PMPA Challenges OSHA Memorandum on Safety Incentive Disincentive Policies

Employers may continue to discipline employees who fail to report injuries appropriately. Positive incentives for safety performance remain targeted by OSHA as potentially discriminatory and dissuasive of reporting injuries. Director Michaels “whole-heartedly agrees” with the use of incentives to encourage positive behaviors and that OSHA “recognizes the employers’ legitimate interest in establishing procedures for receiving and responding to reports of injuries and nothing in the memo is intended to undermine that interest.”