OSHA Crackdown Makes Leading Indicator Metrics a Necessity

Date First Published on SafetySmart Compliance: April 10th, 2012
Topics: Illness Injury Prevention Program |

April 11, 2012 – By Glenn Demby

Traditionally, we measure “safety” by analyzing what is not safety, i.e., injury statistics occurring at each plant site such as recordable injuries, lost time accidents, number of lost or restricted days, workers’ compensation claims paid, etc. All of these measures are “trailing” measures. In addition to leading to after-the-fact solutions, such measures can also result in OSHA violations to the extent they’re used as criteria for awarding workers’ safety incentives.

Here’s a look at the problem—from both a technical and OSHA perspective—and what we can do to resolve it.

How Trailing Indicators Hurt the Safety Culture

Current safety measurement systems don’t do justice to how we are performing relative to safety. Moreover, because of their lack of positive feedback and acknowledgement of positives achieved, they often serve to de-motivate employees and cause them to maintain negative attitudes toward safety.

Moreover, use of trailing indicators to measure safety generally produces a de-motivating effect. It leads to corrective actions that can be perceived by employees to be reactive. “The only time anything gets done around here is after someone gets hurt,” employees think. This causes employees to develop a negative view of safety and fosters doubt about the sincerity and level of management’s commitment to protecting them.

Once this approach to managing safety occurs a few times, it becomes the norm in the eyes of employees. This undermines the credibility of the safety program. Because employees feel that their safety interests are not in line with management’s, when an incident occurs employees tend to take a defensive attitude stating “it wasn’t my fault.” Couple this with another common negative perception held by employees that investigations are exercises in blame and fault-finding. These negative perceptions encourage employees to dismiss the pursuit of new safety programs and label them as a “flavor of the month.” Instead of motivating, our good intentions regarding safety become de-motivating.

Unfortunately, once they develop, these attitudes tend to become embedded in the culture of the organization. That makes them difficult to change.

Trailing Indicators & OSHA Liability

The other problem with trailing indicators are the liability concerns they can create when made the basis of company incentive programs. Last month, Last month, OSHA issued a new enforcement policy ordering inspectors to crack down on employers who use incentives to discourage employees from reporting injuries.

The problem isn’t with incentives per se; it’s with basing incentives on recordable injuries. What OSHA is worried about is that employees won’t report injuries if it means putting their reward in jeopardy. That’s a legal problem because discouraging employees from reporting injuries or exercising other safety rights is a violation of the ban on discrimination under Sec. 11(c) of the Occupational Safety and Health Act.

And, suddenly, this has become a compliance problem of real immediacy. That’s because last month (March 12, 2012), OSHA issued a new enforcement policy ordering inspectors to crack down on employers who use incentives to discourage employees from reporting injuries.

Towards a Solution: Measuring Behavior Not Outcome

How do you solve the lagging indicator problem? The starting point is to consider our definition of safety. Traditionally, safety has been thought of as the avoidance of incidents, accidents and injuries. But we need to see the flip side of these things and recognize that safety is the state of being safe. As such, it’s more of a behavior than an outcome.

For example, when we talk about a safe driver, we generally mean somebody who has not been in an accident, has not received a speeding ticket and has low insurance rates. Although these are good outcomes, they do not necessarily define the person as a “safe” driver. These outcomes could just as easily have been accomplished as a result of luck. Conversely, otherwise “good” drivers don’t necessarily become bad ones merely because they have the misfortune of getting into an accident that wasn’t their fault.

The truly “safe” driver is a person who engages in safe driving behavior – who uses turn signals, checks the blind spots when changing lanes, maintains the recommended distance behind the car in front, etc.

How Feedback Motivates Behavior

Many safety professionals fail to grasp the importance of feedback on measurement. Human beings by nature look to others to evaluate their performance. We want to win, to be recognized for doing a good job and adding value. And we want to receive feedback as soon as possible, especially if we know we’ve done well.

Sadly, we don’t use feedback mechanisms to motivate safe behaviors. On the contrary, we only measure the negative behaviors like accidents and incidents. Sure, we provide feedback to our workers – but only to let them know that they have ‘screwed-up.’

Measuring the Right Things

Get your measurement and feedback systems right and safety performance will improve due to the motivation to win. How do you do this? First, find the right things to measure. Define the desired objectives for key activities and desired outcomes that will provide a positive safety culture at your organization. Elements you’ll want to include in addition to activities are:

  • Management leadership and commitment to safety;
  • Employee attitudes and motivation to work safely;
  • Employee ownership and involvement in the safety program;
  • Communication and feedback effectiveness; and
  • The effectiveness of your current safety programs and initiatives, including incentive and recognition programs, employee suggestion programs, incident investigations, audits and inspections, management of change, work order system, committees and safety meetings.


To measure success under ROI, you must turn your safety performance measurement and recognition system into an achievement-based system, rather than one based on injuries and other failures. Safety professionals must develop measures to assess and reward positive behaviors, not just of workers but everybody in the organization, including management. In addition to improving safety, using these metrics will keep you out of trouble under the OSHA incentives crackdown.

(Click here for a Checklist of 100 leading indicator performance measures.)