February 21, 2020
The Honorable Sherrod Brown
United States Senate
503 Hart Senate Office Building
Washington, DC 20510
Dear Senator Brown,
We appreciate the opportunity to discuss Amazon’s longstanding commitment to protect the health and
safety of our workers. A copy of this response is being sent to the other Senators who also signed the
February 7 letter.
Over the last decade, Amazon has created more U.S.-based jobs than any other company. These jobs include
more than 8,500 in Ohio. Our growing workforce is the heart and soul of our company. Our employees drive
Amazon’s success, and we believe we have a responsibility to protect and support each one of them.
We are also grateful for the chance to address some of the misrepresentations that recently have been made
about our workplace culture and policies. We believe so strongly in our workplace safety environment and
culture that we offer public tours of our fulfillment centers. In 2019, more than 300,000 people took tours of
Amazon fulfillment centers around the world. We respectfully request that you tour an Amazon fulfillment
center and see for yourself how we prioritize safety at our facilities. We have reached out to your staff to
request dates to host you at a fulfillment center in Ohio, or one near Washington, D.C.
Before we address the specific points raised in your letter, we would like to address three issues: the safety
culture at Amazon; our approach to protecting associates; and injury rates and reporting practices.
Safety Culture at Amazon
Safety is Amazon’s number one priority. To us, one injury is too many. We work hard to ensure that our
associates return home safely after each shift. Safety training at Amazon starts on an employee’s first day
and continues throughout their tenure with the company. We begin each day with a pre-shift meeting that
includes stretching and a short safety briefing with line managers to ensure that safety is the focus at the
start of the shift.
Amazon has one of the largest workplace health and safety (WHS) organizations in the world, with more than
2,500 WHS professionals globally and nearly 1,900 in North America. In 2019, we provided more than one
million hours of safety training to associates and invested more than $55 million on safety improvement
projects. Several key investments initiated in 2019 include: improving the safety of our facility parking lots,
retrofitting pallet racking so employees have the newest equipment in dynamic areas of the fulfillment
center, and improving powered industrial truck and pedestrian safety controls.
This year, we plan to increase our investment in safety improvement projects six-fold to more than $300
million. Several new safety investments, which we have planned or begun to implement, are focused on
design changes and technological improvements. For example, to help reduce muscle fatigue, we are
redesigning workstations where associates stand and pack boxes, so that they are adjustable to match an
associate’s height and include ergonomic mats on which to stand. We are also upgrading digital sensors in
our facilities to identify, in real-time, quality control defects that affect the safety of our associates. These
601 New Jersey Ave NW
Washington, DC 20001

 and other improvements will be piloted in several fulfillment centers around the U.S., and will hopefully be in
all Amazon facilities by the end of the year.
Our safety culture is built on a philosophy of continuous improvement. We developed a Global Management
EHS system that breaks down health and safety standards into auditable self-assessments. As part of that
system, our ergonomics program is aligned to industry practices, and applicable Occupational Safety and
Health Administration (OSHA) standards, with the core focus on eliminating manual material handling risks
that are associated with musculoskeletal disorders. Our in-house industrial design ergonomics team trains
our engineering teams in ergonomics design principles and specifications. This has resulted in new
workstation designs, equipment, and job tasks that have addressed muscle fatigue. Our ergonomics team
also partners with the operations team to identify, evaluate, and implement feasible control measures for
existing workstations and tasks, as well as continually exploring how to improve administrative controls such
as job rotation and training.
In addition, all of our Amazon robotics facilities employ Injury Prevention Specialists who are certified athletic
trainers. They work directly with associates on ergonomic techniques to reduce the likelihood of soft tissue
injuries and musculoskeletal disorders. In 2019, we partnered with industry-leading academic institutions
that specialize in musculoskeletal disorders to further focus on the reduction of injuries. We also engage
third-party ergonomists both for technical assessment and peer review.
While we are proud of the current investments and infrastructure that we have put in place, we know that
additional resources will help to ensure that we provide the best work environment for our associates. This
year, we are hiring additional ergonomists and further rolling out safety design ergonomics training for
engineers and field staff.
To train and prepare our newly-hired associates for the job, we recently developed the WorkingWell
program. The program uses academic research and certified athletic trainers to educate our associates and
leadership on healthy work practices, including: a ramp-up schedule to prevent over-training and the risk of
musculoskeletal disorders; classroom sessions that teach proper body movements, health, and wellness; and
ongoing safety training engagements. Early results from the pilot program show a significant improvement in
injury reduction outcomes for our associates. Based on this initial success, Amazon has committed to
continue and expand the program throughout our network this year. This will be the standard by which we
on-board new associates moving forward.
Amazon’s Comprehensive Approach to Protecting and Supporting Workers
In addition to a safe work environment, we provide our workers with industry-leading wages and benefits on
day one. In 2018, we announced that all Amazon associates will earn at least $15 per hour. Our benefits
package includes: medical, vision, and dental insurance; generous parental leave, including five months of
maternity leave; and a network of support programs. Full-time, hourly employees have the same benefits as
corporate employees, ensuring every Amazonian has access to the best health care and insurance programs.
In addition, we provide new career training opportunities to our associates. We offer Career Choice, in which
Amazon pays up to 95% of tuition and fees towards a certificate or diploma in qualified fields of study,
leading to in-demand jobs. Since launching Career Choice in 2012, more than 25,000 Amazonians have
received training for high-demand occupations, including aircraft maintenance, computer-aided design
technician, commercial driving, and nursing. We also announced an upskilling initiative that will see a $700
million investment to provide training for 100,000 U.S. employees by 2025, for skills related to machine
learning, IT jobs, software engineering, and Amazon Web Services training and certification.

2

 Beyond investing in our own workforce, Amazon is proud to have created billions of dollars of investments in
local communities around the country. Since 2010, Amazon has invested more than $270 billion in
infrastructure and compensation to our associates. We have indirectly supported more than 680,000 jobs in
areas like construction, logistics, and other professional services. Almost one-third of the investment and jobs
came from the states represented by signatories on this letter.1 Amazon also supports more than 1.9 million
businesses, courier companies, content creators, and developers in the U.S.
We are proud of the jobs we have created in Ohio and the positive impact Amazon has had on your local
economy.
Amazon’s Injury Rates and Reporting Practices
As noted in several published studies, safety incidents across all industries are underreported from 20% to as
high as 70%.2 At Amazon, however, our illness and injury rates reflect our commitment to fully reporting and
making sure we have the clearest possible picture of any potential safety risks. The nuances in OSHA’s
recordkeeping definitions draw lines between injuries that are recordable and those that are not, and they
create ambiguity when determining if an injury is a result of work or home activities. In 2016, we decided to
change our approach to recordkeeping and design a system that reported all injuries – no matter the severity
– to remove elements of subjectivity and provide the data needed to drive comprehensive safety
improvements.
If an associate is injured and given work restrictions that do not match the positions available in our
fulfillment centers, we have taken steps to ensure that their compensation is not negatively impacted. It is a
common practice at other workplaces that when an injured employee has work restrictions that cannot be
met by the employer, he or she is placed on leave and given partial pay through workers’ compensation. To
reduce the financial impact of an injury on our associates, Amazon has created the Amazon Community
Together (ACT) Program. In locations where ACT has been implemented, associates who agree to participate
in the program receive their full wages and benefits by working at local non-profit organizations while
focusing on their recovery. The positions available through the ACT program typically meet even the most
stringent work restrictions and also provide a valuable resource to the community. Amazon has partnered
with over 750 local and national non-profit organizations such as Habitat for Humanity, Goodwill, and the
American Red Cross. Through ACT, not only do our associates maintain full compensation while injured, but
data has also shown that recovery times have improved by nearly 40 days compared to associates that are
placed on a leave of absence. This program rolled out to select fulfillment centers in North America in 2019,
with plans to expand in 2020.
In addition to the response above, we would like to respond below to the specific actions you requested.
“Reduce workers’ quotas and speed requirements, schedule frequent rest breaks during high production
shifts, and eliminate the policy of terminating workers who do not meet their quotas three times”
Amazon does not use quotas and does not have a policy that terminates associates after they fail to meet
their target performance expectations three times. Our target performance expectations, however, are
based on the performance, aggregated over time, across the network and each individual facility’s
performance. We have dedicated teams that collect data on performance expectations and study their

1

See, Amazon’s Economic Impact Across the U.S., https://www.aboutamazon.com/investing-in-the-u-s.
See Fagan, K.M., & Hodgson, M.J., Under- Recording of Work-Related Injuries and Illnesses: An OSHA Priority,
JOURNAL OF SAFETY RESEARCH (2016) at http://dx.doi.org/10.1016/j.jsr.2016.12.002.
2

3

 effectiveness. Their goal is to ensure the performance expectations are attainable, while prioritizing safety.
When expectations are not met, managers provide coaching and training to individual associates.
All associates are required to take breaks throughout their shifts. Associates, however, may take additional
breaks outside of their traditional break times. There are ample bathrooms throughout our fulfillment
centers, as well as multiple breakrooms or break areas with seating, vending machines, refrigerators,
microwaves, and entertainment or leisure activities such as TVs and games like basketball or foosball tables.
In addition to our break policies, we have programs in place to help associates achieve their performance
targets, such as the previously mentioned WorkingWell program.
“Cease including bathroom breaks as ‘time off task’ and ensure workers are allowed and encouraged to
hydrate and use the bathroom as needed”
Please see the above answer. Associates are allowed and encouraged to take breaks as needed, in addition to
their traditional breaks during a shift. These additional short breaks—including time spent using the
restroom—are paid.
If there are instances where our leaders cannot account for the whereabouts of an associate for a significant
amount of time (“time off task”), managers speak with the associate to understand if there are any issues
that can be addressed by the leadership team (such as defective equipment or process defects). If the reason
behind the “time off task” is related to bathroom breaks, it is excused. Simply put, we do not reprimand
employees, or take adverse actions, for bathroom breaks. Amazon has no policies governing the amount of
time that an associate can use the restroom. If there is an underlying medical condition that requires an
associate to use the restroom frequently, their leader will encourage them to seek medical advice and
Amazon will accommodate any documented needs that they have.
“If Amazon provides worksite medical care, ensure it is staffed by licensed health care professionals
operating within their legal scope of practice”
Amazon fulfillment centers have a program called AMCARE that ensures associates are given first-aid
assistance for injuries and illnesses in a timely manner when they are in an Amazon facility. AMCARE uses
Onsite Medical Representatives (OMRs) who all hold EMT-Basic Certifications. While our OMRs are certified
to respond to medical emergencies, their base function is to provide first-aid care for both occupational and
non-occupational injuries. The care protocols are based on clear, established company guidelines for first-aid
care, and when to escalate care to outside medical treatment in accordance with local, state, and federal
regulations. At any point, associates can choose to visit a doctor to seek medical assistance. Per our
protocols, no associate should ever be discouraged from seeking additional care.
“Provide immediate referrals to a physician for workers who report to Amazon’s on-site medical care that
their symptoms are not improving and for workers who request medical care from a physician so they can
see the doctor or urgent care provider of their choice and receive adequate medical treatment”
We provide immediate referrals for associates. Under the protocols that we provide for our AMCARE OMRs,
if an associate is receiving first-aid treatment for a work-related injury and their symptoms have not
improved or worsened, OMRs are directed to refer the associate for outside medical treatment. If at any time
an associate asks to see an outside medical provider, our OMRs will, of course, accommodate the associate’s
request.
Additionally, Amazon has deployed telemedicine services and technology that allows for our OMRs to
virtually contact licensed nurses and physicians 24 hours a day for non-life threatening medical situations.
This guidance frequently results in our OMRs referring associates to outside medical care. While telemedicine
4

 is not a replacement for a medical referral, it does assist in identifying when advanced medical care is
needed. Beyond the interactions with OMRs, associates are able to see an outside medical provider of their
choice because of their comprehensive medical benefits they receive on day one.
“Conduct a comprehensive ergonomic evaluation of all warehouse tasks involving manual material
handling and implement changes to the physical workplace and to work practices that reduce or eliminate
employee risk or ergonomic injuries”
We strive to establish an injury-free work environment through proactively eliminating risks, engaging
associates, teaching safety and health principles, and holding leaders accountable for safety compliance. In
accordance with our internal policies, the WHS team conducted a Job Hazard Assessment for every position
in the fulfillment network in 2019 to understand the physical requirements, potential hazards, and safety
controls needed for each job. Theses analyses are required to be completed at least annually at every site in
our network, as well as any time a process changes. Our global WHS team is constantly reviewing and
analyzing data in our fulfillment centers to improve, correct, or change processes and physical conditions to
alleviate muscle fatigue. In 2019, we trained more than 400 WHS personnel to assess ergonomic risks, and
we regularly engage with third-party ergonomics experts to audit our evaluations on how to improve the
safety of our workplaces.
We are confident in our understanding of the hazards for every position through our Job Hazard
Assessments, but we are also continuously improving these assessments, particularly those related to
ergonomic risks. As previously stated, Amazon is investing in additional internal and external ergonomics and
engineering resources to continuously review and improve on process and workstation design. Through the
addition of these resources, we will use industry-leading techniques and technology to further identify
opportunities for improvement.
“Implement a strong and enforceable company policy that prohibits supervisors and managers from
discrimination or retaliation when workers report injuries or safety concerns”
Amazon has a strong company policy in place that prohibits discrimination and retaliation against associates
who report injuries or safety concerns. It is important that associates are comfortable reporting any incidents
that they feel make their workplace unsafe. We will promptly investigate concerns associates raise and will
take corrective action.
We proactively seek feedback through an innovative tool that engages our associates to determine their
sentiments about Amazon’s safety culture, called the Safety Leadership Index (SLI) program. In addition,
associates have the ability to submit written questions to managers, email senior leadership, or participate in
our Voice of the Associate board. Some of the opportunities to provide feedback are anonymous (e.g., SLI
program), while others can be either public or anonymous (e.g., Voice of the Associate board). All of these
programs are available to full-time, part-time, and temporary associates.
“Ensure workers, who know their jobs and working conditions best, have a guaranteed way to raise safety
and health concerns and provide recommendations to correct identified hazards and keep workers
apprised in a timely fashion of action taken by management regarding their concerns”
As described in the above response, Amazon has various methods to raise and report safety and health
concerns directly to management, both publicly and anonymously. We feel engaging with our associates
directly is the best way to receive real-time feedback on safety concerns in our facilities.
Through our SLI program, managers collect feedback from our associates in real-time to help improve the
workplace environment and proactively manage risks associated with injuries and illnesses, including unsafe
5

 work conditions or behaviors. We ask associates a series of safety questions each day as they log-in, such as,
“Do you have everything that you need to perform your job safely?” We use the responses we receive to
quickly spot potential problems by targeting certain sites for deliberate planning and execution of actions for
improvement, and to create more avenues for partnerships with associates to increase our communication
with them.
In addition to the SLI program, in 2019, we deployed a leadership-led safety engagement program called
Digital Safety Circles (DSC). Under the DSC program, every leader in a fulfillment center engages with groups
of four to five associates twice a week to discuss current safety opportunities. We collect this feedback to
ensure that the results of these engagements are captured and resolved, and the program collects the
feedback and findings through our internal tools that allow us to aggregate and deep dive on the results at
multiple levels to better understand our opportunities and associate sentiment. Since the launch of the
program, we have completed more than 1,000 DSCs.
“Make public Amazon’s summary record of serious injuries (OSHA 300 A) on Amazon’s website for all of
the country’s worksites”
We are exploring the best way to make information about Amazon’s safety record public, while protecting
employee privacy and confidential information. The OSHA injury logs contain private and sensitive
information, such as names of injured workers and descriptions of their injuries. Amazon and OSHA treat
these logs as confidential, and they are not shared publicly. We follow all relevant regulations to provide
these records to current and former employees, or their authorized representatives, upon request.
In conclusion, we want to reiterate Amazon’s commitment to protecting the health and safety of our
associates. This is, and will remain, our top priority. We hope that you can find time to visit one of our
fulfillment centers and see firsthand how we keep safety at the forefront of all our activities and are
constantly working to make improvements. We welcome your feedback and would be happy to answer any
further questions.
Sincerely,

Brian Huseman,
Vice President, Public Policy

6