OSHA to Focus on Leading Indicators
As opposed to lagging indicators, leading indicators are proactive measures that can bring attention to issues in your current safety program. Because of the effectiveness of leading indicators at spotting problems, the Occupational Safety and Health Administration (OSHA) has taken an increased focus on leading indicators and is encouraging employers to do the same.
Below, a Texas OSHA lawyer discusses everything contractors need to know about leading indicators. Specifically, we’ll be discussing the OSHA resource Using Leading Indicators to Improve Safety and Health Outcomes. By embracing leading indicators, employers can prevent injuries, thereby preventing an untimely visit and citation from OSHA.
Leading Indicators Vs. Lagging Indicators
Lagging indicators measure the frequency of injuries on the jobsite that occurred in the past. Although great for determining if a hazard exists, it's a reactive measure that only allows a hazard to be addressed after it results in an injury. “Today, EHS practitioners continue to rely on injury rates, absenteeism, and other lagging metrics despite the growing acceptance of the fact that these failure-focused measures are ineffective in driving continuous improvement efforts,” posits the Campbell Institute. By contrast, leading indicators allow employers to take preventative measures to address hazards by highlighting early warning signs.
OSHA uses the acronym SMART to indicate good leading indicators. Smart stands for:
- Specific: Leading indicators should provide specifics for achieving a goal related to preventing hazards and injury.
- Measurable: Leading indicators should provide measurable data to highlight clear trends.
- Accountable: Leading indicators should track trends that are relevant to your goal.
- Reasonable: You should be able to reasonably achieve the goal you created.
- Timely: Leading indicators should be tracked regularly.
An example that OSHA uses is the number of workers who attend regularly scheduled safety meetings. In this example, a company notices that, although they have monthly safety meetings, a number of their employees are not attending. Meeting attendance is the leading indicator, and the goal is to drive up attendance, thereby spreading awareness and preventing injury. This is an excellent example; however, the leading indicators that are appropriate for your company may be completely different.
Selecting and Using a Leading Indicator
There are three approaches to selecting a leading indicator: using previously collected data, addressing an identified hazard, and improving an already established safety program. OSHA recommends that employers use the approach that’s best for them — a combination of these approaches may even be appropriate.
Our OSHA lawyers suggest selecting a leading indicator that’s related to a hazard that is the greatest risk to your workers — head injuries from falling debris, for example. Once a leading indicator has been chosen, you should set a goal that aligns with it. So if your leading indicator is the frequency that scaffolding is cleared of debris, your goal would be to increase the number of times the scaffolding is cleared. Next, communicate with your team to ensure that everyone understands the indicator, goal, and method for tracking the indicator. You can then take action to make your goal a reality, all the while collecting data. Using our example, you could fill out a checklist to keep track of how often your workers clear the scaffolding of debris.
Related: OSHA in Texas: Misconceptions
Review your progress regularly and don’t be afraid to make adjustments along the way — this isn’t an exact science. Discovering new ways to prevent injury is a time-consuming yet rewarding process for any contractor willing to invest in worker safety.
Investing in Worker Safety
As OSHA states in the 18-page document, “In addition to the social benefits, employers that use leading indicators to find and fix hazards can realize direct savings to their bottom line. These include savings in repair costs, production costs, workers’ compensation costs, and other legal and regulatory costs that are commonly associated with incidents.” Taking OSHA’s lead and developing an action plan based on leading indicators can be incredibly beneficial for your business. While it can in no way guarantee that OSHA won’t visit your project site, it can ensure that you are prepared if OSHA comes knocking.
In the event that OSHA visits your jobsite and issues a citation despite your best intentions, consider speaking with one of our Texas OSHA defense lawyers. Not only can our team of construction attorneys defend you, but they can also recommend preventative measures like leading indicators that will help to ensure that your jobsite is free from recognized hazards that could lead to injury or death.
If you would like to speak with an OSHA attorney, please contact us today.
Disclaimer: The information contained in this article is for general educational information only. This information does not constitute legal advice, is not intended to constitute legal advice, nor should it be relied upon as legal advice for your specific factual pattern or situation.