Safety is a critical issue for the recycling industry. The many hazards employees encounter in the workplace from the machinery they operate to the heavy scrap materials they handle have resulted in a high number of injuries for the industry. In fact, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) lists refuse and recyclable material collectors as the occupation with the nation’s sixth highest fatality rate, making safety of utmost importance.
Safety programs, however, have come under increased scrutiny in recent years as many have resulted in fewer reported injuries but may not have actually translated into safer working conditions.
Many safety incentive programs, for example, are built on the premise that employees should be rewarded for incurring fewer lost-time incidents resulting from injuries or that employees should face disciplinary action if an injury or incident occurs. But policies such as these have raised red flags for OSHA.
The agency issued a memorandum on the topic of employer safety incentive and disincentive policies in March 2012. The letter called for compliance officers to be on the lookout for employer programs or policies that somehow encouraged employees not to report workplace injuries.
Similarly, while the Institute of Scrap Recycling Industries Inc. (ISRI) offers numerous resources, newsletters and guidelines for companies on the safety section of its website, www.isri.org, visitors are hard-pressed to find any there that relate to safety incentive programs.
John Gilstrap, director of safety for the Washington-based association offers a different approach to ensuring safety within recycling companies. He is not a proponent of incentivizing workers for achieving growing numbers of safe workdays. Instead, Gilstrap offers other suggestions for ensuring safe recycling operations.
“Most of the safety incentive programs that I’m aware of are focused exclusively on the worker, who is getting all these mixed messages,” Gilstrap explains. While he says plenty of companies use incentives, “I find that there are a lot of unintended consequences that come into play.”
First and foremost, Gilstrap says, safety incentive programs directed at employees’ safety records may discourage employees from reporting injuries, an action identified as discriminatory and unlawful by OSHA. “It does not necessarily cause them to work safer,” he says.
“You can always reward positive behavior, but you can’t intimidate the negative outcome,” Gilstrap adds.
Worker safety incentive programs also can be confusing for employees being asked to meet certain productivity goals, according to Gilstrap. “There’s always a bit of a contradictory message: Work safely but work fast. Sometimes those two things can’t exist in the same space,” he says.
He also points to company policies that reward supervisors for high production but still hold workers accountable for injuries caused by carelessness or by not following safety rules that weren’t being enforced in the first place.
“I can’t really think of anything, except perhaps a lightning strike, where injuries are not the direct result of unsafe behaviors,” Gilstrap says.
As an alternative to incentive programs, he says companies should find ways to reward positive safety behaviors, such as employees attending every safety meeting, always wearing personal protective equipment (PPE) or submitting suggestions for safety improvements.
Another key policy Gilstrap recommends is to hold supervisors accountable for the actions of those individuals who report to them. That means rewarding supervisors, not employees, for the safe operational practices that occur on a regular basis. Similarly, he adds, supervisors also should face disciplinary action when their employees are found to be not following safety guidelines.
Gilstrap points out that incentivizing workers, either individually or as a group, as opposed to supervisors, “puts all the onus for safe work behavior on the employees, when it’s been my experience that unsafe work behavior is often tacitly allowed by supervisors.”
These bonuses and rewards or disciplinary measures, Gilstrap says, should be built on behavioral observations by upper management. Under this approach, Gilstrap explains, executive-level managers must observe the behavior of workers and hold the supervisor—as well as the employees—accountable for those behaviors.
Another area of concern, he says, is the investigation of near misses that occur during operations. “If a hunk of metal goes across a yard and doesn’t hit anyone, that’s a fatality that didn’t happen,” he says. Gilstrap recommends that recycling companies investigate near misses the same way they would investigate a fatality.
He says he believes upper management is already in the habit of observing yard operations with an eye toward productivity, but he questions whether safe behaviors also are scrutinized in the same manner at most recycling companies.
“In my experience, the incentive programs that really work concentrate on supervisors on up to senior managers, where bonuses are tied not to production but to safe production,” Gilstrap says.
For example, Gilstrap says, if a worker operates a forklift without wearing seat belts, it’s true the worker is being unsafe, but the supervisor is also at fault for allowing it to happen on his or her watch. Therefore, the supervisor also should face disciplinary consequences, Gilstrap says, and have “real skin in the game” as a result of directing incentives toward those ultimately responsible for overseeing yard operations.
“They’ve got a real reason to make sure employees are doing the things they’re supposed to do,” he says. Making it a priority for supervisors that employees work safely makes safe work a reality, he says.
One of the simplest ways to incentivize supervisors is through compensation or production bonuses tied to safety, Gilstrap says, but it’s certainly not the only way supervisors can facilitate productive and safe operations. For example, if an executive-level manager walks through a yard and observes the forklift operator not wearing his seat belts, that executive should correct the employee and also discipline the operator’s supervisor. “Sometimes that’s enough,” Gilstrap says.
The bottom line, he says, is that supervisors must observe the safe work practices of their employees, whether through daily inspections or by ensuring that safe procedures are followed at all times. Examples of unsafe practices to look for include failure to wear PPE, failure to use seat belts when operating a moving vehicle or equipment, failure to lock out every time maintenance is performed on a piece of equipment, not following confined-space entry rules or driving vehicles such as forklifts too fast.
If an employee is working productively but is not following safety rules, an injury is likely in the future, Gilstrap warns. “The way I see it, the unsafe behavior of the worker is every bit the supervisor’s responsibility as unproductive work is.”
The author is an editor with the Recycling Today Media Group and can be contacted at firstname.lastname@example.org.