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OSHA Embraces Leading Indicators

Nov. 5, 2019
Reversing its enforcement emphasis will change how it deals with employers.

In the future, employers will need to deal with federal safety law compliance from an entirely new perspective. OSHA has announced that it is moving away from relying on past employer safety data, or lagging indicators, to focus its enforcement efforts on what it defines as leading indicators.

“These lagging indicators have been denounced by safety and health professionals as reactive, and an ineffective means of measuring the effectiveness of an employer’s safety and health program. OSHA has finally agreed,” says attorney Samantha Catone of the law firm of Goldberg Segalla LLP. “As a result of this shift, employers must become well-versed in leading indicators and how to utilize them.”

Up until now, the agency for a long time chose to focus on “OSHA recordables,” or the number of work-related injuries contained in an employer’s OSHA 300 log, to assess safety in workplaces.

“Leading indicators can play a vital role in preventing worker fatalities, injuries, and illnesses and strengthening other safety and health outcomes in the workplace,” OSHA says. ”Leading indicators are proactive and preventive measures that can shed light about the effectiveness of safety and health activities and reveal potential problems in a safety and health program.”

On the other hand, the lagging indicators most employers are familiar with measure only the occurrence and frequency of events that occurred in the past, such as the number or rate of injuries, illnesses and fatalities, the agency points out.

“While lagging indicators can alert you to a failure in an area of your safety and health program or to the existence of a hazard, leading indicators are important because they can tell you whether your safety and health activities are effective at preventing incidents,” OSHA observes. “A good safety and health program uses leading indicators to drive change and lagging indicators to measure effectiveness.”

OSHA also stresses that applying leading indicators can improve organizational performance in a variety of ways. By doing so, the agency says employers may find they can prevent workplace injuries and illnesses; reduce costs associated with incidents; improve productivity and overall organizational performance; optimize safety and health performance; and increase worker participation.

How Leading Indicators Work

To assist employers in learning about the use of leading indicators in more detail, OSHA has published an 18-page detailed guide called: “Using Leading Indicators to Improve Safety and Health Outcomes.”

“Leading indicators are a valuable tool regardless of whether you have a safety or health program, what you have included in your program, or what stage you may be at in your program. OSHA encourages employers to get started today,” the agency states. “There is no ‘one size fits all’ way to use leading indicators. Employers with newer programs may use indicators that focus on starting a program, while employers with more mature programs may use them to monitor how close they are to achieving higher performance targets.”

The guide explains three approaches for developing leading indicators: using data that you already collect to achieve a safety or health goal; controlling an identified hazard; and for improving a safety and health program element.

According to OSHA, leading indicators are based on data employers already are collecting. “If you are just getting started with leading indicators, you may find it easier to work with data that you already collect, whether it is data that can improve an element of your safety and health program or data that can help address a hazard or achieve some other safety or health outcome,” the agency says.

OSHA has scheduled a Nov. 7 stakeholders meeting in Washington, DC, to discuss the development and to seek answers from employers to the following questions:

● To what extent are leading indicators used in your workplace?

● Do you use leading indicators as a preventative tool for fixing workplace hazards, or as a tool for improving performance of your safety and health program?

● What leading indicators are most important in your workplace? Why were these indicators chosen?

● How do you determine the effectiveness of your leading indicators? How do you track your leading indicators?

● What leading indicators are, or could be, commonly used in your industry?

● What challenges, if any, have you encountered using leading indicators?

● How many employees are at your facility, and how many are involved in tracking leading indicators?

● How has the use of leading indicators changed the way you manage your safety and health program or other business operations?

● What should OSHA do to encourage employers to use leading indicators in addition to lagging indicators to improve safety management?

The new leading indicator policy is just the latest in changes the agency has made to its enforcement policy and practices. OSHA also recently began using a new system for weighing and measuring enforcement priorities that now includes added emphases depending on the type of hazard inspected and whether the actions were taken in pursuit of the agency’s enforcement initiatives.

About the Author

David Sparkman

David Sparkman is founding editor of ACWI Advance (, the newsletter of the American Chain of Warehouses Inc. He also heads David Sparkman Consulting, a Washington D.C. area public relations and communications firm. Prior to these he was director of industry relations for the International Warehouse Logistics Association. Sparkman has also been a freelance writer, specializing in logistics and freight transportation. He has served as vice president of communications for the American Moving and Storage Association, director of communications for the National Private Truck Council, and for two decades with American Trucking Associations on its weekly newspaper, Transport Topics.

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