OSHA's REVISED Field Operations Manual (FOM ) incorporates "employer safety incentive" programs directly into the inspection process
So many of us can recall the 2012 "Letter to Regional Admins" titled Employer Safety Incentive and Disincentive Policies and Practices where OSHA called out “safety incentive” programs that encourage under reporting of accidents. Then it was merely a “letter” to regional admin(s). Now the Field Operations Manual (FOM) has been revised in a manner that the CSHO is to look for these types of incentive programs when they find recordkeeping deficiencies during their inspection. Now OSHA has established a connection with Safety Incentive Programs and record keeping violations, as well as a violation of section 11(c) of the OSH Act. Here are the references in the REVISED FOM, published on 10/1/15… |
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