ASA Offers Feedback on OSHA’s Use of Leading Indicators

ASA, along with the Construction Industry Safety Coalition (CISC), submitted comments in response to the Occupational Safety and Health Administration (OSHA)’s request for feedback on the effectiveness of leading indicators, which was announced on May 11, 2023. The CISC supports the agency’s development of a Leading Indicator Resource, and we offered the following comments:

“In the construction industry, it can be challenging to clearly define the most effective leading indicators, as certain safety measures that are successful within one sector, geographic location or even individual project may not yield the best results for others. Additionally, with the near-ubiquitous presence of multiple specialty trade contractors performing tasks throughout the lifetime of a project, certain best practices may not guarantee the success of a specific entity’s safety performance.  While there is no preset list of leading indicators that can be applied and have the same result on the extensive spectrum of construction projects, types of work performed and workers, members of the CISC have developed procedures that measure successful safety efforts within certain sectors of the industry. With this data, along with feedback provided by entities represented by Coalition members, the CISC recommends several best practices that can apply to a majority of jobsites at both the contractor and subcontractor levels and can be tailored to fit the needs of smaller businesses in order to maximize their effectiveness while minimizing employer burden.”

The Coalition’s recommendations include the following leading indicators that are commonly practiced throughout the industry:

• Training at All Levels Within a Business: Successful practices in this area include new hire safety orientations, where employers provide workers who are new or returning to the industry with an in-depth knowledge of job-specific hazard elimination and injury prevention processes, as well as an overview of the company’s safety culture that can be seen at every level. For a safety culture to exist, however, employers must also couple these orientations with recurring training for current workers and training that engages supervisors and other leadership.
• Programs that Emphasize Physical and Mental Well-being: More attention is being placed on emerging industry issues, such as mental health and substance abuse, as construction workers experience some of the highest rates of heavy alcohol and illicit drug use and suicide among full-time employees. Therefore, incorporating robust substance abuse programs and suicide prevention information and resources, many of which are more readily available and tailored to apply to different industries, as part of a business’s safety training program can be an effective method of reducing incidence rates.
• Safety Inspections and Safety Program Auditing: Not only are regular jobsite safety inspections a significant contributor to reducing jobsite injuries and illnesses, but reviewing a business’ safety program and correcting or strengthening potential flaws is another helpful method to improve safety performance. As the CISC includes small-business members, the CISC recognizes that not all businesses are able to implement these processes due to their size and financial/staff limitations. However, for the larger businesses that are able to conduct these regular inspections and analyses, they should consider utilizing these business practices.