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Finally…OSHA Focuses on Leading Indicators in Safety & Health

Recently, OSHA announced its intention to hold a stakeholder meeting in Washington D.C. next month to obtain information to create tools to help employers with developing and using leading indicators for safety and  health.  OSHA has long focused on “OSHA recordables” (number of recorded work-related injuries on an employer’s OSHA 300 Log) as a way to illustrate how safe an employer’s workplace may be.  However, most safety and health professionals decry the use of such lagging indicators and instead focus on the use of leading indicators, which are proactive in nature.  Lagging indicators are those which attempt to measure the effectiveness of an employer’s safety and health program after the fact, and therefore lagging indicators are reactive in nature. For example, the number of work-related injuries or days away from work (DAFW) are lagging indicators.  Leading indicators, on the other hand, are proactive in nature and attempt to take proactive measures to address safety and health in the work environment. According to OSHA, “Leading indicators are proactive, preventive, and predictive measures.  A good safety and health program uses leadng indicators to drive change and lagging indicators to measure effectiveness.”

OSHA is looking to open up the dialogue with stakeholders and have a facilitated group discussion with participants. Specifically the meeting will be a roundtable discussion with questions posed by OSHA. OSHA will focus on the questions provided in the notice of stakeholder meeting that are listed below.

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 meeting will be held on November 7, 2019 from 1:00 p.m to 4:30 p.m. ET at the U.S. Department of Labor, 200 Constitution Avenue NW, Washington DC 20210 in Conference Room N-4437. OSHA has established a first-come, first-served registration and for stakeholders wishing to attend they can register online by October 30, 2019 at:  https://projects.erg.com/conferences/osha/register-osha-leadingindicators.htm.

Jackson Lewis P.C. © 2020National Law Review, Volume IX, Number 295


About this Author

Tressi Cordaro, Occupational safety health attorney, Jackson Lewis, enforcement agency lawyer, labor litigation legal counsel

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She advises and represents employers on occupational safety and health matters before federal and state OSHA enforcement agencies.

Ms. Cordaro has advised employers faced with willful and serious citations as the result of catastrophic events and fatalities, including citations involving multi-million dollar penalties. Ms. Cordaro’s approach to representing an employer cited by OSHA is to seek an efficient resolution of contested...