Measuring Health & Safety Performance

Importance of measurement and management

What gets measured, gets managed.

RoSPA suggests that one of the reasons why Occupational Safety & Health (OSH) receives less board-level attention than other organisational priorities is the complexity of measuring prevention across dynamic virtual and physical environments.

The focus must be managing and measuring OSH performance, giving budget holders a clear picture of its value creation potential and positive impacts beyond measured outcomes.

Regulations and Standards

The Health and Safety at Work, etc. Act 1974 requires organisations ‘ensure’ the health and safety of their employees and any non-employees who may be affected by their activities. While there is no mention here of measuring performance, measurement is implicit in showing effective performance of this duty.

The Management of Health and Safety at Work Regulations 1999, sometimes called the ‘management regs’, outline the requirement for monitoring and review of preventive and protective measures. They say that employers must have suitable management arrangements which take account of the scale and nature of work activities. Suitability can be implied by measuring OSH performance, which provides evidence to show compliance with these regulations.

The Health and Safety Executive (HSE) has published HSG65 - Successful Health and Safety Management. This is an over-arching guide on the philosophy of good health and safety and how to achieve it. The chapters of HSG65 reflect the fact that the principles of managing health and safety are aligned with management strategy in other organisational priorities (e.g. quality, production and HR).

HSG65 promotes the use of a safety management system and notes the value of measurement and 'benchmarking'. HSE publishes sector-specific benchmarking for stress, safety climate and home and hybrid working. Comparing the organisation’s OSH performance with others within the sector can provide a compelling case for improvement to maintain a competitive edge.

Limitations of Lost Time Injury (LTI) rates

Many organisations do not measure OSH performance, and those that do often rely heavily on lagging indicators such as lost time injury (LTI) rates. Here the length of time since the last lost time work-related injury is given high weighting as the principal indicator of OSH performance. ‘Target Zero’ initiatives commonly emphasise time since last LTI, but this approach can also be misleading.

Although simple and widely understood, exclusive use of LTI rates is problematic, meaning organisations can overlook important indicators of effective OSH management such as near misses, unsafe conditions, injuries to non-employees, and work-related ill health. It also offers limited insight into safety culture or management effectiveness over behaviour change and attitudes.

Accident triangle models, which suggest ratios between frequency of LTIs and other harms like minor incidents, are not universally applicable and can encourage under-reporting and complacency. HSG65 cautions against using these ratios as success in preventing minor injuries does not necessarily equate to good control of high-risk processes. For example, success in preventing slips, trips and falls does not infer success in managing toxic, flammable or explosive inventories.

It may be tempting to infer that a health and safety management process which produces a low LTI rate also offers good health protection to workers. But the absence of recorded injury cannot be taken to imply a low rate of work-related harm to safety or health.

Interpretation of injury rate trends should be supported by additional indicators:

• Near miss incidents
• Unsafe acts and conditions
• Environmental quality (airborne contaminants, noise, vibration etc.)
• Work-related health conditions.

Health-related risks, such as occupational disease, can have greater long-term impact than injuries. HSE estimates 13,000 annual deaths from past exposure to hazardous conditions, far exceeding the number of annual fatalities from accidents.

Low LTI rates should not be assumed to reflect strong health protection or overall OSH performance. OSH professionals should assess if varying accident rates are part of wider shift in OSH performance or whether they are within the limits of random variation.

Supporting better OSH management

Better OSH management is supported through proactive and reactive monitoring and should use a mix of leading and lagging indicators. For example, specific inspections and workplace tours using checklists, environmental sampling, behaviour sampling, attitude surveys, and hazardous event or near-miss investigation.

"Accident data should never be used as the sole measure of OSH performance - organisations should select a combination of indicators as OSH performance measures”.

Auditing health and safety management systems

The measurement of OSH performance using audit systems to produce a score or ranking is increasingly common, particularly in larger, high hazard organisations.

Output performance measures such as LTI rates are mistakenly seen as the most valid indicators of success in accident prevention. However, we know these carry intrinsic weakness. Monitoring indirect indicators associated with process rather than output is a stronger measure.

Periodic, structured OSH management systems audits can provide a more meaningful reflection of performance changes over time. An OSH audit enables the duty holder to identify strengths and weaknesses in existing management arrangements, including gaps between theory and practice, and to assess the combined impact of management changes on performance over time. Involvement auditing can improve understanding of health and safety management, for example, when managers and workforce representatives are jointly involved in evidence gathering and analysis.

Developing audits for small organisations remains a challenge. Audits should be detailed enough to measure performance - this may be adequately achieved by periodic inspection or process compliance review. Where risks are substantial or safety depends on rigorous adherence to procedures, it may be appropriate to seek added assurance through use of third-party audit services.

What is an OSH audit?

There are many approaches to auditing. Like a manager measuring performance, it may collect evidence through observation, interview, tracking process compliance, and review outcomes against pre-determined targets. Crucially OSH auditing, like financial auditing, constitutes an external and independent, check over how well organisational practice adheres to existing process and systems.

Some auditing systems, like RoSPA's health and safety systems audit, are based on HSG65. This involves question sets which probe the integrity and performance of management systems horizontally, while including some vertical 'verifiers'. Other systems take the form of vertical compliance audits based around certain activities or specific legislation.

Whatever the approach, OSH auditing should verify control of risks through preventive measures as well as the effective operation of the health and safety management system. Evidence from documents, observations and interviews can assess the adequacy and implementation of elements such as H&S policy, organisation, planning and implementation, monitoring and review. The audit process should verify the system can also detect emerging risk and implement controls before harm occurs.

Regulation and auditing

HSG65 advocates for auditing and items to consider in selecting and/or preparing for audit. Further sector-specific guidance could be useful to help organisations tailor their approach. At present auditing is used mainly as an internal management technique, benchmarking then spotlighting areas for improvement. Its outputs can also be used to evidence good health and safety management to stakeholders (clients, business partners, investors, insurers, shareholders, workforce representatives and enforcing authorities) or as a basis for certification.

With the exception of some high hazard industries, there is no legal requirement for organisations to audit their health and safety management systems. Although there is an implication in Regulation 5 of the Management regulations that companies should undertake audit, there is a strong case for making this an explicit requirement.

RoSPA is arguing for clarity on interpretation of regulatory requirements for auditing. HSE could be given the power to require independent auditing, for example, in high-risk organisations or activities or following convictions for health and safety offences.

A health and safety management standard

ISO 45001 is the international standard for OSH management systems, certification to which is also based on auditing. Organisations aspiring to certification should consider how best they can evidence their capability to manage health and safety by demonstrating that they:

• Have the essential elements of a health and safety management system in place
• Are measuring progress against plans and targets
• Are on a path of continuous improvement
• Are learning from their health and safety experiences

RoSPA believes that consensus about health and safety management system standards and auditing is vital. Our concerns with existing frameworks include:

• Unspecified level of competence required of auditors, which can undermine audit integrity
• Over-reliance on documents rather than evidence gathered by interview or observation
• Certification to standards risks stalling improvement of overall performance, instead promoting administrative consistency
• Certification promoted to inappropriate organisation by certifying bodies, leading to additional costs, bureaucracy and no real added value

Smaller organisations should refer to ISO 45002 for approaches which are proportionate to their circumstances (for example, reporting against a simple health and safety action plan).

Measuring safety culture

There is a growing appreciation that an organisation’s ‘safety culture’ can be as influential over real-world outcomes and OSH performance as OSH management systems.

“The way we do things around here” - safety culture is the collective attitudes, beliefs, behaviours and values of all employees at an organisation, and how these influence how things are actually done. HSG65 explains culture in the terms of control, co-operation, communication and competence. 

Organisations with a positive safety culture are characterised by communications founded on mutual trust, by shared perceptions of the importance of safety, and by confidence in the efficacy of preventive measures. Poor safety culture undermines OSH management systems and may even mask high rates of accidents and injury.

Safety culture is complex and measurement can present a challenge, particularly in organisations who have typically focused on LTI. Safety culture is usually measured using questions which examine the attitudes of employees towards OSH. Other factors which may also influence safety culture include:

• management commitment and style
• employee involvement
• training and competence
• communication
• compliance with procedures
• organisational learning

Target Setting

Targets must be grounded in robust data, analysis, and understanding of risk management processes. They should reflect accident causation and preventability, supported by clear baselines. Transparency in reasoning and stakeholder involvement is critical for credibility and workforce buy-in.

Employees, as key holders of operational knowledge, should be consulted through formal structures (e.g. safety committees) and encouraged to contribute ideas and share experiences. Collaborative, evidence-based target setting ensures meaningful progress toward improved OSH performance.

Effective targets include both output measures (e.g. near-miss rates, reductions in harmful exposures either physical, psychological, or environmental) and process measures (e.g. OSH management practices). Unrealistic or arbitrary targets undermine engagement and should be challenged to protect safety culture. If targets are shown to be misaligned to goals or a poor reflection of outcomes then they should be revised to avoid superficial compliance, particularly if duty holders are diverted to deliver against them rather than focus on the real, underlying objectives.

The big picture

In practice, measuring all these parameters effectively is labour-intensive. Organisations which are currently assessing OSH performance using single measures, such as accident rates, should be encouraged to adopt a more integrated approach.

OSH performance is inherently multidimensional, and no single metric can fully reflect an organisation’s effectiveness. Even the best measurements provide a snapshot and should be reviewed regularly. It is essential to adopt an integrated approach combining:

• Leading indicators e.g. safety culture, integrity of management systems.
• Lagging indicators e.g. compliance with control standards, implementation practices.
• Verification measures e.g. error, harm, and loss data.