Disclosures of Occupational Health and Safety Performance Indicators: A Perspective from South African Listed Companies

Abstract

Employers in South Africa are mandated by labour laws to implement systems of work for the maintenance and promotion of health and safety at work. In response, companies have adopted and implemented occupational health and safety management systems (OHSMSs) whose effectiveness should be continuously monitored through performance measurement. However, there remains no national convention on the specific performance measurement indicators for companies to use. The objective of this study was to determine, characterise and compare lagging indicators adopted and reported by the top 150 Johannesburg Stock Exchange (JSE)-listed companies in South Africa. This qualitative study evaluated annual reports and data books from these companies by analysing textual data through qualitative document analysis. Only 87 of the 150 case companies reported performance using lagging indicators. The basic materials, consumer goods, consumer services and industrial sectors had the most companies which reported performance metrics. Fatality count and lost time injury frequency rate (LTIFR) were the most commonly reported performance metrics and were reported by 64 and 41 companies, respectively. There was variation in the number, type and form of adopted lagging indicators by the case companies. Companies in the manufacturing and mining sectors were more likely to report OHS performance, in general, than those in other sectors. The observed variation across sectors emphasises the need for harmonised indicators to measure and report OHS performance in South Africa.

1. Introduction

Labour laws such as the Mine Health and Safety Act (No 29 of 1996) [1] and Occupational Health and Safety Act (No 83 of 1994) [2] in South Africa require employers to set up health and safety systems to ensure a safe and healthy workplace. Similar laws, the Health and Safety at Work (No 74 of 1974) and the Management of Health and Safety at Work Regulations, also exist in the United Kingdom [3,4]. The activities of health and safety systems are directed towards the prevention of fatalities, injuries and occupational diseases (ODs) [5,6,7]. However, over the last three decades, there has been insufficient evidence alluding to the effectiveness of employer-implemented health and safety systems [8]. However, statistics indicate a declining trend in the number of occupational injuries and diseases. Despite these noted declines, the aggregate numbers and protracted nature of some of these infirmities still remain stubbornly high [9,10,11,12]. The information gap is attributable to the lack of measurement guidelines on system effectiveness, globally. Government agencies such as the Health and Safety Commission (HSC) in the United Kingdom [13] and the Australian National Health and Safety Commission [14,15] have attempted to develop performance guidelines to assist companies in measuring OHS performance, a system outcome. Examples of performance indicators recommended by the HSC include the number of RIDDOR-defined (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations) injuries, illnesses and dangerous occurrences; details of any fatalities and preventative actions taken; lost time injuries (LTIs); and the number of health and safety enforcement notices, amongst others. Safe Work Australia until recently recommended the use of the LTI as a measure of OHS performance [14,15]. Guidelines on performance indicators for the prevention of chemical accidents have been developed by the Organisation for Economic Co-operation and Development (OECD) [16]. In South Africa, current legislation has a glaring weakness in that it omits the prescription of OHS performance measurement.

1.1. OHSMS, Performance Indicators and Corporate Reporting Behaviour

In South Africa, regulators do not prescribe a specific OHSMS that should be adopted and implemented by companies [1,2]. Companies therefore self-regulate on selecting the specific OHSMS applicable for their local conditions and activities. The ISO 45001:2018 [6] and the International Labour Organisation [17] standards are the most common OHSMSs and provide structured approaches for the management of health and safety at work, as well as the activities to be conducted to achieve compliance with legal requirements [6]. The complexity of the OHSMS is informed by the size of a company and nature of activities conducted. However, companies adopting voluntary OHSMSs for certification purposes are required to measure performance continually as a means of demonstrating conformance to system requirements. The ISO 45001:2018 [6] and the International Labour Organisation [17] standards do not prescribe indicators for use during performance evaluation of an OHSMS, leading to inter-company variance in reporting. On this point, the International Council on Mining & Metals (ICMM) has proposed requiring that affiliate companies report standard OHS performance indicators, enabling benchmarking [7,18]. For listed companies, OHS performance reporting forms part of corporate governance, which assures investors and other stakeholders of compliance with relevant laws [19].

Researchers on the subject matter have attempted to explain the context of company OHS disclosures through the lens of the legitimacy, stakeholder and institutional theories. These theories are all premised on the acknowledgement that companies operate within a community system [20,21]. The philosophical underpinnings of these three theories are complementary and are overlapping [21]; however, the legitimacy theory is commonly used for reporting social issues such as OHS disclosures [21] and is briefly explored. All three theories place an expectation on companies to comply with local laws [20,21]. The legitimacy theory postulates that companies continuously strive to be perceived by external stakeholders as being compliant with evolving societal norms and standards [21]. Confronted with this legitimacy gap, companies implement an OHSMS as an internal response mechanism that guides OHS activities [22]. The OHSMS outcomes are disclosed by companies to various stakeholders, a form of managing stakeholder expectations [21]. However, the extent of the disclosures made within integrated annual reports or sustainability or Environmental, Social and Governance (ESG) reports is an internal company issue and is determined through materiality analysis in line with adopted reporting frameworks [23]. On the basis of these theories, company disclosures will vary based on the form and extent of implemented OHSMS.

The next sections provide an overview of accident reporting, performance measurement and corporate disclosures and target setting in South Africa.

1.1.1. Accidents and Incident Reporting

Apart from the theoretical basis motivating companies to report OHS performance, there are formal legal reporting mechanisms of workplace accidents and incidents in South Africa. These legal reporting mechanisms are outlined in Sections 24 and 25 of the Occupational Health and Safety Act, 1993 [2] and Regulation 8 of the General Administrative Regulations [24] and apply to general industry. In the mining industry, the Mineral and Petroleum Resources Development Act 2002 [25] has similar reporting arrangements. Moreover, Section 35(7) and Section 36 in the Mine Health and Safety Act (1996) also require reporting of OHS incidences [1].

As part of the ongoing regulatory oversight, the Mine Health and Safety Act (1996) also require employers to submit statutory reports to the Provincial Inspector of Mines at specified periods including information contained in the occupational hygiene measurement programme and annual medical reports [1]. Employers under the Occupational Health and Safety Act of 1993 [2] are also required to submit biennial occupational hygiene reports to the Department of Employment and Labour on workplace surveys conducted by approved inspection authorities for occupational hygiene [26].

In the United States, companies report injury data that are input to compute the country’s injury rates, an arrangement absent in South Africa. Once computed, companies can find meaning in the submitted data as it allows for company and sectoral benchmarking [27].

1.1.2. Health and Safety Performance Measurement and Disclosures

Performance measurement is beneficial in that it can identify gaps and strengthen company-implemented OHSMS [28]. Performance measurement in OHS is based on the reporting of leading and lagging indicators. Leading indicators are “activity indicators” [29] “focused on a few critical risk control systems to ensure their continued effectiveness” [13]. Lagging indicators are “outcome indicators” [29] “requiring the reporting and investigation of specific incidents and events to discover weaknesses in that system” [13]. Most importantly, both indicators can prove useful as conclusions made from their analysis can prompt accurate exposure abatement measures [7]. The in-tandem use of both leading and lagging statistics can be maximised to the benefit of companies. Leading indicators provide an advance warning system for incidents when applied within the context of behaviour-based safety as they identify precursor variables [7].

Both leading and lagging indicators may be concurrently adopted by a single company; however, their usefulness is dependent on the complexity at which the analysis is conducted [7].

Lagging indicators, a departure point for this study, are used in risk-based performance measurement approaches, whereas in both the compliance-based and process-based approaches, leading indicators are used instead [30]. The performance measurement indicators should be relevant to both OHS and management [31]. Taken together, performance data derived from both leading and lagging indicators allow for the continuous comparison of present and past OHS performance levels. System auditing is also used as an alternative means of measuring OHSMS performance [32]. The use of OHS performance indicators as a measure of OHSMS performance should be from a viewpoint that depends on employee reporting. However, under-reporting and biased reporting threaten the validity of the reported OHS indicators [33].

Both leading and lagging indicators are reported in company annual or integrated annual or ESG reports in line with legal requirements such as the Companies Act, Act 71 of 2008 [34], as well as the JSE Sustainability Disclosure Guidance [35], ICMM [18] and Global Reporting Initiative (GRI) guidelines [36]. By reporting OHS performance, companies may be demonstrating or reporting progress made towards achieving voluntary commitments such as the United Nations Sustainable Development Goals (UN SDGs) and United Nations Global Compact (UNGC), amongst others. The JSE Sustainability Disclosure Guidance initiative and the GRI guidelines provide a reporting context, format and framework. The GRI framework [36,37], though voluntary, has gained prominent adoption and use by multinational companies, including those in South Africa. These frameworks include OHS performance indicators, such as leading and lagging indicators, which are expressed as statistics. This reporting aligns with the corporate legal compliance theory [38], providing the context of the motivation behind reporting compliance.

In South Africa, there are currently no formal regulatory reporting requirements of both leading and lagging indicators. In the absence of nationally prescribed performance indicators, companies discretionally develop internal monitoring, measurement, analysis and performance evaluation methods. Companies also freely select the frequency at which monitoring and performance measurement are conducted [6]. However, measuring OHSMS performance remains difficult for companies, as the “how” aspect remains unanswered [5].

Presently, there are various Key Performance Indicators (KPIs) used to measure the impact of company implemented OHS programmes [39]. Examples of such KPIs include the lost time injury frequency rate (LTIFR), OD counts, total recordable injury frequency rate (TRIFR), fatal injury frequency rate (FIFR), medical treatment cases (MTCs) and lost time injuries (LTI), amongst others [18]. However. there is no convention for which KPIs should be adopted across countries and companies. An effective approach to OHS performance measurement should be underpinned by the selection of indicators corresponding to companies’ OHS objectives [40].

1.1.3. Mine Health and Safety Council (MHSC) Milestone Targets

In the South African mining industry, the Mine Health Safety Council (MHSC), a tripartite legal structure created by the Mine Health and Safety Act in 1996 [1], sets milestone targets that mining companies should comply with as a contribution to OHS performance measurement [41]. Recent targets set in 2024 include a 20% reduction target for lost time injuries (LTIs) and serious injuries and a 95% compliance rate for measured respirable crystalline silica, coal dust respirable particulate and platinum respirable particulate [41]. The South African general industry, covered by the Occupational Health and Safety Act 1993, has no comparable performance targets. The MHSC milestone targets are the closest attempt South African regulators have come to prescribing performance measures for industry.

South Africa has a mature regulatory framework that prescribes the establishment of OHSMSs by companies and the reporting of accidents and incidents. Despite this regulatory state of affairs, the self-regulatory nature of the adoption of voluntary OHSMSs creates a gap. The specific gap relates to the lack of common performance measurement indicators across companies and sectors. This makes benchmarking OHS performance across companies and sectors cumbersome. There is a growing need for the evaluation of company OHS performance through the use of reliable, validated performance indicators in South Africa. Indicators adopted for measuring OHS performance inform future strategies and work practices [42]. The objective of this study is to determine, characterise and compare lagging indicators adopted and reported by the top 150 JSE-listed companies in South Africa.

2. Materials and Methods

This study considered the top 150 Johannesburg Stock exchange-listed companies (https://www.listcorp.com/jse/ (accessed 23 September 2024)) by market capitalisation, recorded on 23 September 2024, which was used as a cut-off date for report publication. The OHSMS performance indicators were published in company annual integrated reports or sustainability reports or Environmental, Social and Governance (ESG) reports. The sustainability or ESG reports were published separately from integrated reports by some companies and contained data on non-financial information such as OHS performance. Integrated reports contain both financial and non-financial performance information in a single report. The choice of reporting format lies solely with each company. The 2023 annual reports were targeted and selected to coincide with a 14-month lapse from the launch date of the JSE Sustainability Disclosure Guidance initiative [43]. According to the Johannesburg Stock Exchange [43], the Sustainability Disclosure Guidance initiative was launched “to help companies navigate the landscape of reporting standards without being onerous, and to provide explicitly for the South African context”. The reports emanating from the Sustainability Disclosure Guidance initiative record company performance measures including OHS performance [35], a departure point for this current study. In addition to annual reports, some companies also reported ESG performance data in standalone Microsoft Excel data books as supplementary information to annual integrated or sustainability or ESG reports. The industrial classification of all companies listed in the JSE based on the Industry Classification Benchmark (ICB) method is shown in Figure 1. The ICB method aggregated the companies into nine sectors. The financial companies (96; 35%) constituted the highest number of listed companies, whereas the oil and gas (3; 1.1%) had the smallest number of listed companies. The basic materials and industrial industries both had the same number of companies, at 16.1%, listed in the JSE.

Table 1. Industry categories of companies included in the study.

Industry Category	Total Listed Companies (274 Companies)	Number and Percentage of Top 150-Companies Included in the Study
Basic materials	45	28 (9.9%)
Consumer goods	21	11 (4%)
Consumer services	38	25 (9.1%)
Financial	96	54 (19.7%)
Healthcare	7	4 (1.5%)
Industrial	44	16 (5.8%)
Oil and gas	3	1 (0.4%)
Technology	14	7 (2.6%)
Telecommunications	6	4 (1.5%)
Total	274	150 (54.5%)

shows the industrial breakdown of the 150 companies included in the study. The included companies were influenced by the market capitalisation as recorded on the cut-off date. The financial sector, with 54 companies, had the highest number of companies in the top 150 companies and corresponded with the economic cycle at the time of the study. According to the StatsSA quarterly labour survey [44], the included industry categories employ a large number of the workforce and have inherent OHS hazards. Currently, no utilities are listed on the JSE; structurally, utilities are managed by the state as the main shareholder.

2.1. Report Access, Data Extraction, Management and Analysis

The 2023 reports and data books were downloaded from each of the included companies’ web addresses. The reports and data books, published in Adobe Acrobat PDF and Microsoft Excel formats, respectively, were stored in a password-protected research folder labelled with each company name prior to analysis.

The reported OHS performance data in all the cited sources was similar, although the data books contained additional information such as calculation formulae, historic performance comparisons, etc. In some instances, integrated reports contained summarised data and narration, whereas sustainability and ESG reports contained extensive narration on the data. On this basis, sustainability and ESG reports and data workbooks were the primary information sources during data extraction and analysis. The integrated reports were then used to verify the accuracy of the data recorded in the sustainability and ESG reports.

Textual analysis was manually conducted in each of the reports and data books to extract the specific lagging indicators names reported. The boolean operators “health and safety”; “occupational health and safety”; “occupational health” and “occupational diseases” were used to electronically locate, identify and verify the indicators extracted manually from the reports. No variation in the manual and electronic data extraction was observed. The data extraction recorded the specific term(s) of the lagging indicators reported by each company. The lagging indicator terms were captured on a Microsoft Excel spreadsheet along with each company name. The terms were captured as they appeared on the source documents. The data collection and analysis strategy in Figure 2 was used to ensure dependability and confirmability of the entire research process.

2.2. Inclusion and Exclusion of Reports

In cases where the 2023 reports and data workbooks were unavailable, the company performance details were excluded from the final analysis. Where sustainability or ESG reports were not included or chosen as a reporting format by the companies, the annual integrated reports were the primary data sources during data extraction. Annual and sustainability or ESG reports that did not contain any lagging indicators following analysis were numerically counted for interpretation purposes (

Table 2. Sectoral distribution of OHS performance indicators.

Sector	Number of Companies Reporting (Total in Study)	Percentage (%) of Companies Reporting	Total Number of Lagging Indicators Reported
Basic materials	26 (28)	17%	37
Industrial	13 (16)	8,7%	21
Consumer goods	9 (11)	6%	18
Healthcare	4 (7)	2,7%	24
Consumer services	11 (25)	7,3%	18
Telecommunications	4 (4)	2,7%	11
Financial	18 (54)	12%	18
Technology	2 (7)	1,3%	2
Total	87 (150)	58%	-

and

Table 3. Sectoral reporting formats.

Sector	Report Type
	Annual Report	Integrated or Annual Integrated Report	ESG Reports	Sustainability Reports	Data Books
Basic materials	4	19	4	13	6
Industrial	0	13	2	3	0
Consumer goods	3	6	0	3	0
Consumer services	0	10	1	5	0
Financial	2	14	4	4	0
Healthcare	0	4	1	2	2
Technology	0	1	0	0	0
Telecommunications	0	4	0	2	0
Total	9	71	12	32	8

).

Inclusion and Exclusion of Leading Indicators

The measurement of OHS performance at the corporate level was anchored in the reporting of lagging indicators rather than leading indicators [45]. Similar to lagging indicators, there was also a lack of a commonly adopted leading indicators across companies to enhance benchmarking. Leading indicators were also less informative at corporate level in instances where specific process activities were performed [45]. On this basis, leading indicators were excluded in this study.

The exclusion of leading indicators in this study may have introduced selection and desirability biases. Notwithstanding these possible biases, the sectoral variation and spread of the case companies reduced the likelihood of the quality of this study being compromised.

3. Results

3.1. Overview of OHS Performance Reporting

Table 2 shows the sectoral category, number and percentage of companies reporting performance indicators and the total number of lagging indicators per sector. In total, 87 (58%) of the case companies reported lagging indicators, whereas 63 (42%) companies did not report them. Companies within the basic materials sector reported 37 different lagging indicators compared to two indicators reported in the technology sector. This reflects the regulatory pressure under which these companies operate, where OHS safety targets have been set [41]. Eight of the basic materials companies included in this study were affiliated to the ICMM. The lagging indicators adopted by the ICMM-affiliated companies was intended for conformance with the benchmarking requirements amongst sister companies across the globe [18]. The basic materials, industrial, consumer goods and consumer services sectors reported the most lagging indicators, reflecting the hazardous nature of work in these sectors. The telecommunications and technology sectors had the fewest companies that reported lagging indictaors, reflecting the low hazard profile of this type of work [46]. The basic materials sector, in particular, has been placed under greater public pressure to disclose OHS performance due to the number of fatalities, which often attracts media attention [32]. The specific lagging indicators per reporting company are shown in Supplementary File S1.

In total, 132 documents (annual reports n = 9, integrated or integrated annual reports n = 71, sustainability reports n = 32, ESG reports n = 12 and data workbooks n = 8) were evaluated (Table 3). The majority of companies (71) adopted the use of integrated/annual integrated and sustainability report formats compared to annual reports and ESG report formats. The reporting of data books as a supplement to ESG or sustainability reports was only adopted by eight companies from the basic materials (6) and healthcare sectors (2).

Figure 3 shows the referenced reporting frameworks adapated by the companies. The uptake of the JSE Sustainability Disclosure Guidance since its publication in June 2022 was adopted by only 27 of 87 companies that reported OHS performance. The GRI reporting framework was the most commonly applied. These sustainability reporting frameworks are voluntary and are applied by companies as guidance rather than as mandatory, including by the ICMM-affiliated basic materials companies. In some instances, the case companies adopted or combined more than one reporting framework related to OHS performance.

3.2. Overview of Reported Lagging Indicators

A total of 59 different lagging indicators were reported by the case companies (Figure 4). Fatality counts were the most reported lagging indicator (64), followed by OD counts (23), medical treatment cases (MTCs) (13), lost time injuries (LTI) (13), and first aid cases (FACs) (10). The lost time injury frequency rate (LTIFR) (41) was the most commonly used rate followed by the total recordable injury frequency rate (TRIFR) (17) and the fatal injury frequency rate (FIFR) (14). Comparably, more companies reported nominal lagging indicators compared to rates.

The rate-based lagging indicators were calculated using different base denominated hours, reflecting an operational environment without a standardised worldwide calculation formula. The reporting and selection of adopted lagging indicators by basic materials companies was tied to ICMM [7] industry affiliation, an industry body that prescribes reporting guidelines for subscribed companies.

3.3. Sectoral Overview of Lagging Indicators Reported

Fatality counts were the most commonly reported lagging indicator across all sectors, with 10 industrial companies, 9 financial companies and 8 companies from both the basic materials and consumer goods sectors reporting them (Figure 5). A total of 40 of 87 companies reported fatality counts. The LTIFR was the second most common lagging indicator reported across all sectors.

There remain inter- and intra-sectoral variation in the adoption and reporting of lagging indicators (

Table 4. ICMM-affiliated basic materials companies’ lagging indicators.

Lagging Indicator	BHP Group Limited	Glencore plc	Anglo American plc	Anglo American Platinum Ltd.	South32 Limited	Anglogold Ashanti	Harmony Gold Mining Company	Sibanye Stillwater Limited	African Rainbow Minerals
Lost time injury frequency rate (LTIFR)	-	✓	-	✓	✓	✓	✓	✓	✓
Total recordable injury frequency rate (TRIFR)	✓	✓	✓	-	-	✓	-	✓	-
Total recordable injuries/recordable injuries/cases	-	-	-	-	-	✓	-	✓	✓
Reportable injury frequency rate (RIFR)	-	-	-	-	-	-	-	-	-
Reportable injuries/injury on duty (IOD)/reportable incidents	✓	-	-	✓	-	-	-	-	✓
Occupational disease or occupational illness incidence/rate	✓	-	-	-	-	-	-	-	-
Occupational disease (OD) count	✓	✓	✓	✓	-	-	✓	-	✓
Fatalities/fatal injuries	✓	✓	✓	✓	-	✓	✓	✓	✓
Fatality frequency rate (FIFR)	-	✓	-	-	-	-	-	✓	-
Medical treatment case (MTC)	-	-	-	-	-	✓	-	-	-
First aid case (FAC)	-	-	-	-	-	-	-	-	-
Lost time injuries (LTI)/lost time incidents	-	-	-	✓	-	✓	-	✓	✓
Recordable injuries	-	-	-	-	-	-	-	-	-
Serious injury frequency rate (SIFR)	-	-	-	-	-	-	-	✓	-
High potential injury frequency	✓	-	-	✓	-	✓	-	-	-
Total recordable injury frequency (TRIF) or (TIFR)	✓	-	-	-	-	-	-	✓	-
High consequence injury frequency	✓	-	-	-	-	-	-	-	-
Number of recordable work-related injuries	✓	-	-	-	-	-	-	-	-
Number of high consequence work-related injuries	✓	-	-	-	-	-	-	-	-
High potential injuries (counts)	✓	-	-	-	-	✓	-	-	-
Occupational exposure reduction trend over time	✓	-	-	-	-	-	-	-	-
Severity rate	-	-	-	-	-	-	-	-	✓
Total recordable fatalities	-	-	-	-	-	-	-	-	-
Life-altering injuries	-	-	-	-	-	-	-	-	-
Total recordable cases	-	-	-	-	-	-	-	-	-
Fatal injury frequency rate	-	-	-	-	-	✓	✓	✓	-
Medical treatment case frequency rate	-	-	-	-	-	✓	-	-	-
Serious injuries/number of severe occupational injuries	-	-	-	-	-	-	-	✓	-
Medically treated injury frequency rate (MTIFR)	-	-	-	-	-	-	-	✓	-

✓ Reported.

,

Table 5. Indutrial sector’s lagging indicators.

Lagging Indicator	Bidvest Group	Wilson Bayly Holmes-Ovcon Limited	Afrimat Limited	Super Group Limited	Reunert Limited	Grindrod Limited	PPC Limited	Raubex Group Limited	KAP Limited	CA Sales Holdings Limited	Hudaco Industries Limited	Nampak Limited	Bell Equipment Limited
Lost time injury frequency rate (LTIFR)	✓	✓	✓	-	-	✓	✓	✓	-	-	✓	✓	✓
Total recordable injury frequency rate (TRIFR)	-	-	✓	-	-	-	-	-	-	-	-	-	-
Total recordable injuries/recordable injuries/cases	-	-	-	-	-	-	-	-	-	-	-	-	✓
Reportable injury frequency rate (RIFR)	-	-	-	-	-	-	-	✓	-	-	-	-	-
Reportable injuries/injury on duty/reportable incidents	-	✓	-	-	-	-	-	-	-	-	-	✓	-
Occupational disease count	-	-	-	-	✓	-	✓	-	✓	-	-	-	-
Fatalities/fatal injuries	✓	✓	✓	✓	✓	✓	✓	✓	-	✓	-	✓	-
Fatality frequency rate/FIFR	-	-	-	-	-	-	✓	✓	-	-	-	-	-
Medical treatment case (MTC)	-	-	✓	-	-	-	-	-	-	-	-	-	-
First aid case (FAC)	-	-	✓	-	-	✓	✓	-	-	-	-	-	-
Lost time injuries/incidents (LTI)	-	✓	-	-	-	✓	✓	-	✓	-	✓	-	-
Injuries	-	-	-	-	✓	-	✓	-	-	✓	-	-	-
High potential injuries (counts)	-	-	✓	-	-	-	-	-	-	-	-	-	-
Lost workday cases/days lost to WR accidents or illness/days lost due to LTI	-	-	-	-	✓	-	-	-	-	✓	-	-	-
Accidents	-	-	-	✓	-	-	-	-	-	-	-	-	-
Recordable case rate	-	✓	-	-	-	-	-	-	-	-	-	-	-
Compensation for occupational injuries and diseases (no lost time)	-	-	-	-	-	-	-	-	✓	-	-	-	-
Total compensation for occupational injuries and diseases	-	-	-	-	-	-	-	-	✓	-	-	-	-
Lost time injury severity rate	-	-	-	-	-	-	-	-	-	-	✓	-	-
All incidence frequency rate	-	-	-	-	-	-	-	-	-	-	✓	-	-
Production injury frequency rate (PIFR)	-	-	-	-	-	-	-	-	-	-	-	-	✓

✓ Reported.

and

Table 6. Consumer goods sector’s lagging indicators.

Lagging Indicator	Anheuser-Busch Inbev	Compagnie Fin Richemont	British American Tobacco	Tiger Brands Limited	AVI Limited	Oceana Group Limited	RCL Foods Limited	Premier Group Limited	Astral Foods Limited
Total recordable case frequency rate (TRCFR)	-	-	-	✓	-	-	-	-	-
Lost time injury frequency rate (LTIFR)	-	-	-	✓	-	✓	✓	-	✓
Total recordable injury frequency rate (TRIFR)	-	-	✓	-	-	-	✓	-	-
Total recordable injuries/recordable injuries/cases	✓	-	-	-	-	✓	-	-	-
Occupational disease or occupational illness incidence/rate	-	✓	-	-	-	-	-	-	-
Occupational disease count	-	✓	-	-	-	-	✓	-	-
Fatalities/fatal injuries	✓	✓	✓	✓	-	✓	✓	✓	✓
Fatality frequency rate/FIFR	-	-	-	✓	-	-	✓	-	-
Medical treatment case (MTC)	-	-	-	✓	-	-	✓	✓	✓
First aid case	-	-	-	✓	-	-	✓	-	✓
Lost time injuries (LTI)/incidents	✓	-	✓	-	-	-	-	✓	✓
Recordable injuries	-	-	-	-	-	-	✓	✓	✓
Serious injury frequency rate	-	-	✓	-	-	-	-	-	-
Number of recordable work-related injuries	-	✓	-	-	-	-	-	-	-
lost time incidence rate	-	-	✓	-	-	-	-	-	-
Disabling injury cases	-	-	-	-	✓	-	-	-	-
High consequence cases	-	✓	-	-	-	-	-	-	-
Disabling injury frequency rate	-	-	-	-	✓	-	-	✓	-

✓ Reported.

). The ICMM-affiliated basic materials sector companies reported 29 different lagging indicators compared to 21 and 19 from the industrial and the consumer goods sectors, respectively. Company or industry affiliation had limited internal influence on the adoption and reporting of lagging indicators.

3.4. Single Coding and Risk of Bias

The screening and evaluation of the reports and data books was conducted by a single reviewer, the Primary Investigator, OR. Single-reviewer screening was chosen in view of the Primary Investigator’s expertise on the subject matter, the well-defined literature search and the inclusion and exclusion criteria [47,48]. Double or triple review of the reports and data books for each company, as applicable, verified the content from each corresponding document minimising the omission of applicable information.

4. Discussion

This study evaluated annual reports and data books of the top 150 JSE-listed companies to determine, characterise and compare reported lagging indicators. The reporting of lagging indicators and adopted metrics varies between companies and includes nominal counts and rates. Companies in the basic materials and industrial sectors extensively reported varying set of lagging indicators compared to those in other sectors such as the technology and financial sectors. Any of the reported metrics indicate failures in certain aspects of the companies’ OHSMSs [42] and require accurate analysis for successful prevention [16]. However, such reporting practices reflect disclosure choices and regulatory/industry norms and not necessarily actual safety performance.

4.1. Overview of Performance Reporting

Similarly to Indonesia, the reporting of OHS disclosures in South Africa is voluntary in view of the absence of regulatory prescriptions [49]. The reporting frameworks chosen by each company was influenced by industry affiliations and guidelines outlined in the voluntarily adopted sustainability frameworks. Mining companies affiliated with the ICMM specifically reported on a set of lagging metrics on an annual basis [7]. Differences in the selection of reporting frameworks inadvertently resulted in the adoption of variable lagging indicators across companies and sectors. The JSE Sustainability Disclosure Guideline, when fully adopted by all companies, should help minimise the observed variability in reporting formats and types of lagging indicators adopted. This is in line with an observation made by the Center for Safety & Health Sustainability on a study conducted by reviewing reports from the Corporate Knights’ Global 100 most sustainable companies in the world during 2012 [50].

Comparably, there were more companies in the basic materials, industrial and consumer goods sectors that reported lagging indicators than those in the financial, consumer services and technology sectors. This finding is in line with previous studies that found that industry category [51,52] and OHSMS certification play a major role in company OHS disclosures [53]. The basic materials, industrial and consumer goods sectors operate hazardous processes that expose employees to various occupational hazards. The comparably high disclosures within the basic materials sector, specifically, is a response by companies to manage societal legitimacy following incidences that often resulted in fatalities [32].

The variance in the reporting is also linked to the each company’s determination of materiality and the subsequent choice of material topics [20]. From a legitimacy theory perspective, the choice of reported topics is linked to the need to protect reputation [23] which explains the abstract nature of disclosed information [20]. From a stakeholder theory perspective, the detailed nature of disclosed material and issues are linked to stakeholder pressure [20] and the need for greater transparency. Furthermore the disclosures reflect manager choices on the format and scale of the disclosures targeting specific influential stakeholders [21,46]. Some companies achieve legitimacy goals by limiting the detail of disclosures in reports [54].

4.2. Overview of Performance Indicators

The observed variance in choice of indicators reported by the case companies reflects the current policy uncertainty in South Africa regarding the available means for OHS performance measurement [55]. The variability in the indicators was also observed in a 2012 study conducted by the Center for Safety & Health Sustainability [50]. The variance in the adopted performance metrics obfuscate the true status of health and safety at work as benchmarking is rendered cumbersome. Some of the indicators reported by the same company may be interdependent [56], highlighting the need for the adoption of streamlined high-level sets of indicators [8]. The lack of synthesised performance metrics also complicates regulatory oversight [8].

The varied indicators attest to an operational environment worldwide in which the “ideal” indicator has yet to be identified [5,57] and adds to the protracted contestation and debate concerning the theoretical foundation of OHSMS performance measurement [5,42]. These indicators should be correctly selected for relevance to the operational conditions they are applied to increase reliability and produce comparable data [42].

The variance in the reporting metrics justifies the JSE’s launch of the voluntary Sustainability Disclosure Guidance in 2022 [35], which recognised the need for offering guidance to companies on performance reporting from a South African perspective. According to the JSE [35], the voluntary Sustainability Disclosure Guidance has been designed to align with both international standards and the local context. Once finalised, this initiative is likely to result in the improvement of reporting and industry benchmarking.

The reported lagging indicators should be cautiously interpreted and should not be construed to measure absolute safety and risk. As an example, Safework Australia [42] cautions against the use of the LTI to indicate prevailing workplace safety due to its poor correlation when used for evaluating OHS failures and measuring the success of OHS controls [42] and its proneness to manipulation [42,57] and to assigning similar weights to injuries with varying consequences [57]. Companies may also, in general, be inclined to manage the indicators rather than performance [42].

4.3. Implications and Recommendations

The variance in the adoption of lagging indicators highlights the need for standardisation of disclosure about performance indicators for comparability and oversight [16]. Despite the contestation about their usefulness in industry, lagging indicators provide information on the effectiveness of past actions taken to control risks and can also be meaningfully used to understand hazards [14]. The adopted lagging indicators should be quantifiable, permit statistical inference procedures and be valid or representative of what is to be measured [57,58]. Additionally, the lagging indicators should also be sensitive to incident frequency in order to facilitate trending. In this regard, indicators using numeric or absolute counts of injuries or fatalities or ODs are ideal in that they inform the urgency of the need to implement exposure control measures [58].

Another performance philosophy to be considered within a South African context is the severity framework, in which injuries are classified based on impacts to employee life. The consideration of the severity framework is in line with advances in knowledge on the subject matter which informs the review and reassessment of the validity and reliability of used metrics. Within this context, a shift from reliance on the LTI and LTIFR towards the use of indicators such as the TRIFR has been proposed in countries like Australia [42].

From a policy guidance perspective, South Africa regulators should investigate the feasibility of performance standards listed by the American Industrial Hygiene Associations’ Center of Safety and Health Sustainability [59].

4.4. Limitations

This study had limitations. The list of the top 150 JSE-listed companies changes depending on market conditions and may skew the sectoral concentration of the companies included. The focus of this current study on the top 150 JSE-listed companies by market capitalisation limits the generalisability of the results to only highly capitalised companies. Data from small and medium enterprises which were also listed on the Bourse, as well as those listed in alternative exchanges, were excluded.

The study relied on various reports and available data books as secondary OHS data sources rather than primary data. There currently exist different definitions and calculation formulae of recorded lagging indicators, which influences the context in which they are applied and reported. Further studies are required to investigate the conformance of company reporting to standards such as the GRI and JSE Sustainability Disclosure Guidance reporting frameworks, etc., including the calculation formulas used for computing the reported indicators.

5. Conclusions

This qualitative study revealed variance in both the reporting frameworks of sustainability measures and lagging indicators. Companies in the industrial, consumer goods, consumer services and basic material sectors are more likely to report OHS performance than those in other sectors. Across all included companies, there remains variation in the number, type and scale of selected and adopted lagging metrics. The variable reporting of lagging indicators is a result of a lack of standardised performance metrics in South Africa that would allow for inter- and intra-sectoral benchmarking. The observed variation in metrics across sectors emphasises the need for harmonised indicators to measure and report OHS performance in South Africa.