WORKPLACE 

SAFETY AND 

HEALTH 

Better OSHA 

Guidance Needed on 

Safety Incentive 

Programs 

Report to Congressional Requesters

April 2012 

GAO-12-329 

United States Government Accountability Office

GAO 
United States Government Accountability Office

Highlights of GAO-12-329, a report to 

congressional requesters 

April 2012 

WORKPLACE SAFETY AND HEALTH 

Better OSHA Guidance Needed on Safety Incentive 

Programs 

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 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.

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.

The Two Types of Safety Incentive Programs

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.

View GAO-12-329. For more information, 

contact Revae Moran at (202) 512-7215 or 

moranr@gao.gov. 
Page i GAO-12-329 Workplace Safety and Health 

Letter 1 

Background 2

Safety Incentive Programs and Policies May Affect Injury and 

Illness Reporting 7

Three-Quarters of U.S. Manufacturers Had Safety Incentive 

Programs or Other Workplace Safety Policies 12

OSHA Has Taken Limited Actions to Address Safety Incentive 

Programs and Other Workplace Safety Policies 19

Conclusions 23

Recommendations for Executive Action 24

Agency Comments 24

Appendix I Scope and Methodology 27

Appendix II Studies on the Effect of Safety Incentive Programs, Workplace Safety 

Policies, and Safety Culture on Workplace Safety 32

Appendix III Questionnaire Used for GAO’s Survey of Manufacturing Worksites 35

Appendix IV Comments from the Department of Labor 43

Appendix V GAO Contact and Staff Acknowledgments 45

Table

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

Workplace Safety 9

Figures

Figure 1: The Two Types of Safety Incentive Programs 6

Figure 2: Manufacturers with Safety Incentive Programs and Other 

Policies, by Type, 2010 13

Contents
Page ii GAO-12-329 Workplace Safety and Health 

Figure 3: U.S. Manufacturers with Only One Program or Other 

Workplace Safety Policy, Compared with Manufacturers 

with Multiple Programs or Other Policies, 2010 15

Figure 4: Manufacturers with Safety Incentive Programs and Other 

Workplace Safety Policies, by Size, 2010 17

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

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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Page 1 GAO-12-329 Workplace Safety and Health 

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.1 In October 2009, we 

reported that safety incentive programs can provide disincentives for 

workers to report injuries and illnesses to their employers.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 

 

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, GAO-10-10 (Washington, D.C.: 

Oct. 15, 2009).

 
 

Page 2 GAO-12-329 Workplace Safety and Health 

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,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.4

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.

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.

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.5

 

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. 

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 

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. 

Background
 

Page 3 GAO-12-329 Workplace Safety and Health 

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.6

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.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.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.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, 

 

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.

OSHA’s Recordkeeping 

Requirements
 

Page 4 GAO-12-329 Workplace Safety and Health 

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.

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.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.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, 

 

10VPP 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. 

11OSHA may inspect VPP and SHARP worksites with fatalities or other serious injuries or 

complaints about safety or health hazards. 

OSHA Cooperative 

Programs, Outreach, and 

Training
 

Page 5 GAO-12-329 Workplace Safety and Health 

unions, and community groups.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.

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.

13

(1) Management commitment and employee involvement

According to 

OSHA, the four elements of an effective safety and health management 

system are as follows:

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 safetyand 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.

 

12OSHA refers to these individuals as compliance assistance specialists. 

13In 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. 

Workplace Safety and 

Health Management 

Systems
 

Page 6 GAO-12-329 Workplace Safety and Health 

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). Ratebased 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 behaviorbased 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

Safety Incentive Programs
 

Page 7 GAO-12-329 Workplace Safety and Health 

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.

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.14

 

14We 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.

Each 

of the six studies, however, had methodological limitations that prevent 

Other Workplace Safety 

Policies

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
 

Page 8 GAO-12-329 Workplace Safety and Health 

generalizing the effects of these programs on injury and illness reporting 

for all workers.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.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.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.”18

 

15Each 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.

Information on the six studies is summarized in table 1.

16Jean 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. 

17In addition, this study focused on nurses in two states, so the results may not apply to all 

nurses or other workers. 

18Kristy 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. 
 

Page 9 GAO-12-329 Workplace Safety and Health 

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

Study author(s) 

(publication year)

Dependent 

measure(s)

Effect of ratebased programsEffect of behaviorbased programsAcknowledgment of 

potential for underreporting

Brown et. al. (2005)a Reporting of injuries No effect Not studied Yes

Lauver and Lester (2007)a Reported and 

unreported injuries 

and near misses

Not studied No effect Yes

Ludwig et. al. (2001) Use of safe practices Not studied Inconclusive Not applicable

Alavosius et. al. (2009) Injury rate Injury rate reductionb Yes

Gangwar and Goodrum (2005) Injury rate Injury rate reductionb,c Yes

Hinze (2002) Injury rate No effect Injury rate reduction 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. 

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.
 

Page 10 GAO-12-329 Workplace Safety and Health 

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.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.20

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 

 

19In 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.

20The 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.

How Employers Manage 

Safety Can Affect Injury 

and Illness Reporting
 

Page 11 GAO-12-329 Workplace Safety and Health 

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.21

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,

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.

22 three found that having a positive 

safety culture increased the likelihood of injury and illness reporting.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.

 

21Several 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’ OSHArequired injury and illness logs or records of workers’ compensation claims.

22Each 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. 

23Two of the three studies share an author. 
 

Page 12 GAO-12-329 Workplace Safety and Health 

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.

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.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.25

 

24The 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: ratebased 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.

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 

25The 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). 

Three-Quarters of 

U.S. Manufacturers 

Had Safety Incentive 

Programs or Other 

Workplace Safety 

Policies
 

Page 13 GAO-12-329 Workplace Safety and Health 

policy. Demerit systems were the most common policy reported, followed 

by post-incident drug and alcohol testing policies (see fig. 2).26

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

Type, 2010

 

26The 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). 
 

Page 14 GAO-12-329 Workplace Safety and Health 

Very few manufacturers had only one type of safety incentive program, and 

few had only one type of other workplace safety policy.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.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 fig. 3).29

 

27The 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). 

28The 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 postincident 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).

29The 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 behaviorbased and at least one other program or policy estimate of 13.3 percent is (10.1, 17.0). 
 

Page 15 GAO-12-329 Workplace Safety and Health 

Figure 3: U.S. Manufacturers with Only One Program or Other Workplace Safety 

Policy, Compared with Manufacturers with Multiple Programs or Other Policies, 2010
 

Page 16 GAO-12-329 Workplace Safety and Health 

Large manufacturers were more likely to have safety incentive programs 

and demerit systems than smaller manufacturers.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 fig. 4).31

 

30We 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).

31The 95 percent confidence interval for the post-incident drug alcohol testing estimate of 

44.2 percent for small manufacturers is (34.3, 54.1).
 

Page 17 GAO-12-329 Workplace Safety and Health 

Figure 4: Manufacturers with Safety Incentive Programs and Other Workplace 

Safety Policies, by Size, 2010

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.32

 

32The 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). 

We estimated that 31 percent of U.S. 
 

Page 18 GAO-12-329 Workplace Safety and Health 

manufacturers performed contractual work in 2010.33 Contracting 

companies requested injury and illness rate data from nearly a third of 

these manufacturers prior to signing a contract with them.34

U.S. manufacturers provided incentives to workers for a variety of safety 

goals and behaviors. Nearly three-quarters of manufacturers with ratebased programs, according to our estimates, rewarded workers for having 

no reported injuries and illnesses.

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.

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.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.37

The criteria for providing rewards differed between rate-based and behaviorbased 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 nonmonetary awards, such as gift cards, were more commonly offered than time 

 

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

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

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

36The 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).

37The 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).
 

Page 19 GAO-12-329 Workplace Safety and Health 

off work or a token of recognition, such as a plaque.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 ratebased or behavior-based safety incentive programs was twice as high as 

those that rewarded supervisors.39

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 

 

38The 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).

39The 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).

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
 

Page 20 GAO-12-329 Workplace Safety and Health 

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.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.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,42

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 

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.

 

40One 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). 

41The 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. 

4229 U.S.C. §§ 657(c), 658(a). For OSHA’s recordkeeping regulations, see generally 29 

C.F.R. part 1904.
 

Page 21 GAO-12-329 Workplace Safety and Health 

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.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.44

 

4329 U.S.C. § 666(a). 

44We 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.
 

Page 22 GAO-12-329 Workplace Safety and Health 

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 

OSHA Has Guidance on 

Safety Incentive Programs 

for One of Its Cooperative 

Programs but Has Not 

Adopted Similar Guidance 

for Other Efforts
 

Page 23 GAO-12-329 Workplace Safety and Health 

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.

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 

Conclusions
 

Page 24 GAO-12-329 Workplace Safety and Health 

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.

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.

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 

Recommendations for 

Executive Action

Agency Comments
 

Page 25 GAO-12-329 Workplace Safety and Health 

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 publically 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 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.

Revae E. Moran

Director, Education, Workforce, and Income Security Issues
 

Page 26 GAO-12-329 Workplace Safety and Health 

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
Appendix I: Scope and Methodology

Page 27 GAO-12-329 Workplace Safety and Health 

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.

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
Appendix I: Scope and Methodology

Page 28 GAO-12-329 Workplace Safety and Health 

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 

Survey of Manufacturing 

Worksites
Appendix I: Scope and Methodology

Page 29 GAO-12-329 Workplace Safety and Health 

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 
Appendix I: Scope and Methodology

Page 30 GAO-12-329 Workplace Safety and Health 

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.

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 

Examination of OSHA’s 

Efforts to Address Safety 

Incentive Programs and 

Workplace Policies
Appendix I: Scope and Methodology

Page 31 GAO-12-329 Workplace Safety and Health 

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.
Appendix II: Studies on the Effect of Safety 

Incentive Programs, Workplace Safety 

Policies, and Safety Culture on Workplace 

Safety 

Page 32 GAO-12-329 Workplace Safety and Health 

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.

Appendix II: Studies on the Effect of Safety 

Incentive Programs, Workplace Safety Policies, 

and Safety Culture on Workplace Safety
Appendix II: Studies on the Effect of Safety 

Incentive Programs, Workplace Safety 

Policies, and Safety Culture on Workplace 

Safety 

Page 33 GAO-12-329 Workplace Safety and Health 

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.
Appendix II: Studies on the Effect of Safety 

Incentive Programs, Workplace Safety 

Policies, and Safety Culture on Workplace 

Safety 

Page 34 GAO-12-329 Workplace Safety and Health 

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.
Appendix III: Questionnaire Used for GAO’s 

Survey of Manufacturing Worksites

Page 35 GAO-12-329 Workplace Safety and Health 

Appendix III: Questionnaire Used for GAO’s 

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

Survey of Manufacturing Worksites 

Page 36 GAO-12-329 Workplace Safety and Health 
Appendix III: Questionnaire Used for GAO’s 

Survey of Manufacturing Worksites

Page 37 GAO-12-329 Workplace Safety and Health 
Appendix III: Questionnaire Used for GAO’s 

Survey of Manufacturing Worksites

Page 38 GAO-12-329 Workplace Safety and Health 
Appendix III: Questionnaire Used for GAO’s 

Survey of Manufacturing Worksites 

Page 39 GAO-12-329 Workplace Safety and Health 
Appendix III: Questionnaire Used for GAO’s 

Survey of Manufacturing Worksites

Page 40 GAO-12-329 Workplace Safety and Health 
Appendix III: Questionnaire Used for GAO’s 

Survey of Manufacturing Worksites

Page 41 GAO-12-329 Workplace Safety and Health 
Appendix III: Questionnaire Used for GAO’s 

Survey of Manufacturing Worksites

Page 42 GAO-12-329 Workplace Safety and Health 
Appendix IV: Comments from the Department 

of Labor

Page 43 GAO-12-329 Workplace Safety and Health 

Appendix IV: Comments from the 

Department of Labor
Appendix IV: Comments from the Department 

of Labor

Page 44 GAO-12-329 Workplace Safety and Health 
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 45 GAO-12-329 Workplace Safety and Health 

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

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.

Appendix V: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(130988)
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