Call for OSHA NEP on SIF prevention at House Workforce Protections Subcommittee

Safety professionals emphasized using leading safety indicators, in contrast to OSHA’s current lagging indicators, during a May 13 U.S. House of Representatives Workforce Protections Subcommittee hearing.

Titled “Building a Safer Future: Private-Sector Strategies for Emerging Safety Issues,” Subcommittee Chairman Ryan Mackenzie (R-PA) emphasized a need for “collaborative, practical policymaking” to prevent serious injuries and fatalities (SIFs) in today’s workplaces.

“While the nature of work constantly changes, the regulatory framework governing workplace safety has often struggled to keep pace,” Mackenzie said. “To achieve further improvements, we must look to frontline workers, business owners, researchers, and safety experts who are developing innovative approaches to workplace safety”

Leading indicators already helping identify hazards

Pat Sughrue, Cianbro Corp senior corporate director of health, safety, and environmental, presented how the general contractor’s “proactive, measurable safety systems” successfully keep workers safe.

Sughrue said OSHA’s total recordable incident rate (TRIR) “is a lagging, no-fault outcome measure - it reflects injuries that have already occurred rather than the conditions and behaviors that create risk.

“In contrast, leading indicators measure the inputs and processes that prevent injuries before they occur and directly assess how well a safety system is functioning in real time,” Sughrue said. “These indicators are actionable: They tell leaders what to improve, where risk exists, and who needs support - long before someone is hurt.”

Examples of Cianbro’s leading indicators include:

• Daily Stretching, Communication, and Fit for Duty Evaluations
• Daily reporting of all good catches, near misses, and environmental impacts
• Identifying High Energy Hazards and Controls, including tracking, trending, and actions shared
• Safety walks, Audits, X-rays, and trends
• Peer-to-Peer Behavioral Observations
• Craft Observations Raising Excellence (CORE) Committees led by craft professionals
• Daily pre-task planning and meetings, including Jobsite Hazard Analysis and Jobsite Safety Analysis (JSA)
• New-hire orientation and site-specific orientation
• Lifelong Education and Development tracking
• Last Minute Risk Analyses

Sughrue also cautioned the highly-visible TRIR is often perceived as a “scorecard” despite OSHA treating injury recording as a no-fault process, which can encourage underreporting and shift focus to blaming.

“Leading indicators, by contrast, reinforce a learning-based safety culture by rewarding problem identification, transparency, and corrective action,” he added.

NSC calls for SIF National Emphasis Program

Lorraine Martin, National Safety Council CEO, said leading indicators can provide early awareness of potential SIFs, shifting the attention of safety professionals as well as employees from reaction to “hazard hunting.”

Martin said NSC advocates for employers to implement their own SIF prevention practices, but also for OSHA to establish a National Emphasis Program (NEP) on SIF prevention in specific industries.

“An NEP would accelerate the shift from reactive compliance to proactive risk management by explicitly encouraging employers to advance in their safety maturity,” she said. “An NEP focused on SIF prevention would also signal that preventing serious injuries and fatalities requires a higher level of organizational maturity than traditional lagging indicator compliance.”

Martin said NSC outlined SIF prevention practices in its SIF Prevention Model, using ANSI/ASTM E2920-26, a “Standard Guide” for recording occupational injuries, illnesses, and SIFs, as a framework.