The Problem 

If you ask a group of EHS professionals whether they are getting quality, actionable data from their observation programs and BBS initiatives, a significant number will say no. But why?

In my experience, the majority of data coming out of observation programs, BBS programs, and other leading indicator monitoring efforts are focused on what I like to call the "low hanging fruit", the low-energy hazards that typically don't result in serious injuries or fatalities. Think PPE compliance, housekeeping, and minor procedural issues. These are real hazards, and I'm not suggesting we completely ignore them. But the question worth asking is: are these the highest priority hazards for me to assess and address?

The answer is generally no. Yet, these are the hazards that dominate our leading indicator data and therefore are where we spend an outsized amount of our focus and attention.

The reason is straightforward. Low-energy hazards are easier to see and easier to understand. An observer walking a job site can spot a missing hard hat or an extension cord across a walkway without much effort. Identifying a high-energy critical hazard (a residual pressure exposure, a rotating equipment exposure, an electrical exposure) requires more thought, more time, and a framework to guide the identification and assessment. Without a framework, observers default to what is easiest to recognize.

There is actually a biological basis for this. Hazards that are visually obvious are processed instinctively and require comparatively low cognitive effort, others require the observer to engage in higher-order thinking - they need to understand energy transfer, an underlying hazard or a systematic hazard. This is why the same types of critical hazards get missed over and over again.

The result is that our leading indicator programs are generating a lot of data about low-severity (low-energy) hazards, and comparatively little data about the exposures that are most likely to cause serious injuries and fatalities (SIFs). This matters because the hazards that cause SIFs are not simply "worse versions" of the hazards that cause first aid cases. Research has shown that different exposures lead to different outcomes and the hazards with >=1500 Joules of energy are the ones that are most likely to result in SIFs. These are high-energy hazards. 

The “Work-as-Imagined" vs The “Work-as-Done”

The second issue I have encountered throughout my career has to do with how we use risk assessments and risk registries.

These are valuable tools. I want to be clear about that. Risk assessments create a structured opportunity for cross-functional collaboration to identify hazards and document controls. This ensures there is alignment and visibility across the different levels of the organization. They add significant value. But there are two consistent problems I have seen arise.

The first is that risk assessments typically reflect "work-as-imagined" rather than "work-as-done." Most risk assessments are completed in an office or conference room setting, where the team is identifying hazards and controls based on best-case conditions. In the field, best-case conditions often don't exist. Time pressures, equipment disruptions, changing conditions, and workflow variations can all affect both the hazards present and the effectiveness of the controls in place. The question worth asking is: what do the hazards and their associated controls actually look like when this task is performed in the real world?

The second problem is subjectivity in risk scoring. Most systems I have worked with use some combination of frequency and severity ratings to generate a risk score. The problem is that two experienced practitioners can look at the same hazard, for the same task, at the same location, and arrive at meaningfully different scores. This variability makes it difficult to compare assessments over time, across facilities, or between assessors. And if we cannot reliably compare the data, it is hard to trend it and even harder to make resource allocation decisions based on it.

A New Approach: High Energy Control Assessments

This is where High Energy Control Assessments (HECAs) can help organizations.

The core concept behind HECAs is straightforward: safety performance is better measured by the presence of effective controls than by the absence of injuries. Rather than asking "has anything bad happened?", HECAs ask whether the critical high-energy hazards present in a work environment are directly controlled right now, in real-time, as work is being conducted.

In practice, a HECA works like this. An observer goes into the field during an active work task and identifies the high-energy hazards present in that environment. For practicality in the field, SafetyFunction has created 13 high-energy icons (hazards with >=1500 Joules of energy) that account for the majority of high-energy hazards found across work tasks. For each high-energy hazard identified, the observer assesses whether a direct control is in place.

A direct control has a specific definition. It must be specifically targeted to the high-energy source. It must effectively mitigate exposure when properly installed and used. And it must remain effective even if there is unintentional human error during work that is unrelated to the installation of the control.

The scoring is what makes HECAs particularly useful from a data standpoint. Each high-energy observation receives a binary label: Success (the high-energy hazard has a corresponding direct control) or Exposure (the high-energy hazard does not have a corresponding direct control). There is no subjective “frequency x severity” calculation. There is no assessor variability distorting the result. The outcome is an objective, rules-based score that can be trended over time, compared across sites, and used to drive data-driven resource allocation decisions.

This is also where HECAs complement existing risk assessment efforts rather than replacing them. Think of it this way. Your risk assessment tells you what the hazards and controls should look like for a given task. Your HECA tells you what the hazards and controls actually look like when that task is performed in real-time. Together, they give you both the work-as-imagined and work-as-done perspectives. The gap between the two is often where the most important learning opportunities are found.

BBS programs and supervisor checklists don't need to go away either. Pairing them with a HECA framework gives observers a structured tool to guide their attention toward high-energy hazards, rather than defaulting to what is easiest to see. Instead of trending the number of observations submitted, you can trend the percentage of high-energy hazards with direct controls in place across your sites and in order to identify the highest-risk tasks. This is the kind of data that you can bring to stakeholder meetings to help visualize real-time risk and to facilitate conversations on areas of focus and investment in order to mitigate exposures.

What To Do About It

As I mentioned above, this is not an argument for eliminating observation programs, BBS initiatives, or risk assessments. These tools all have a place in a well-functioning safety management system. But if we want to do a better job of mitigating SIF exposures and ultimately eliminating SIF injuries, we need tools that focus our hazard identification, monitoring, and safety investment on the exposures that typically cause serious injuries and fatalities, i.e. the high-energy hazard exposures.

High Energy Control Assessments provide organizations with a structured, objective tool to more easily identify and monitor the most critical job risks. They help us monitor work-as-done rather than simply work-as-imagined, and they give us a rules-based scoring method that can be trended to understand where we need to focus to meaningfully reduce SIF risk.

The value of the HECA framework described above hinges on whether organizations can consistently implement it in the field, at scale. That is where modern EHS technology becomes a meaningful catalyst: it can translate conceptual models into repeatable field practices, collecting structured data in real-time, in order to surface actionable insights that drive continuous improvement. At Intelex, we have developed a solution to do just that. Our HECA solution allows organizations to leverage this safety model while providing the added benefit of doing so through an EHS Management System technology.

If you have questions or want to learn more about any of the information outlined in this article, please feel free to reach out to Angelo.Cianfrocco@intelex.com. Or find additional supporting content at www.safetyfunction.com/ebs or www.intelex.com.