Using Lagging Metrics for PSM Compliance

The Occupational Safety and Health Administration (OSHA) is suggesting that you use metrics to analyze and improve your Process Safety Management (PSM) program. Let’s see if some of these ideas will work for you. Today we will look at OSHA’s suggestions for using lagging metrics, and tomorrow we will review how leading metrics can help you track your compliance with PSM requirements.

Why Should You Use Metrics?

The best-run environmental, health, and safety (EHS) operations employ an approach to decision making, one based on data and facts. Decisions related to the allocation of resources, technology purchases, training, employee performance, and outsourcing or internalizing EHS functions can all be based on data compiled through the use of appropriate metrics.

A good performance metric can provide an organization with valuable information to help improve efficiency, increase profitability, expand capacity or programs, or plan for future needs. Management and employee performance rewards are often based on performance metrics, which send a clear message to employees at all levels of the organization about where their efforts should be focused. Likewise, if something is not measured, it can be perceived to have low priority in an organization.

What Do the VPP Folks Do?

OSHA surveyed examples of metrics that are used by facilities enrolled in its Voluntary Protection Program (VPP). OSHA contends that these facilities have achieved a high standard of safety excellence and other facilities would do well to follow some of their examples. Based on survey responses from VPP folks, OSHA has compiled a list of areas within the PSM program and some metrics VPP facilities use to track performance.

Is It Leading or Lagging?

Two types of metrics are commonly used to track PSM performance:

  • Lagging metrics are measurable factors or statistics that indicate facts about events that have already occurred. It is often easier to evaluate past performance than current or future conditions. Lagging metrics are often used to evaluate the cause of an incident and whether there is a potential for recurring problems.
  • Leading metrics are measurable factors or statistics that indicate, or are believed to indicate, the future value or direction of another variable. It is “leading” because its direction or magnitude of change can be used to, or is believed to, predict the behavior of something else.Leading metrics are preventive and give early clues to problems that can be corrected before a major process safety incident occurs.

Lagging Metrics for PSM

Examples of lagging metrics associated with PSM programs are:

  • Injury and/or incident reports, and
  • Unplanned or uncontrolled releases, aka, loss of containment

Injury and incident reports describe the causes of an incident that were identified by an investigation and the corrective measures taken or that should be taken to addresses the causes. According to OSHA, metrics that VPP sites use to track PSM incidents include:

  • Near-miss incidents that did not cause a loss of containment;
  • Recordable injuries and first-aid incidents that resulted from a loss of primary containment;
  • Number of incidents vs. number of incidents with formal reports; and
  • Status of incident investigations.

Loss of containment is an unplanned or uncontrolled release of materials. For these types of incidents, VPP facilities commonly track:

  • The number of incidents;
  • Whether there was primary or secondary containment; and
  • The cause and location of the incident.

Tune in to tomorrow’s Advisor to see which leading metrics VPP facilities are using to track the performance of their PSM programs.