​PROGRAM EVALUATION & IMPROVEMENT covers control measures and periodic evaluation for effectiveness.  Verify that the program is implemented and is operating. Initially and at least annually, employers need to evaluate the program to ensure that it is operating as intended, is effective in controlling identified hazards, and is making progress toward established safety and health goals and objectives.

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Once a safety and health program is established, it should be evaluated initially to verify that it is being implemented as intended. After that, employers should periodically, and at least annually, step back and assess what is working and what is not, and whether the program is on track to achieve its goals. Whenever these assessments identify opportunities to improve the program, employers, managers, and supervisors—in coordination with workers—should make adjustments and monitor how well the program performs as a result. Sharing the results of monitoring and evaluation within the workplace, and celebrating successes, will help drive further improvement.

Program evaluation and improvement includes:

• Establishing, reporting, and tracking goals and targets that indicate whether the program is making progress.

• Evaluating the program initially and periodically thereafter to identify shortcomings and opportunities for improvement.

• Providing ways for workers to participate in program evaluation and improvement.

Action item 1: Monitor performance and progress

The first step in monitoring is to define indicators that will help track performance and progress. Next, employers, managers, supervisors, and workers need to establish and follow procedures to collect, analyze, and review performance data.

Both lagging and leading indicators should be used. Lagging indicators generally track worker exposures and injuries that have already occurred. Leading indicators track how well various aspects of the program have been implemented and reflect steps taken to prevent injuries or illnesses before they occur.

How to accomplish it

• Develop and track lagging indicators of progress toward established safety and health goals, such as:

  • Number and severity of injuries and illnesses

  • Results of worker exposure monitoring that show that exposures are hazardous

  • Workers' compensation data, including claim counts, rates, and cost

• Develop and track leading indicators, such as:

  • Level of worker participation in program activities

  • Number of employee safety suggestions

  • Number of hazards, near misses and first aid cases reported

  • Amount of time taken to respond to reports

  • Number and frequency of management walk-throughs

  • Number and severity of hazards identified during inspections

  • Number of workers who have completed required safety and health training

  • Timely completion of corrective actions after a workplace hazard is identified or an incident occurs

  • Timely completion of planned preventive maintenance activities

  • Worker opinions about program effectiveness obtained from a safety climate or safety opinion survey

• Analyze performance indicators and evaluate progress over time.

• Share results with workers and invite their input on how to further improve performance.

• When opportunities arise, share your experience and compare your results to similar facilities within your organization, with other employers you know, or through business or trade associations.

Note: Indicators can be either quantitative or qualitative. Whenever possible, select indicators that are measurable (quantitative) and that will help you determine whether you have achieved your program goals. The number of reported hazards and near misses would be a quantitative indicator. A single worker expressing a favorable opinion about program participation would be a qualitative indicator.

Action item 2: Verify that the program is implemented and is operating

Initially and at least annually, employers need to evaluate the program to ensure that it is operating as intended, is effective in controlling identified hazards, and is making progress toward established safety and health goals and objectives. The scope and frequency of program evaluations will vary depending on changes in OSHA standards; the scope, complexity, and maturity of the program; and the types of hazards it must control.

How to accomplish it

• Verify that the core elements of the program have been fully implemented.

• Involve workers in all aspects of program evaluation, including: reviewing information (such as incident reports and exposure monitoring results); establishing and tracking performance indicators; and identifying opportunities to improve the program.

• Verify that the following key processes are in place and operating as intended:

  • Reporting injuries, illnesses, incidents, hazards, and concerns

  • Conducting workplace inspections and incident investigations

  • Tracking progress in controlling identified hazards and ensuring that hazard control measures remain effective

  • Collecting and reporting any data needed to monitor progress and performance

• Review the results of any compliance audits to confirm that any program shortcomings are being identified. Verify that actions are being taken that will prevent recurrence.

Action item 3: Correct program shortcomings and identify opportunities to improve

Whenever a problem is identified in any part of the safety and health program, employers—in coordination with supervisors, managers, and workers—should take prompt action to correct the problem and prevent its recurrence.

How to accomplish it

If you discover program shortcomings, take actions needed to correct them.

• Proactively seek input from managers, workers, supervisors, and other stakeholders on how you can improve the program.

• Determine whether changes in equipment, facilities, materials, key personnel, or work practices trigger any need for changes in the program.

• Determine whether your performance indicators and goals are still relevant and, if not, how you could change them to more effectively drive improvements in workplace safety and health.

Note: The scope and frequency of program evaluations will depend on the scope, complexity, and maturity of the program and on the types of hazards it must control. Program evaluations should be conducted periodically (and at least annually) but might also be triggered by a change in process or equipment, or an incident such as a serious injury, significant property damage, or an increase in safety-related complaints.