OSHA’s Leading Indicators in a nutshell

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OSHA is changing the rules in an attempt to improve safety and health outcomes. OSHA's 300 log is losing its power. Will this shift be successful? The plain answer is yes.

For more than 50 years, companies have been looking for ways to improve their EHS performance in order to reduce the cost associated to incidents and accidents. And for good or bad, everything ends up in a 4-letter acronym that almost everybody knows: PDCA.

The Plan-Do-Check-Act cycle is the cornerstone of any system, documented or not, and rules the ways companies and the economy work. The natural business-application of PDCA comes through the implementation of a management system, which establishes some guidelines to ensure that the full cycle is applied and maintained. Every company has a management system in place, documented or not, certified or not.

The cycle starts by planning. In order to make a plan, you need to know who you are, what you do, who has interest on what you do, and what is everybody expecting from you. Also, you need to know where you want to go and set the target. With this body of information, you can set the rules of the game by leading your team to create a plan which can support you to reach your goals, your business goals. This plan is not an easy thing, it requires dedication, commitment and accountability from the people who participate in it.

Based on the good understanding of this context of your business, focusing on your processes and performing a risk-opportunities analysis, it’s easy to visualize what needs to be done, what the priorities are and what drives the desired outcomes. So, writing down the plan gives you the opportunity to look at it from every angle, ensuring that covers it all, and that it is managing the risks and levering relevant opportunities.

Congrats, now you have a great plan! Your next and easy step is to put it at work. So, now you have processes running your operation which are based on your plan, but… are they achieving the OUTCOMES you planned? How could you know?

And here is where we deal with CONTROLS and indicators. If you do something, at least you want to know if you are doing it right. This becomes a natural thing. For your processes, you want to know if they are not just giving the intended results, like manufacturing a piece according to specifications, but you want also to know if that piece fulfills the expectations of all the people who has interest on it, and further than that, you need to know if it is taking you closer to the target. So, you need to find SMART ways to figure it out.

Let’s make a pit-stop for a minute and focus on three words I remarked: outcomes, controls and SMART. Any indicator must be Specific, Measurable, Accountable, Reasonable and Timely, SMART, you already knew that. This has been out there for decades. But the great trick with indicators is controls and outcomes. Years of practice have demonstrated that it is not enough to measure the RESULTS of a process. You can have a process which is giving you consistent results, but which is not going to where you want it to go. And this is exactly what has been happening with EHS.

We are so used to measure the composition of the exhaust of a boiler and to compare it to the regulations or to count the days without accidents and to compare it with a target, that we think this is a good deal. But we still have days out-of-specs and accidents. What’s wrong then?

The secret is how you define your controls and how you measure your processes. At “the end of the pipe” you can only be reactive. If you want to be proactive and achieve not only your intended results but your mission-critical goals, you need to go beyond and set your controls up-stream your processes, far from the end of the pipe. The trick is to find those process variables that have the most significant impact on the intended outcomes. But the good news is that you have a plan, and your plan includes a clear understanding of the context of your processes and a thorough risk-opportunities analysis, right?

Well, then you are all set up. This is exactly what “leading indicators” mean. While lagging indicators are reactive by nature, leading indicators focus on establishing appropriate controls upstream the process where the identified variables and its associated risks -which cannot be eliminated or minimized-, can be monitored in such a way that any deviation can be timely managed to avoid an undesired outcome.

This is the most powerful tool you have. This means that Zeroaccidentland could be more than a myth. If you can properly understand your context, identify and manage the risks at every step and set proactive controls and measurements to ensure your plan is working, then you will certainly reach your goal.

Just don’t forget to analyze the results and make adjustments, remember that PDCA is a live cycle!