace 
safety policies, OSHA may recognize some employers as having exemplary 
safety and health management systems without considering the 
potentially negative effects of some of their programs and policies. 

Recommendations for Executive Action: 

To increase consistency across OSHA's cooperative programs, the 
Secretary of Labor should direct the Assistant Secretary of OSHA to 
implement criteria on safety incentive programs and other workplace 
safety policies across all of its cooperative programs such as VPP and 
SHARP. The criteria should be consistent with the most recent VPP 
guidance memorandum that prohibits employers with safety incentive 
programs that focus on injury and illness rates from participating in 
the program. 

To help OSHA inspectors consistently educate employers about the 
importance of safety culture, the Secretary of Labor should direct the 
Assistant Secretary of OSHA to add language about key elements of a 
positive safety culture--and the potential effect of different types 
of safety incentive programs and other workplace safety policies--to 
its field operations manual. 

Agency Comments: 

We provided a draft of this report to Labor for review and comment. 
Labor's Assistant Secretary for OSHA provided written comments, which 
are reproduced in appendix IV. OSHA agreed with our recommendations 
and emphasized the agency's concern about workplace programs that 
appear to encourage safe work practices but actually discourage 
workers from reporting injuries. OSHA also provided technical 
comments, which we incorporated as appropriate. 

In response to our recommendation that OSHA implement criteria on 
safety incentive programs and other workplace safety policies across 
all of its cooperative programs such as VPP and SHARP, OSHA stated 
that it will provide policy guidance about safety incentive programs 
across the agency's cooperative programs. According to OSHA, this 
guidance will be similar to the VPP policy prohibiting participants 
from using safety incentive programs that have the potential to 
discourage workers from reporting injuries. Establishing such criteria 
across all of its cooperative programs will help OSHA accurately 
recognize employers with exemplary safety and health management 
systems. 

In response to our recommendation that OSHA add language about key 
elements of a positive safety culture--and the potential effect of 
different types of safety incentive programs and other workplace 
safety policies--to its field operations manual, OSHA stated that it 
has issued guidance for its inspectors about safety incentive programs 
that underscores the agency's position that programs that discourage 
workers from reporting injuries may violate whistleblower protection 
statutes and OSHA's recordkeeping regulations. OSHA issued this 
guidance to regional and whistleblower program officials in March 2012 
and published it on the agency's website, but it has not yet been 
incorporated into the agency's field operations manual. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies of this report 
to the Secretary of Labor, relevant congressional committees, and 
other interested parties. In addition, the report will also be 
available at no charge on GAO's website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have questions about this report, please contact 
me at (202) 512-7215 or moranr@gao.gov. Contact points for our Offices 
of Congressional Relations and Public Affairs may be found on the last 
page of this report. Key contributors to this report are listed in 
appendix V. 

Signed by: 

Revae E. Moran: 
Director, Education, Workforce, and Income Security Issues: 

List of Congressional Requesters: 

The Honorable Tom Harkin:
Chairman:
Committee on Health, Education, Labor and Pensions:
United States Senate: 

The Honorable Patty Murray:
Chairman:
Subcommittee on Employment and Workplace Safety:
Committee on Health, Education, Labor and Pensions:
United States Senate: 

The Honorable George Miller:
Ranking Member:
Committee on Education and the Workforce:
House of Representatives: 

The Honorable Lynn Woolsey:
Ranking Member:
Subcommittee on Workforce Protections:
Committee on Education and the Workforce:
House of Representatives: 

[End of section] 

Appendix I: Scope and Methodology: 

Literature Review and Expert Input on Safety Incentive Programs and 
Other Workplace Safety Policies That May Affect Injury and Illness 
Reporting: 

To determine what is known about the effect of workplace safety 
incentive programs and other workplace safety policies on injury and 
illness reporting, we conducted a literature search for relevant 
studies. We sought studies that analyzed the effect of workplace 
safety incentive programs; other workplace safety policies, such as 
post-incident drug testing; or safety culture on workers' use of safe 
practices; injury and illness rates; or reporting of injuries and 
illnesses. To identify the studies, we searched bibliographic 
databases covering scientific, safety, medical, and economic 
literature, including ArticleFirst, CINAHL, EconLit, Electronic 
Collections Online, EMBASE, MEDLINE, ProQuest, PsycINFO, SciSearch, 
and Social SciSearch for relevant search terms and citations of 
studies. We limited the searches to materials published in 2001 or 
after. We performed these searches from August 2011 to October 2011, 
and identified over 600 abstracts of studies. Among these studies, we 
excluded those that did not satisfy our criteria that each study (1) 
be published in a peer-reviewed journal and (2) contain relevant, 
primary research conducted in the United States. We also excluded 
studies that seemed duplicative or did not meet GAO's methodological 
standards. To assess the methodological quality of the studies, two 
GAO research methodologists independently reviewed each study that 
satisfied our criteria and excluded those that did not contain 
original research or lacked rigor. Using this approach, we identified 
26 methodologically sound studies (see app. II for a list of the 26 
studies). 

To supplement our understanding of what is known about the effect of 
safety incentive programs and other workplace safety policies on 
injury and illness reporting, we interviewed experts and industry 
officials from academia, employer associations, a law firm, a 
consulting firm, unions, and state and federal occupational safety and 
health agencies. We spoke with individuals from the University of 
Connecticut, Boston University, Institute for Work and Health, United 
Steel Workers, United Mine Workers of America, American Federation of 
Labor and Congress of Industrial Organizations, National Association 
of Manufacturers, Mercer, Voluntary Protection Programs Participants' 
Association, Gibson, Dunn & Crutcher, Occupational Safety and Health 
Administration (OSHA), Bureau of Labor Statistics (BLS), National 
Institute for Occupational Safety and Health, Chemical Safety Board, 
and state occupational safety and health agencies in California, North 
Carolina, South Carolina, and Vermont. To identify these experts and 
industry officials, we reviewed relevant trade press and congressional 
transcripts and sought referrals from interviewees. To ensure balance, 
we spoke with an array of experts and industry officials with varying 
backgrounds and perspectives. 

Survey of Manufacturing Worksites: 

To study the prevalence of workplace safety incentive programs as well 
as other workplace safety policies that may affect injury and illness 
reporting, we surveyed a nationally representative sample of 
manufacturing worksites. We selected a systematic random sample of 
1,000 manufacturers from a total of 26,552 included in our sample 
frame of data. Our sample frame consisted of the set of manufacturers 
with 11 or more employees contained in a nationally representative BLS 
establishment survey fielded in 2010. This list was a relatively 
complete, current source of business names and addresses that had 
undergone a strict refinement process to remove establishments that 
were out of business, duplicates, or miscoded. We sorted the 
manufacturers by the sample weight for the BLS survey prior to the 
systematic random selection in order to ensure that a range of 
manufacturers was obtained. 

We designed and implemented a dual mode survey (mail and web-based) to 
obtain information from manufacturers on the types and characteristics 
of safety incentive programs and policies used at their workplaces, 
and the extent to which they performed contractual work for other 
companies. To develop our survey questions, we drew on information we 
gathered from interviews with occupational safety and health 
stakeholders and from scholarly studies on occupational safety and 
health. We pretested the survey with nine manufacturers that 
represented the three size populations of manufacturers studied 
(small, medium, and large) and submitted the questionnaire for an 
additional independent review by two survey specialists within GAO and 
experts in OSHA and BLS. We then made revisions based on their 
feedback prior to finalizing the survey. We conducted the survey using 
a self-administered questionnaire, and offered prospective respondents 
the option of completing and mailing a hard copy questionnaire or 
completing the questionnaire online (see app. III for a copy of the 
survey). To encourage participation, we mailed a reminder postcard, a 
second questionnaire, and made follow-up phone calls to all those who 
had not yet responded in regular intervals prior to closing the 
survey. A total of 663 manufacturers responded, resulting in a final 
weighted response rate of 62.4 percent. 

Because we surveyed a sample of manufacturers, the survey results are 
weighted estimates for a population of manufacturers and thus are 
subject to sampling errors associated with samples of this size and 
type. Our sample is only one of a large number of samples we might 
have drawn. As each sample could have provided different estimates, we 
expressed our confidence in the precision of our particular sample's 
results as a 95 percent confidence interval (e.g., plus or minus 10 
percentage points). We excluded 29 of the sampled manufacturers 
because we were able to determine that they were out of business at 
the time of our survey or they indicated that they did not engage in 
manufacturing. Therefore, all 29 of the manufacturers we excluded were 
considered out of scope. All estimates produced from the sample and 
presented in this report are representative of the in-scope population. 

The practical difficulties of conducting any survey may introduce 
errors resulting from the data collection procedures, commonly 
referred to as nonsampling errors, which can introduce unwanted 
variability into the survey results. There are four primary sources of 
nonsampling error: 

1. Measurement--error in responses recorded on the survey instruments 
resulting from poorly worded, biased, or sensitive questions; 
ambiguous instructions; or lack of information available to 
respondents. 

2. Nonresponse--bias from failing to get responses from establishments 
whose answers would have differed significantly from those that did 
participate. 

3. Coverage--bias from failing to include all eligible establishments 
or from including ineligible establishments in the list from which we 
sampled. 

4. Data processing--error arising from faulty handling or processing 
of the data. 

We took extensive steps in developing the questionnaire, collecting 
the data and analyzing the results to address the potential sources of 
nonsampling error. To minimize measurement error, GAO staff with 
subject-matter expertise collaborated with a survey design specialist 
to develop the questionnaire. We pretested the instrument using 
cognitive interviewing techniques and interviewed the pretest 
respondents to ensure that (1) the questions and instructions were 
clear, unambiguous, and in the correct order; (2) the terms we used 
were precise; (3) the survey did not place an undue burden on the 
respondents completing it; and (4) the survey was unbiased. To assess 
the risk of nonresponse bias, we obtained answers over the phone to 
three survey questions from 19 nonrespondents. We statistically 
compared the answers from the nonrespondents with those of our 
respondents on these three questions and found no statistically 
significant differences. Our sample frame minimized the risk of 
coverage error by drawing on a nationally representative list of 
manufacturers that was thoroughly reviewed and cleaned to remove 
ineligible establishments. Finally, we took several steps to reduce 
processing errors: (1) Quality control measures were implemented 
during preparation and mailout of survey packages to ensure that the 
respondents would receive the package with the proper login 
identification number and that the packages contained the correct 
contents. (2) We contracted with an outside company to enter the data 
from the paper questionnaires into a database, and we checked a 10 
percent sample of the database as a quality control measure. (3) 
Respondents who completed questionnaires online entered their answers 
directly which eliminated the errors associated with a manual data 
entry process. (4) After we analyzed the data, a second independent 
data analyst checked all of the computer programs for accuracy. 

Examination of OSHA's Efforts to Address Safety Incentive Programs and 
Workplace Policies: 

To examine OSHA's efforts to address safety incentive programs, we 
reviewed relevant federal laws and regulations, OSHA's policies and 
procedures, and interviewed OSHA officials regarding the agency's 
activities. We interviewed selected OSHA officials from the agency's 
national office as well as several regional and area offices to learn 
about (1) their efforts to address the potential impact of safety 
incentive programs and workplace policies on injury and illness 
reporting, (2) the recordkeeping enforcement initiative, and (3) their 
views on safety incentive programs and the potential relationship 
between these programs and injury and illness reporting. We 
interviewed officials from three regional offices and five area 
offices representing 5 of the 10 different OSHA regions. In all of 
these interviews we attempted to meet with regional and area office 
officials with experience in the recordkeeping enforcement initiative 
and those that oversee cooperative programs and other outreach and 
training efforts. We visited five OSHA offices and spoke with 
officials from four state occupational safety and health agencies. We 
selected these offices based on their geographic dispersal and 
representation of OSHA regions. 

To assess the results of OSHA's recordkeeping enforcement initiative, 
we analyzed data from the OSHA Recordkeeping Inspection Assistant 
database, which contains records of the inspections OSHA conducted in 
2009, 2010, and 2011. Prior to our analysis, we assessed the 
reliability of the OSHA Recordkeeping Inspection Assistant database by 
reviewing information obtained from OSHA about the database, and 
interviewing a knowledgeable agency official. Where there were 
discrepancies in the data, we worked with this official to clarify 
and, in some cases, correct the data. For example, we found two 
records that were missing key identifying information about the OSHA 
region in which the inspections occurred. On the basis of our 
assessment, we concluded that the updated data were sufficiently 
reliable for our reporting purposes. 

We conducted this performance audit from September 2010 to April 2012 
in accordance with generally accepted government auditing standards. 
These standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Studies on the Effect of Safety Incentive Programs, 
Workplace Safety Policies, and Safety Culture on Workplace Safety: 

Alavosius, Mark, Jim Getting, Joseph Dagen, William Newsome, and Bill 
Hopkins. "Use of a Cooperative to Interlock Contingencies and Balance 
the Commonwealth." Journal of Organizational Behavior Management, vol. 
29, no. 2 (2009): 193-211. 

Brown, Jean Geiger, Alison Trinkoff, Kenneth Rempher, Kathleen 
McPhaul, Barbara Brady, Jane Lipscomb, and Charles Muntaner. "Nurses 
Inclination to Report Work-Related Injuries: Organizational, Work-
Group, and Individual Factors Associated with Reporting." AAOHN 
Journal, vol. 53, no. 5 (2005): 213-217. 

Chowdhury, Sanjib K., and Megan Lee Endres. "The Impact of Client 
Variability on Nurses' Occupational Strain and Injury: Cross-Level 
Moderation by Safety Climate." Academy of Management Journal, vol. 53, 
no. 1 (2010): 182-198. 

DeJoy, David M., Lindsay J. Della, Robert J. Vandenberg, Mark G. 
Wilson. "Making Work Safer: Testing a Model of Social Exchange and 
Safety Management." Journal of Safety Research, vol. 41, no.2 (2010): 
163-171. 

Evans, Demetrice D., Judd H. Michael, Janice K. Wiedenbeck, and 
Charles D. Ray. "Relationships Between Organizational Climates and 
Safety-Related Events at Four Wood Manufacturers." Forest Products 
Journal, vol. 55, no. 6 (2005): 23-28. 

Fugas, Carla S., José L. Meliá, and Silvia A. Silva. "The "Is" and the 
"Ought": How Do Perceived Social Norms Influence Safety Behaviors at 
Work?" Journal of Occupational Health Psychology, vol. 16, no. 1 
(2011): 67-79. 

Gangwar, Manish, and Paul M. Goodrum. "The Effect of Time on Safety 
Incentive Programs in the US Construction Industry." Construction 
Management and Economics, vol. 23, no. 8 (2005): 851-859. 

Hinze, Jimmie. "Safety Incentives: Do They Reduce Injuries?" Practice 
Periodical on Structural Design and Construction, vol. 7, no. 2 
(2002): 81-84. 

Hofmann, David A., and Barbara Mark. "An Investigation of the 
Relationship Between Safety Climate and Medication Errors As Well As 
Other Nurse and Patient Outcomes." Personnel Psychology, vol. 59, no. 
4 (2006): 847-869. 

Hoonakker, Peter, Todd Loushine, Pascale Carayon, James Kallman, 
Andrew Kapp, and Michael J. Smith. "The Effect of Safety Initiatives 
on Safety Performance: A Longitudinal Study." Applied Ergonomics, vol. 
36, no. 4 (2005): 461-469. 

Huang,Yueng-Hsiang, Michael Ho, Gordon S. Smith, and Peter Y. Chen. 
"Safety Climate and Self-Reported Injury: Assessing the Mediating Role 
of Employee Safety Control." Accident Analysis and Prevention, vol. 
38, no. 3 (2006): 425-433. 

Lauver, Kristy J., Chris Quinn Trank, and Huy Le. "Information by 
Design: How Employee Perceptions of Organizational Design Relate to 
Injury Reporting." Journal of Leadership and Organizational Studies, 
vol. 18, no. 3 (2011): 344-352. 

Lauver, Kristy J., and Scott W. Lester. "Get Safety Problems to the 
Surface: Using Human Resource Practices to Improve Injury Reporting." 
Journal of Leadership and Organizational Studies, vol. 14, no. 2 
(2007): 168-179. 

Leiss, Jack K. "Management Practices and Risk of Occupational Blood 
Exposure in U.S. Paramedics: Needlesticks." American Journal of 
Industrial Medicine, vol. 53, no. 9 (2010): 866-874. 

Ludwig,Timothy D., Jay Biggs, Sandra Wagner, and E. Scott Geller. 
"Using Public Feedback and Competitive Rewards to Increase the Safe 
Driving of Pizza Deliverers." Journal of Organizational Behavior 
Management, vol. 21, no. 4 (2001): 75-104. 

Mark, Barbara A., Linda C. Hughes, Michael Belyea, Yunkyung Chang, 
David Hofmann, Cheryl B. Jones, and Cynthia T. Bacon. "Does Safety 
Climate Moderate the Influence of Staffing Adequacy and Work 
Conditions on Nurse Injuries?" Journal of Safety Research, vol. 38, 
no. 4 (2007): 431-446. 

Michael, Judd H., Zhen George Guo, Janice K. Wiedenbeck, Charles D. 
Ray. "Production Supervisor Impacts on Subordinates' Safety Outcomes: 
An Investigation of Leader-Member Exchange and Safety Communication." 
Journal of Safety Research, vol. 37, no. 5 (2006): 469-477. 

Morantz, Alison D., and Alexandre Mas. "Does Post-Accident Drug 
Testing Reduce Injuries? Evidence from a Large Retail Chain." American 
Law and Economics Review, vol. 10, no. 2 (2008): 246-302. 

Morrow, Stephanie L., Alyssa K. McGonagle, Megan L. Dove-Steinkamp, 
Curtis T. Walker Jr., Matthew Marmet, and Janet L. Barnes-Farrell. 
"Relationships Between Psychological Safety Climate Facets and Safety 
Behavior in the Rail Industry: A Dominance Analysis." Accident 
Analysis and Prevention, vol. 42, no. 5 (2010): 1460-1467. 

Probst, Tahira M., and Armando X. Estrada. "Accident Under-Reporting 
Among Employees: Testing the Moderating Influence of Psychological 
Safety Climate and Supervisor Enforcement of Safety Practices." 
Accident Analysis and Prevention, vol. 42, no. 5 (2010): 1438-1444. 

Probst, Tahira M., Ty L. Brubaker, and Anthony Barsotti. 
"Organizational Injury Rate Underreporting: The Moderating Effect of 
Organizational Safety Climate." Journal of Applied Psychology, vol. 
93, no. 5 (2008): 1147-1154. 

Seo, Dong-Chul. "An Explicative Model of Unsafe Work Behavior." Safety 
Science, vol. 43, no. 3 (2005): 187-211. 

Smith, Gordon S., Yueng-Hsiang Huang, Michael Ho, and Peter Y. Chen. 
"The Relationship Between Safety Climate and Injury Rates Across 
Industries: The Need to Adjust for Injury Hazards." Accident Analysis 
and Prevention, vol. 38, no. 3 (2006): 556-562. 

Vredenburgh, Alison G. "Organizational Safety: Which Management 
Practices are Most Effective in Reducing Employee Injury Rates?" 
Journal of Safety Research, vol. 33, no. 2 (2002): 259-276. 

Wallace, Craig, and Gilad Chen. "A Multilevel Integration of 
Personality, Climate, Self-Regulation, and Performance." Personnel 
Psychology, vol. 59, no. 3 (2006): 529-557. 

Zohar, Dov, and Gil Luria. "The Use of Supervisory Practices as 
Leverage to Improve Safety Behavior: A Cross-Level Intervention 
Model." Journal of Safety Research, vol. 34, no. 5 (2003): 567-577. 

[End of section] 

Appendix III: Questionnaire Used for GAO's Survey of Manufacturing 
Worksites: 

Survey of Workplace Safety Incentive Programs and Practices: 

Introduction: 

The U.S. Congress has requested that the Government Accountability 
Office (GAO) provide information about workplace safety incentive 
programs and practices aimed at reducing work-related injuries and 
illnesses. We are surveying a representative sample of U.S. 
manufacturing-related establishments to better understand existing 
safety incentive programs and practices, as well as basic injury and 
illness recordkeeping practices. Your establishment was randomly 
selected from a national listing of manufacturing-related 
establishments based on size. Because your establishment is part of a 
statistical sample, your cooperation is critical to providing the 
Congress complete and balanced information on the types of safety 
incentive programs and practices typically found in manufacturing-
related establishments. This questionnaire should take about 10 
minutes to complete. 

The results of this questionnaire will be used to compile descriptive 
information on safety incentive programs and practices. GAO is not an 
enforcement agency and will not use responses for inspection, 
targeting, or other enforcement activities. In reporting the results 
of this questionnaire, we will only present aggregated data, not 
information that identifies any individual respondent, location, or 
company. 

Instructions: 

This questionnaire should be completed by the person most familiar 
with safety programs and practices at your establishment. Some 
questions require knowledge about your establishment's injury and 
illness recordkeeping practices. More than one person may complete 
this questionnaire so please feel free to consult with colleagues, as 
needed. 

The questionnaire is divided by topic into three short sections: (1) 
Workplace Safety Incentive Programs and Practices; (2) Injury and 
Illness Records; and (3) Final Comments. 

Please complete the questionnaire within 10 business days of receipt. 
There are three ways to submit this questionnaire: 

(1) Online: Go to [hyperlink, 
https://websurveys.gao.gov/workplacesafety] and enter the user name
and password provided on the enclosed postcard to complete the 
questionnaire online; or; 

(2) By Mail: Send the completed questionnaire in the enclosed pre-
addressed business reply envelope to U.S Government Accountability 
Office; Attn: Joel Green; 301 Howard Street, Suite 1200; San 
Francisco, CA 94105-2252; or; 

(3) By Fax: Fax the completed questionnaire to (202) 512-2514, Attn: 
Jim Lloyd. 

If you have any questions, please call Jim Lloyd toll-free at 1-855-
384-7949 or send an email to: safetysurvey@gao.gov. 

Thank you for your time and assistance! 

Questionnaire Instructions and Definitions: 

Please check the box next to or below the appropriate response. For 
purposes of this questionnaire: 

- "Establishment" refers to the worksite located at the address on the 
cover letter; 

- "In calendar year 2010" refers to any period of time during the year 
regardless of duration; 

- "Injuries" and "illnesses" refer to work-related injuries and 
illnesses. 

Section 1: Workplace Safety Incentive Programs and Practices: 

Some establishments provide workers rewards to help prevent injuries 
and illnesses. Two common types of programs or practices that reward 
workers include: (1) rewarding employees for reporting few or no work-
related injuries and illnesses during a particular time period, for 
example giving bonuses to employees who went 3 months without a 
reported injury; and (2) rewarding employees for using safety 
practices that may help prevent injuries and illnesses, for example 
giving bonuses to employees who identify hazardous conditions. 

1. In calendar year 2010, did your establishment offer rewards to 
employees for having few or no work-related reported injuries and 
illnesses? (Please mark Yes or No) 
Yes: 
No: 
Not Sure: 

2. In calendar year 2010, did your establishment offer rewards to 
employees for meeting any of the following goals? (Please mark Yes or 
No for each item) 

No reported injuries or illnesses during a certain time: 
Yes: 
No: 
Not Sure: 

Low number or rate of reported injuries or illnesses during a certain 
time: 
Yes: 
No: 
Not Sure: 

Reduction in the number or rate of reported injuries or illnesses from
one time to the next: 
Yes: 
No: 
Not Sure: 

Other: 
Yes: 
No: 
Not Sure: 

(If "Other," please specify) 

3. In calendar year 2010, did your establishment offer rewards to 
employees for using safety practices such as the practices listed 
below in question 4? (Please mark Yes or No) 
Yes: 
No: 
Not Sure: 
  
4. In calendar year 2010, did your establishment offer rewards to 
employees for using any of the following safety practices? (Please 
mark Yes or No for each item) 

Wearing protective gear: 
Yes: 
No: 
Not Sure: 

Attending safety training: 
Yes: 
No: 
Not Sure: 

Notifying management of near-miss incidents: 
Yes: 
No: 
Not Sure: 

Identifying hazards or hazardous conditions: 
Yes: 
No: 
Not Sure: 

Recommending health or safety improvements: 
Yes: 
No: 
Not Sure: 

Being part of a safety team: 
Yes: 
No: 
Not Sure: 

Other: 
Yes: 
No: 
Not Sure: 

(If "Other," please specify)  
  
5. In calendar year 2010, were the following used to reward employees 
for the two common types of programs or practices listed below?  
(For each item, please mark Yes or No under column (1] and column 
[2])   

Monetary award (for example, bonus): 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Food or meals: 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Time off of work: 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Certificate of recognition, plaque or trophy: 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Other non-monetary award (for example, gift card or t-shirt): 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Bingo (for example, "Safety Bingo"): 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Scratch-off cards (for example, "Safety Jackpot"): 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Drawing or raffle: 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Other: 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

(If "Other," please specify) 

6. In calendar year 2010, who received rewards for the two common 
types of programs or practices listed below? (For each item, please 
mark Yes or No under column (1] and column [2])   

Entire company: 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Entire establishment:  
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Work teams, departments, or shifts: 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Individual manager or supervisor: 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Injury and illness recordkeeper: 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Individual front-line worker (non-manager): 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

Other: 
[1] Reward for having few or no reported injuries or illnesses: 
Yes: 
No: 
Not Sure: 
[2] Reward for using safety practices: 
Yes: 
No: 
Not Sure: 

(If "Other," please specify) 
  
7. In your opinion, do you think rewards valued at the amounts  below 
help prevent work-related injuries and illnesses for the two common 
types of programs or practices listed below? (For each reward amount, 
please choose one response under column [1] and one response under 
column [2]. 

Less than $10: 
Great Extent: 
Some Extent: 
No Extent: 
Not Sure: 

$10 to less than $100: 
Great Extent: 
Some Extent: 
No Extent: 
Not Sure: 

$100 to less than $1000: 
Great Extent: 
Some Extent: 
No Extent: 
Not Sure: 

$1,000 or more: 
Great Extent: 
Some Extent: 
No Extent: 
Not Sure: 

8. In calendar year 2010, did your establishment have a policy or 
practice of disciplining employees for certain unsafe practices (for 
example, not wearing protective gear or not notifying management of 
near-miss incidents)? (Please mark Yes or No for each item) 
Yes: 
No: 
Not Sure: 

9. In calendar year 2010, did your establishment have a policy or 
practice of testing employees for alcohol or drugs after their 
involvement in injury-causing incidents (aside from any driving 
accidents, as required by law)? (Please mark Yes or No for each item) 
Yes: 
No: 
Not Sure: 
 
10. If there are any other issues, details, or information concerning 
safety incentive programs or practices at your establishment that you 
would like us to know about, please use the space below to provide 
this information.
 
Section 2: Injury and Illness Recordkeeping Practices: 

Some questions in this section require knowledge about your 
establishment's injury and illness recordkeeping practices. Please 
feel free to consult colleagues as needed.  

11. In calendar year 2010, did your establishment perform work under 
contract for the U.S. government, for example, the U.S. Department of 
Defense? (Please mark Yes or No) 
Yes: 
No: 
Not Sure: 
 
12. In calendar year 2010, did your establishment perform any work 
under contract for another company? (Please mark Yes or No) 
Yes: (Continue to Question 13); 
No: (Skip to Question 14); 
Not Sure: (Skip to Question 14). 

13. Has your establishment's injury and illness record ever been 
requested by any potential contracting company? (Please mark Yes or No) 
Yes: 
No: 
Not Sure: 

If you have any additional details, please provide below]):  

14. In calendar year 2010, were you responsible for maintaining OSHA's 
Form 300 (or equivalent) for logging work-related injury or illness? 
(Please mark Yes or No) 
Yes: (Continue to Question 15); 
No: (Skip to Question 18); 
Not Sure: (Skip to Question 18). 
 
15. In calendar year 2010, were you ever unsure of whether or how to 
record an injury or illness? (Please mark Yes or No) 
Yes: 
No: 
Not Sure: 
 
16. In calendar year 2010, did you ever feel you needed more training 
or guidance on recording work-related injuries or illnesses on OSHA's 
Form 300 (or equivalent)? (Please mark Yes or No) 
Yes: 
No: 
Not Sure: 
 
17. Which types of training or guidance on recording work-related 
injuries and illnesses on OSHA's Form 300 (or equivalent) would you 
find helpful? (Please mark Yes or No for each item) 

Training:  

On-the-job training by a supervisor or colleague: 
Yes: 
No: 
Not Sure: 

From a third-party (for example, private expert at conferences or 
workshops): 
Yes: 
No: 
Not Sure: 

From OSHA at conferences or workshops: 
Yes: 
No: 
Not Sure: 

OSHA webinar(s): 
Yes: 
No: 
Not Sure: 

Guidance:  

More guidance from OSHA available via a toll-free phone number: 
Yes: 
No: 
Not Sure: 

More written guidance from OSHA available online: 
Yes: 
No: 
Not Sure: 

Other: 
Yes: 
No: 
Not Sure: 

(If "Other," please specify)   

Section 3: Final Comments: 

18. Please use the space below to provide any additional information 
about workplace safety and
recordkeeping practices that you would like us to know about. 

You've reached the end of the questionnaire. 

Thank you for your participation! 

Please return the questionnaire as described on the cover page. 

[End of section] 

Appendix IV: Comments from the Department of Labor: 

U.S. Department of Labor: 
Assistant Secretary for Occupational Safety and Health: 
Washington, D.C. 20210: 

March 20, 2012: 

Ms. Revae E. Moran, Director: 
Education, Workforce, and Income Security Issues: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

Dear Ms. Moran: 

Thank you for the opportunity to comment on the Government 
Accountability Office's (GAO) report, Better OSHA Guidance Needed On 
Safety Incentive Programs. The following comments are submitted on 
behalf of the Department of Labor's Occupational Safety and Health
Administration (OSHA). 

OSHA appreciates the time and effort that GAO took to perform this 
study. OSHA has long been on record as being very concerned about the 
existence of programs that appear to encourage safe work but in fact 
discourage injured workers from reporting injuries. OSHA has seen too 
many programs that offer a pizza party or allow workers to enter a 
raffle for a new television or even a truck as a reward for no reports 
of injuries on the job. Even worse is the threat to automatically drug-
test, discipline or fire any worker who reports an injury. Employers 
who use these programs also often offer monetary bonuses to managers 
to keep injury rates low. The effect of these programs is to 
discourage workers from reporting their injuries. 

Effective safety programs rely on accurate reporting. If a worker does 
not report an injury, he or she may not receive proper treatment or be 
eligible for workers' compensation benefits. But the damage does not 
stop there. Although these employers appear to be safer, unreported 
injuries are never investigated, problems remain concealed, workers 
remain exposed, and nothing is ever learned to prevent future injuries. 

Reports and patterns of current workplace injuries and illnesses are 
particularly important tools in preventing future injuries and 
illnesses. Employers and workers need this information in a timely 
manner to focus their prevention activities. OSHA needs this 
information to better target its inspections. 

OSHA recognizes that incentive programs can be a useful means for 
improving safety if they incentivize workers to identify hazards, 
participate in training or participate in investigating near-misses. 

OSHA will soon provide policy guidance about safety incentive programs 
across the agency's cooperative programs, similar to the revised 
Voluntary Protection Programs (VPP) Policy which makes clear that VPP 
participants fail to meet the requirements to participate in VPP if 
their incentive programs have the potential to discourage workers from 
reporting injuries. In addition, OSHA has issued policy guidance to 
its field inspectors that clarifies OSHA policy regarding incentive 
programs. The guidance will underscore OSHA's position that programs 
that discourage workers from reporting injuries may violate section 
11(c) of the OSHA law or other whistleblower statutes, and that some 
may also violate OSHA recordkeeping regulations. 

OSHA appreciates the opportunity to review and respond to GAO's draft 
report. 

Sincerely, 

Signed by: 

David Michaels, PhD, MPH: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Revae Moran, (202) 512-7215 or moranr@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Gretta L. Goodwin, Assistant 
Director, and Joel Green, Analyst-in-Charge, managed all aspects of 
this assignment; James E. Lloyd III and Michelle Loutoo Wilson made 
significant contributions to all phases of the work; Grace Cho made 
substantial contributions to data analysis and message and report 
development; Carl Barden and Pamela Davidson provided assistance in 
designing the study, conducting data analysis, and developing the 
report; Lorraine Ettaro, Stuart Kaufman, and Carl Ramirez helped with 
survey administration; Delores Hemsley assisted in data collection; 
Catherine Hurley assisted in data analysis; Ashley McCall provided 
literature search assistance; Barbara Chapman, Cynthia Saunders, and 
Elizabeth Wood assisted in the methodological review of studies; 
Susannah Compton assisted in message and report development; James 
Bennett created the report's graphics; Sarah Cornetto provided legal 
advice; and Amber Yancey-Carroll and Anna Bonelli reviewed the report 
to check the facts presented. 

[End of section] 

Footnotes: 

[1] The BP U.S. Refineries Independent Safety Review Panel, The Report 
of the BP U.S. Refineries Independent Safety Review Panel (January 
2007). 

[2] GAO, Workplace Safety and Health: Enhancing OSHA's Records Audit 
Process Could Improve the Accuracy of Worker Injury and Illness Data, 
[hyperlink, http://www.gao.gov/products/GAO-10-10] (Washington, D.C.: 
Oct. 15, 2009). 

[3] In this report, we use the term "injury and illness reporting" to 
refer to the reporting of occupational injuries and illnesses by 
workers to their employers. 

[4] Manufacturing accounted for over 11 million workers or about 10 
percent of total U.S. employment in 2009. 

[5] Pub. L. No. 91-596, 84 Stat. 1590, codified as amended at 29 
U.S.C. §§ 553, 651-78. 

[6] In these states, the state standards and their enforcement must be 
at least as effective as the federal standards. 29 U.S.C. § 667(c)(2). 
Most of these state plans cover both public and private sector 
worksites. However, the state plan in five states (Connecticut, 
Illinois, New Jersey, New York, and the Virgin Islands) only covers 
public sector (state and local government) worksites; private sector 
worksites are covered by federal OSHA. Under the OSH Act, "state" is 
defined to include the District of Columbia, Puerto Rico, the Virgin 
Islands, American Samoa, and Guam. 29 U.S.C. § 652(7). 

[7] Employers that are generally exempt from OSHA's recordkeeping 
requirements include employers with 10 or fewer employees, and those 
in specific low-hazard retail, service, finance, insurance, or real 
estate industries. 29 C.F.R. §§ 1904.1-1904.2. However, all employers 
must report to OSHA any work-related incident that results in a 
fatality or the hospitalization of three or more employees. 29 U.S.C. 
§ 1904.39. 

[8] See generally 29 C.F.R. §§ 1904.4 -1904.29. Work-related injuries 
and illnesses that must be recorded include, among others, those that 
result in days away from work, restricted work or transfer to another 
job, medical treatment beyond first aid, and loss of consciousness. 

[9] 29 U.S.C. § 660(c), 29 C.F.R. § 1904.36. 

[10] VPP worksites are reevaluated every 3 to 5 years to determine 
whether they merit staying in the program. To maintain VPP status, 
worksites must maintain an average injury and illness rate that is 
below the average rate published by the Bureau of Labor Statistics 
(BLS) for their industry for 1 of the most recent 3 years. VPP 
worksites are required to report their injury and illness rates to 
OSHA annually. 

[11] OSHA may inspect VPP and SHARP worksites with fatalities or other 
serious injuries or complaints about safety or health hazards. 

[12] OSHA refers to these individuals as compliance assistance 
specialists. 

[13] In this report, we use the term "safety culture," which is used 
by industry officials to refer to "safety climate," a term commonly 
used by researchers. We use the terms "safety culture" and "workplace 
safety and health management system" interchangeably in this report. 

[14] We reviewed studies from peer-reviewed journals published from 
January 2001 to October 2011. We included studies that evaluated the 
effect of safety incentive programs, workplace safety policies, or 
safety culture on workers' injury and illness rates, reporting of 
injuries or illnesses, or use of safe behaviors. We excluded studies 
that were reviews of other studies or in which the primary research 
was not conducted in the United States. For more information on our 
methodology, see appendix I. 

[15] Each of the six studies focused on a profession, industry, or 
geographic region, so the results may not apply to other professions, 
industries, or regions. For example, two of the studies focused on the 
construction industry and the results cannot be generalized to workers 
in other industries or to all construction workers because of their 
sample designs. 

[16] Jean Geiger Brown, Alison Trinkoff, Kenneth Rempher, Kathleen 
McPhaul, Barbara Brady, Jane Lipscomb, and Charles Muntaner, "Nurses 
Inclination to Report Work-Related Injuries: Organizational, Work-
Group, and Individual Factors Associated with Reporting," AAOHN 
Journal, vol. 53, no. 5 (2005): 213-217. 

[17] In addition, this study focused on nurses in two states, so the 
results may not apply to all nurses or other workers. 

[18] Kristy J. Lauver and Scott W. Lester, "Get Safety Problems to the 
Surface: Using Human Resource Practices to Improve Injury Reporting," 
Journal of Leadership and Organizational Studies, vol. 14, no. 2 
(2007): 168-179. 

[19] In some industries, such as transportation, post-incident drug or 
alcohol testing may be required. For example, regulations issued by 
the Department of Transportation's Federal Motor Carrier Safety 
Administration require employers to test drivers of commercial motor 
vehicles for alcohol and controlled substances after certain types of 
accidents. 49 C.F.R. § 382.303. 

[20] The study was based on research at a large retail chain. See A. 
Morantz and A. Mas, "Does Post-Accident Drug Testing Reduce Injuries? 
Evidence from a Large Retail Chain," American Law and Economics 
Review, vol. 10, no. 2, (2008): 246-302. In our review of the 
literature, we did not identify any studies of the effect of demerit 
systems that punish workers for unsafe work practices. 

[21] Several of these studies relied on nongeneralizable surveys of 
workers to measure safety culture. In addition, many relied on 
workers' memories to measure the incidence of injuries and illnesses, 
whereas others used documentation, such as employers' OSHA-required 
injury and illness logs or records of workers' compensation claims. 

[22] Each of the studies had a methodological issue that may limit the 
generalizability of the findings. For example, three of the four 
studies included nonrandom samples and the results may be affected by 
selection bias. 

[23] Two of the three studies share an author. 

[24] The manufacturers included in our survey sample were private 
sector workplaces with 11 or more employees. According to BLS, there 
are roughly 153,000 manufacturers nationwide in this population. This 
estimate includes manufacturers with one or more of the following 
types of safety incentive programs and other workplace safety 
policies: rate-based programs, behavior-based programs, demerit 
systems and post-incident drug and alcohol testing. The 95 percent 
confidence interval for the estimate of 75.5 percent is (68.7, 82.2). 
Our survey excluded post-incident drug and alcohol testing required by 
law for driving accidents. Post-incident drug and alcohol testing may 
be limited or prohibited by law in some states; for example, according 
to an official from the Vermont Occupational Safety and Health 
Administration, it is generally against the law for employers in 
Vermont to conduct post-incident drug and alcohol testing. GAO did not 
independently evaluate state laws or policies on post-incident drug 
and alcohol testing. 

[25] The estimate for safety incentive programs includes manufacturers 
with one or more of the following types of safety programs: rate-based 
and behavior-based. The estimate for workplace safety policies 
includes manufacturers with one or more of the following types of 
policies: demerit systems and post-incident drug and alcohol testing. 
The 95 percent confidence interval for the safety incentive programs 
estimate of 25.4 percent is (20.6, 30.1), and for the other workplace 
safety policies estimate of 74.9 percent is (68.2, 81.6). 

[26] The 95 percent confidence interval for the demerit systems 
estimate of 68.9 percent is (62.2, 75.6), and for the post-incident 
drug and alcohol testing estimate of 55.9 percent is (49.0, 62.8). 

[27] The 95 percent confidence intervals for these data are as 
follows: manufacturers that had only a rate-based program estimate of 
0.3 percent is (0.0, 1.0), manufacturers that had only a behavior-
based program estimate of 0.3 percent is (0.0, 1.0), manufacturers 
that had only a post-incident drug and alcohol testing estimate of 6.0 
percent is (3.7, 9.2), and manufacturers that had only a demerit 
system estimate of 16.6 percent is (11.6, 22.7). 

[28] The estimate for manufacturers with multiple safety incentive 
programs or other workplace safety policies includes manufacturers 
with two or more of the following types of programs and policies: rate-
based programs, behavior-based programs, demerit systems, and post-
incident drug and alcohol testing policies. The 95 percent confidence 
interval for the estimate of 55.2 percent is (48.4, 62.0). The 
estimate for manufacturers with several safety incentive programs or 
other workplace safety policies includes manufacturers with three or 
more of the same types of safety incentive programs and policies. The 
95 percent confidence interval for the estimate of 21.5 percent is 
(17.0, 25.9). 

[29] The 95 percent confidence intervals for these data include 
manufacturers that had the following: demerit systems and at least one 
other program or policy estimate of 50.5 percent is (43.9, 57.1), post-
incident drug and alcohol policies and at least one other program or 
policy estimate of 49.0 percent is (42.4, 55.5), rate-based programs 
and at least one other program or policy estimate of 21.7 percent is 
(17.3, 26.2), and behavior-based and at least one other program or 
policy estimate of 13.3 percent is (10.1, 17.0). 

[30] We defined large manufacturers as those with 250 or more workers, 
medium manufacturers as those with 50 to 249 workers, and small 
manufacturers as those with 11 to 49 workers. The 95 percent 
confidence interval for large manufacturers which had the estimate of 
89.1 percent for demerit systems is (81.0, 94.6), 45.0 percent for 
rate-based programs is (37.6, 52.3), and 39.5 percent for behavior-
based programs is (32.3, 46.7). The 95 percent confidence interval for 
medium manufacturers which had the estimate of 84.9 percent for 
demerit systems is (79.4, 89.4), 36.5 percent for rate-based programs 
is (29.9, 43.1), and 22.3 percent for behavior-based programs is 
(16.7, 27.9). The 95 percent confidence interval for small 
manufacturers which had the estimate of 58.5 percent for demerit 
systems is (48.3, 68.7), 12.5 percent for rate-based programs is (7.2, 
19.6), and 6.6 percent for behavior-based programs is (3.0, 12.3). 

[31] The 95 percent confidence interval for the post-incident drug 
alcohol testing estimate of 44.2 percent for small manufacturers is 
(34.3, 54.1). 

[32] The 95 percent confidence interval for the 38.3 percent estimate 
of manufacturing contractors that had rate-based programs whose injury 
and illness rates had been requested of is (24.1, 54.8), and for the 
12.6 percent estimate of manufacturing contractors whose injury and 
illness rates had not been requested of is (6.5, 23.1). 

[33] The 95 percent confidence interval for the estimate of 30.8 
percent is (24.6, 37.0). 

[34] The 95 percent confidence interval for the estimate of 33.2 
percent is (22.7, 43.7). 

[35] The 95 percent confidence interval for the estimate of 73.7 
percent is (62.7, 82.8). 

[36] The 95 percent confidence intervals for the estimates of 39.5 
percent is (28.8, 50.2), and 23.0 percent is (13.6, 34.9). 

[37] The 95 percent confidence intervals for the estimates of 68.8 
percent is (56.0, 79.8), and 36.6 percent is (24.6, 48.5). 

[38] The 95 percent confidence interval for the rate-based program 
monetary rewards estimate of 53.2 percent is (42.7, 63.7), the 
behavior-based program monetary rewards estimate of 43.6 percent is 
(30.8, 56.3), the rate-based program meals reward estimate of 56.8 
percent is (46.2,67.3), the behavior-based program meals rewards 
estimate of 46.6 percent is (33.9, 59.3), the rate-based program non-
monetary rewards estimate of 40.5 percent is (30.5, 50.5), the 
behavior-based program non-monetary rewards estimate of 44.5 percent 
is (32.3, 56.6), the rate-based program time off work rewards estimate 
of 4.5 percent is (2.1, 8.3), the behavior-based program time off work 
rewards estimate of 5.5 percent is (0.8, 17.5), the rate-based program 
token of recognition rewards estimate of 24.8 percent is (15.3, 36.5), 
and the behavior-based program token of recognition rewards estimate 
of 21.4 percent is (13.8, 30.7). 

[39] The 95 percent confidence interval for the rate-based program 
individual frontline worker estimate of 43.1 percent is (32.7, 53.5), 
the behavior-based program individual frontline worker estimate of 
52.8 percent is (40.0, 65.5), the rate-based program supervisor 
estimate of 20.0 percent is (12.3, 29.8), and the behavior-based 
program supervisor estimate of 26.4 percent is (15.0, 40.7). 

[40] One provision of OSHA's ergonomics standard from 2000 required 
employers to ensure that their policies and practices did not 
discourage reporting of ergonomics injuries. However, the ergonomics 
standard was invalidated by Congress in 2001 under the Congressional 
Review Act. Pub. L. No. 107-5, 115 Stat. 7 (2001). 

[41] The whistleblower protection provision is limited because 
affected employees must file a complaint within 30 days of the adverse 
action, see 29 U.S.C. § 660(c)(2) and, according to OSHA officials, 
they are not guaranteed anonymity during OSHA's investigation. In 
addition, in some cases OSHA may decide pursuing a claim in court is 
not an appropriate use of resources, particularly when the monetary 
value of the reward is relatively small. 

[42] 29 U.S.C. §§ 657(c), 658(a). For OSHA's recordkeeping 
regulations, see generally 29 C.F.R. part 1904. 

[43] 29 U.S.C. § 666(a). 

[44] We analyzed the preliminary results of OSHA's recordkeeping 
enforcement initiative as of October 21, 2011, and found that 75 
percent of inspected worksites had some type of safety incentive 
program, disciplinary workplace policy, or post-injury drug or alcohol 
testing. Of the 264 worksites inspected as of then, almost half of the 
worksites inspected had recordkeeping errors that would have affected 
the injury and illness rate used by OSHA to target worksites for 
inspection. However, the most common mistakes were relatively minor. 
For example, many worksites listed an employee's injury or illness on 
the log but made a mistake in the number of days the employee was not 
at work or on restricted duty. The recordkeeping enforcement 
initiative yielded a total of 882 violations of OSHA's recordkeeping 
requirements as of October 21, 2011. 

[End of section] 

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