Recently the Federal Department of Labor, through the Occupational Safety & Health Administration (OSHA), held a stakeholder meeting to brainstorm on how OSHA might use leading indicators; potentially as an OSHA metric. The attendees spanned all industries from food processing to academia. The construction industry was heavily represented, and many attendees were already using leading indicators in some form or fashion.
In holding this meeting, it was apparent that OSHA’s goal was to better understand how private stakeholders are using leading indicators, so OSHA might improve their model of lagging indicators. OSHA also expressed an interest in further developing their leading indicators webpage resources (https://www.osha.gov/leadingindicators/) so they could be utilized by private industry to improve safety and health.
OSHA regularly utilized the term “health outcomes” as opposed to accidents or injuries. Generally, the use of health outcomes reflects a public health approach that is more inclusive of all aspects of well-being (including mental, physical, social health) as opposed to an accident-based emphasis that tends to focus on acute traumatic events.
I: What is a Leading Indicator Versus a Lagging Indicator?
OSHA’s published leading indicator document defines leading and lagging indicators as:
Leading Indicator – leading indicators are proactive, preventive, and predictive measures that provide information about the effective performance of your safety and health activities. They measure events leading up to injuries, illnesses, and other incidents and reveal potential problems in your safety and health program.
Lagging Indicator – lagging indicators measure the occurrence and frequency of events that occurred in the past, such as the number or rate of injuries, illnesses, and fatalities.
Lagging indicators can be useful to provide a snapshot of overall effectiveness of a safety and health program because they provide information on how many people were hurt and how badly. However, the limitation in lagging data is that it tends to be reactionary, after an injury, illness, accident or fatality has already occurred. A safety program measuring illness and injury after the fact is a bit paradoxical because the safety program is attempting to prevent the illness and injuries it is measuring. Leading indicators attempt to predict future safety performance and tend to be proactive in nature in order to achieve continuous improvement. In short, lagging indicators measure failure while leading indicators are geared towards evaluating the performance of ongoing safety measures. The consensus has been that a combination of leading and lagging indicators are most effective in providing a complete measure of the effectiveness of a safety and health program.
II: OSHA SMART Model
During the Washington D.C. OSHA outreach meeting there was a reoccurring sentiment that target companies for OSHA’s leading indicator efforts should be small to medium business. Multiple stakeholders representing safety and health programs for large companies indicated their organizations had been using leading indicators for years. However, most seemed to agree that small to medium companies might not have a dedicated safety and health staff and these smaller companies would be the greatest beneficiary of OSHA resources and guidance in using leading indicators. OSHA in their current guidance document has advanced the following principles for effectively using leading indicators:
SMART Principles (Specific, Measurable, Accountable, Reasonable & Timely)
- Specific – Does your leading Indicator provide specifics for the action that you will take to minimize risk from a hazard or improved a program area?
- Measurable – Is your leading indicator presented as a number, rate or percentage that allows you to track and evaluate clear trends over time?
- Accountable – Does your leading indicator track an item that is relevant to your goal?
- Reasonable – Can you reasonably achieve the goal that you set for your leading indicator?
- Timely – Are you tracking your leading indicator regularly enough to spot meaningful trends from your data within your desired timeframe?
III: Use of Leading Indicators
OSHA uses three approaches for developing leading indicators: 1) Utilizing data already collected (example – percentage of workers attending safety training); 2) Identifying hazards in the workplace (example – hazards identified during a walk through with potential negative health outcomes); and 3) Using leading indicators to improve an element of a safety & health program (example – measuring the implementation of recommended practices for worker participation in a safety & health program). OSHA has laid out the following steps for the use of leading indicators:
Step 1 – Choose a Leading Indicator.
Step 2 – After the leading indicator is chosen, set a goal for that indicator.
Step 3 – Communicate with workers about the indicator, the goal and how it will be tracked.
Step 4 – Collect the data, measure progress toward the goal, make modifications if not meeting the goal and communicate progress with workers.
Step 5 – Periodically reassess your goal and indicator. Some indicators and goals can take longer time to see progress.
Step 6 – Respond to what is learned. Share information with personnel in the organization and make changes based upon what is learned through the indicator.
A core concern at the OSHA stakeholder outreach was the development of a leading indicator resource for small to medium sized business. OSHA expressed a desire to create a library accessible through the OSHA leading indicator webpage as a resource. Currently the OSHA webpage does contain a resource tab that could be built out as a library.
A common proposed solution to OSHA for the gathering of leading indicator data was the use of technology. Many stakeholders were either using or developing technological solutions to gather data to be used as leading indicators. There was also a fair amount of discussion on the role of machine learning or artificial intelligence for analysis of leading indicators to identify trends. Sensors on workers and/or equipment was a common theme for collecting leading indicators. There were concerns related to privacy and how to avoid turning leading indicators into a punitive or production measure that could be detrimental to workers.
Finally, OSHA appeared to have a desire to connect any new leading indicator standard to an existing lagging indicator standard (such as existing OSHA recordables). This reflects an acknowledgement that leading indicators are more effective when connected to a lagging indicator and/or health outcome. There was also considerable discussion about benchmarking between industries, so an industry like construction can compare indicators and outcomes with an unrelated industry like healthcare. This could be a powerful tool for shifting inner industry perspectives as to what are acceptable risk and health outcomes. Whatever the result of OSHA’s exploration of leading indicators, the move is timely given the ongoing increase of technology use and data gathering on construction projects.