On November 7, 2019, OSHA held a public stakeholder meeting on safety key performance indicators (KPIs). During this meeting, the agency sought input from employers and industry groups on leading and lagging safety KPIs. Specifically, OSHA aimed to gather information about: (1) how companies regularly implement leading indicators; (2) how the information is used to strengthen work protection best practices; (3) the possibility of creating a digital library of leading indicators accessible on the OSHA website; and (4) next steps for OSHA’s leading and lagging indicators. The agency did not specify how this information would be used and, specifically, whether it would be utilized to develop a future rulemaking or guidance document.
Several agency representatives were present, including Lauren Sweatt, the OSHA Deputy Assistant Secretary of Labor for Occupational Safety and Health. Invited participants included safety researchers and organizations, as well as industry representatives from construction and contractors, farming and grocery, paper manufacturing, heavy manufacturers, recycling, oil and gas, healthcare and hospitals, small businesses, and insurance. Reed Smith participated as an observer.
In general, industry representatives spoke positively about the effectiveness of leading safety indicators over lagging indicators, which is consistent with recommendations from other agencies including the U.S. Chemical Safety Board (CSB). Meeting participants described how the use of leading safety indicators consistently correlated with reduced incident rates and helped unite management and hourly employees around safe work practices.
In preparation for the meeting, OSHA published its Using Leading Indicators to Improve Safety and Health Outcomes guidelines. The publication describes quality leading indicators as specific, measurable, accountable, reasonable, and timely, and provides examples of what OSHA considers to be effective versus ineffective KPIs. It also describes the methods OSHA recommends for employers to use in developing effective and efficient leading indicators, including the use of data that the organization already collects to achieve safety or health goals.