
By Chet Brandon
EHS data is only useful when it helps leaders make better decisions and take timely action. Incident reports, corrective action records, hazard observations, audit findings, injury data, exposure information, and corrective action trends all contain signals. The leadership challenge is knowing which signals deserve action now, which need more investigation, and which are simply background noise.
In this context, heuristics are not guesses or shortcuts used to avoid thinking. They are practical decision strategies that help leaders make timely judgments when information is incomplete, time is limited, and operational complexity is high. Gigerenzer and Gaissmaier (2011) describe heuristic decision making as a way to simplify judgment under uncertainty, which is directly relevant to EHS leadership where decisions often must be made before every fact is perfectly known.
That matters because EHS leaders rarely operate with perfect information, unlimited time, or a fully controlled operating environment. We often have enough information to detect signals, enough experience to recognize patterns, and enough responsibility to act before risk becomes consequence.
Over my career, I have learned that effective EHS analysis does not require unnecessary complexity. It requires disciplined review, practical judgment, and a strong bias toward action. A dashboard that does not change a decision is just decoration. The purpose is to understand what the system is telling us and act before weakness becomes failure.
These heuristics are experience-based review tools. They do not replace technical analysis, regulatory review, industrial hygiene assessment, engineering evaluation, or legal guidance where those are required. Their value is helping leaders recognize patterns quickly enough to start the right work.
These tools and tactics were not developed in a classroom or from theory alone. They come from roughly 35 years of experience in heavy industry, including chemicals, metals, glass, aerospace, manufacturing, and industrial services. They were also sharpened through extensive work with an asbestos legal defense team for a Fortune 500 manufacturing company, where I learned how important it is for EHS decisions to be fact-based, well-documented, professionally sound, and explainable under serious scrutiny. That experience reinforced a practical lesson: if an EHS decision cannot be clearly explained and ethically defended, it probably needs stronger analysis before it is accepted.
A Practical 6-Step EHS Data Review Method
When reviewing EHS performance data, I generally use six practical questions.
1. What Is the Trend?
Start with the trend. Is performance improving, deteriorating, stable, or shifting unexpectedly?
Look at magnitude, direction, velocity, and stability. A large number may matter, but a sudden change in an otherwise stable pattern may matter even more. When data moves quickly in the wrong direction, leaders should not dismiss it as noise until they understand what changed.
A spike in injuries, a sudden increase in corrective action delays, a change in severity potential, or a shift in event location may indicate a change in exposure, work mix, staffing, supervision, procedure quality, or control effectiveness.
The first leadership question is simple:
What changed, and why?
2. What Are the Top Recurring Drivers?
After reviewing the trend, apply Pareto logic.
Most EHS performance issues are not evenly distributed. A small number of event types, tasks, locations, hazards, or control failures often account for a large share of the total impact. I typically look for the top three to five recurring issues because those are often the most actionable.
This keeps the organization from spreading improvement energy too thin. The goal is not to fix everything at once. The goal is to focus first on the issues creating the most repeated failures or the greatest operational risk.
The key question is:
What few issues are driving most of the problem?
3. What Separates the Best From the Worst?
The next step is to compare the Best of the Best with the Worst of the Worst — the BOBs and WOWs.
When one site, department, shift, crew, or process is performing much better than another, the difference is usually not accidental. The best performers may have stronger planning discipline, better supervision, more effective pre-job reviews, stronger engineering controls, better housekeeping, faster corrective action closure, or more consistent frontline engagement.
The value of this comparison is that it identifies solutions already working inside the organization. Instead of importing a theoretical best practice, leaders can transfer a proven internal practice to weaker areas. The Shainin System is a problem-solving system associated with strategies and tools for quality improvement and identifying dominant causes (Steiner et al., 2008).
The practical question is:
What are the best performers doing that the worst performers are not?
4. What Severe Exposure May Be Hiding in the Data?
Frequency is important, but it is not enough.
Some serious exposures may not appear often in the data but still carry severe consequence potential. These are the plausible Black Swan-type events that may be hidden inside routine work. A task may have few recorded injuries but still contain fatality, serious injury, fire, explosion, chemical exposure, or environmental release potential.
Leaders need to ask:
What low-frequency, high-consequence event could occur here?
Taleb’s Black Swan concept is commonly associated with events that are highly improbable, difficult to predict, carry major impact, and are often explained too easily after the fact (Taleb, 2007). In EHS leadership, the practical value is not debating whether an event is perfectly unpredictable. The value is forcing ourselves to look beyond the most frequent items in the data and ask where the operation could fail severely.
I am especially interested in severe risks that can be meaningfully reduced with modest resources. If a high-consequence exposure can be reduced through a practical control, it should not be ignored simply because it does not dominate the incident count.
Pareto analysis tells us where we are failing often. Black Swan thinking tells us where we could fail badly. Both are necessary.
5. Are the Corrective Actions Strong Enough?
Once the patterns are understood, the next question is whether the proposed corrective actions are strong enough to control the risk.
The NIOSH Hierarchy of Controls is a useful starting point. NIOSH identifies the preferred order of controls as elimination, substitution, engineering controls, administrative controls, and personal protective equipment. NIOSH also notes that elimination, substitution, and engineering controls are generally more effective because they control exposures with less reliance on human interaction (National Institute for Occupational Safety and Health [NIOSH], 2024).
That does not mean every solution can be engineered immediately. It does mean leaders should avoid over-relying on weak controls when stronger controls are feasible.
There also needs to be balance. Engineering controls can be highly effective, but they may require capital, design time, or longer implementation. Procedural and behavioral controls can move faster, but they depend on consistent human execution. A strong corrective action plan often uses layers: immediate interim controls, practical near-term actions, and stronger long-term controls where needed.
Before accepting a corrective action, I ask:
- Does this reduce the actual exposure, or does it only remind people to be careful?
- Is it aligned with the hierarchy of controls?
- Can it be implemented quickly enough to matter?
- Does it apply beyond one isolated event?
- Does it address a recurring driver or a credible severe-risk exposure?
- Is there an owner, due date, verification method, and effectiveness check?
- Would this action prevent the same event under real operating conditions?
If the answer is no, the corrective action is not ready.
6. Which Actions Deserve Priority?
Prioritization should consider both potential impact and resource requirement.
High-impact actions that require modest resources should move quickly. These are often the best opportunities to strengthen the system without waiting for a major program, capital project, or lengthy redesign.
A simple prioritization model works well:
| Priority | Impact | Resource Requirement | Leadership Response |
|---|---|---|---|
| 1 | High | Low | Act immediately |
| 2 | High | Medium or High | Establish interim controls and plan permanent correction |
| 3 | Medium | Low | Implement through routine improvement work |
| 4 | Low | High | Defer unless required for compliance, strategy, or risk reduction |
This does not mean difficult high-risk issues can be ignored. If a credible high-risk exposure exists, some level of control is required. The task is to sequence the work intelligently: immediate containment, practical short-term improvement, and sustainable long-term control.
Is the Decision Ethically Defendable?
A final test I use before accepting a significant corrective action or risk decision is whether the decision is ethically defendable.
In practical terms, I ask myself a hard question:
If I were on the stand in a court of law explaining this decision, would I be comfortable defending it?
That question sharpens the analysis. It moves the decision beyond preference, convenience, budget pressure, or organizational habit. It forces a leader to consider whether the action was reasonable, informed, timely, and consistent with the known risk.
This is not about making every EHS decision from a defensive legal posture. That would slow the organization down and weaken judgment. It is about testing whether the decision can withstand honest scrutiny.
In a court of law, a position is defended through facts, records, credible reasoning, and consistency with accepted professional practice. For expert testimony, Federal Rule of Evidence 702 addresses whether testimony is based on sufficient facts or data, uses reliable principles and methods, and applies those principles and methods reliably to the facts. That is a useful practical screen for EHS decision-making even outside litigation (Legal Information Institute, n.d.).
For EHS decisions, I ask:
- What facts supported the decision?
Data, observations, audits, interviews, photos, risk assessments, or technical findings. - Was the reasoning documented?
Who was involved, what was considered, what alternatives were evaluated, and why the final action was selected. - Was the method professionally sound?
Did we use recognized standards, hierarchy-of-controls thinking, competent judgment, and reliable information? - Did we consider feasible stronger controls?
A weak control is hard to defend if a stronger practical control was available. - Was the response proportional to the risk?
Higher-severity exposures require stronger and faster action. - Was the decision ethically aligned?
The action should reflect the professional obligation to protect people, the environment, property, and professional integrity. - Could I explain it clearly under questioning?
A defensible decision should be easy to explain: what we knew, what we considered, what we did, why we did it, and how we verified it.
As part of that final evaluation, I also use the BCSP Code of Ethics as a professional cross-check. BCSP requires applicants, candidates, and credential holders to uphold its Code of Ethics, and the Code includes the duty to hold paramount the safety and health of people and the protection of the environment and property (Board of Certified Safety Professionals [BCSP], n.d.).
For me, that means the decision should place protection ahead of convenience, pressure, or expediency. It should be honest, fact-based, professionally competent, free of improper conflict, and consistent with the integrity expected of the safety profession.
The courtroom test strips away excuses. It forces the question: did we make a responsible decision with the facts, resources, and options available at the time?
Ethically defendable does not always mean perfect. Leaders often make decisions with incomplete information, competing priorities, and real operational constraints. But ethically defendable does mean the decision was made with integrity, competence, urgency, and proportionality to the risk.
If I would not feel comfortable explaining the decision under oath, or if the decision does not align with the professional obligations reflected in the BCSP Code of Ethics, then the decision is not ready. It needs stronger analysis, stronger controls, better documentation, faster timing, clearer ownership, or a different course of action.
The leadership standard is simple:
Make decisions you can defend because they were technically sound, ethically grounded, professionally responsible, and aligned with the duty to protect people, the environment, and the business.
A Practical Example
Consider a company reviewing 12 months of hand injury data.
The trend shows a sharp increase in the last quarter. Pareto analysis shows that most events involve line-clearance, jam-clearing, and minor adjustment tasks. A BOBs/WOWs comparison shows that the best-performing site uses fixed guarding standards, pre-task verification, and supervisor field observation. The worst-performing site relies mostly on verbal reminders and retraining after events.
A Black Swan review identifies a credible amputation pathway: unexpected startup or incomplete energy isolation while an employee’s hand is inside the point of operation. The hierarchy-of-controls review shows that the existing corrective actions are too dependent on employee attention and memory.
A stronger action plan would include:
- Immediate verification of guarding and energy-control expectations
- Temporary restrictions on higher-risk adjustment tasks until controls are confirmed
- Engineering review of guarding, interlocks, access points, and potential bypass conditions
- Standardized pre-task verification for line-clearance and jam-clearing work
- Supervisor field verification for high-risk tasks
- Targeted retraining only as a supporting action, not the primary control
- Follow-up review to confirm whether hand injuries, bypass conditions, and high-risk observations decline
This is the difference between reporting data and using data to improve control of the operation.
Red Flags That Should Trigger Executive Attention
Certain patterns should immediately raise concern:
- High-energy incidents or near misses
- Extreme changes in otherwise stable data
- Repeating failures across multiple sites, departments, shifts, or crews
- Poorly written incident descriptions that suggest weak understanding
- Repeat involvement by the same individuals, tasks, equipment, or supervisors
- Significant outliers
- Clustering by body part, equipment type, location, task, contractor group, or failure mode
These patterns may indicate more than isolated failure. They may signal a weakening management system, inconsistent supervision, poor hazard recognition, ineffective corrective actions, or loss of operational discipline.
EHS Data Review Worksheet
A practical EHS data review should answer these questions:
- What changed?
- Is the trend stable, improving, deteriorating, or shifting suddenly?
- Where is the issue concentrated?
- What are the top three to five recurring drivers?
- Who are the BOBs and WOWs?
- What are the best performers doing differently?
- What severe exposure could be hidden in the data?
- What controls currently exist?
- What is the highest feasible level of control?
- Which corrective actions are high-impact and practical?
- Is the decision ethically defendable?
- Would I be comfortable defending the decision under oath?
- Is the decision consistent with the BCSP Code of Ethics?
- Who owns each action?
- When will it be completed?
- How will effectiveness be verified?
If a review does not answer these questions, it is not complete.
The Leadership Standard
The value of EHS data is not in the dashboard. It is in the decision the dashboard enables.
A strong review process should identify where risk is moving, what is driving it, what controls are weak, and which actions will most effectively improve the system. Leaders should expect data analysis to produce clear conclusions, prioritized action, assigned ownership, timing, and verification of effectiveness.
Good EHS analysis answers four basic questions:
What is changing?
What is driving the change?
What risk does it create?
What action will reduce that risk?
EHS performance improves when leaders turn information into disciplined execution. That means identifying trends, focusing on the vital few, learning from internal high performers, staying alert to severe-risk exposure, using the hierarchy of controls, testing decisions for ethical defensibility, and prioritizing corrective actions that are timely, practical, scalable, and effective.
The goal is not simply to understand the data.
The goal is to strengthen the operation.
References
Board of Certified Safety Professionals. (n.d.). BCSP code of ethics. https://www.bcsp.org/hubfs/8981246/Downloads-PDFs-and-PPTs/BCSPcodeofethics.pdf?hsLang=en
Gigerenzer, G., & Gaissmaier, W. (2011). Heuristic decision making. Annual Review of Psychology, 62, 451–482. https://doi.org/10.1146/annurev-psych-120709-145346
Legal Information Institute. (n.d.). Rule 702. Testimony by expert witnesses. Cornell Law School. Retrieved June 7, 2026, from https://www.law.cornell.edu/rules/fre/rule_702
National Institute for Occupational Safety and Health. (2024, April 10). Hierarchy of controls. Centers for Disease Control and Prevention. https://www.cdc.gov/niosh/hierarchy-of-controls/about/index.html
Steiner, S. H., MacKay, R. J., & Ramberg, J. S. (2008). An overview of the Shainin System for quality improvement. Quality Engineering, 20(1), 6–19. https://doi.org/10.1080/08982110701648125
Taleb, N. N. (2007). The black swan: The impact of the highly improbable. Random House.












