Process Safety Performance An EPSC view on the use of lagging indicators in reporting process safety performance June 20

1. Process Safety Performance An EPSC view on the use of lagging indicators in reporting process safety performance June 2010

2. Process Safety Performance EPSC encourages the use of performance indicators in process safety amongst member and non-member companies. The use of appropriate metrics serving both internal company and industry-wide needs will stimulate learning, identify opportunities for improvements and facilitate communication on achievements. Process Safety is distinct to personal safety. Traditional safety performance indicators such as ‘Lost Time Injuries’ or ‘Total Recordable Injuries’ do not give sufficient insight in process safety performance. When over-emphasized these might even distract attention away from managing process safety adequately.

3. Process Safety Performance Reporting In 2008 in an EPSC position paper, the problems of learning from shared incident data were brought to the attention of CEFIC. Lagging indicator definitions varied, making direct comparisons between shared company performance data difficult. The Previous best approaches for performance reporting were accelerated by investigations such as The Baker Panel report... Company-internal reporting systems for incidents External sharing and reporting of incidents Reporting of process safety incidents under RC (US, 1995) OECD “Guidance on Safety Performance Indicators”(2003/2008) EPSC report “Leading Indicators for Process Safety” (2004) European legal framework (Seveso, MARS-database) …and clearly placed ‘process safety’ (again) on the agenda.

4. Previous Best Approaches For Indicators • Academic discussions in safety journals • Shared lessons from other companies • Guidance from agencies and industry bodies

5. Responsible Care® and Lagging Indicators The principles of Responsible Care® require continual effort in learning and improvement, and industry organizations are developing ways to communicate on performance and share information. EPSC values efforts from organizations like CCPS, ACC and CEFIC in establishing common ground in reporting on process safety performance through the development of lagging indicators on process safety. EPSC considers the internal company reporting on process safety incidents a crucial condition for achieving continuous improvements. Work on lagging process safety indicators supports this reporting.

6. Lagging process safety performance indicators Developments in the USA: CCPS developed an approach for lagging and leading indicators for process safety (Guidelines for Process Safety Metrics) The ACC adopted the approach developed by the CCPS. API used this as a starting point and developed an API-standard (API- RP754). Further referred to as ‘UN-DG based approach’. Developments in Europe: EPSC installed a working party for sharing information, comparing company approaches and developing joint vision. The CEFIC discussed an own approach and requested EPSC technical advice on this. No recommended standard in Europe (yet).

7. Approaches(see Annex for more detail) The ideas for lagging process safety performance indicators developed by CEFIC and the approach developed in the US by CCPS have a lot of similarity and use the concept of ‘Process Safety Incidents’. Both define so-called ‘process safety incidents’ based on releases of substances above a certain threshold or when certain consequences occur due to contact with released substances (e.g. fire, explosion, lost-time injures, etc. Both follow a tiered approach. On the definition of release thresholds there are crucial differences. In the API standard the classification based on UN-DG is used (further referred to as “UN-DG based approach”), in the CEFIC proposals GHS is used (“GHS-based approach”).

8. EPSC Working Group – A Comparison of MethodsQualitative and Quantitative results EPSC has member companies in favor of either a UN-DG based or a GHS-based approach. The pros and cons were extensively discussed and several attempts to align on one global metrics approach were made. Such alignment was not found. Starting in 2009 it was decided to run a comparison study of the level of incident reporting which is offered by two reporting systems, that of GHS-based and UN-DG based. Three companies provided historical incident data as input to GHS-based and UN-DG based reporting systems. This provided a sample of 221 incidents that were classified using the two reporting systems. The objective of the exercise was to allow EPSC members to make informed choices regarding the potential to report using API-754 and to determine whether more efforts to compare the approaches has added value.

9. A Comparison of Methods Qualitative and Quantitative results Differences in the systems for handling location of release or activity causing release do not greatly influence the results. Different classification systems for chemicals are in broad agreement on hazard level of substances. Duration of release does not greatly influence the result. GHS and API-754 are qualitatively similar. For similar data sets, GHS produces approx. 4 times as many PSI reports as API-754 produces Tier 1 reports. GHS produces approx. 2 times as many PSIs as API-754 Tier 1 and Tier 2 combined. Quantitative difference: The CEFIC GHS system defines more incidents as reportable.

10. Observations – Ease of use When the classifications are known (UNDG and GHS), or when the substance is in the PSI Evaluation tool (CCPS for UNDG or EU-lists for GHS) the thresholds are easily found. When not: classification according to UNDG requires some toxicity data, flash point, boiling point and sometimes volatility. Although already requiring specialist knowledge, this is still very simple compared to having to establish the GHS classification when it is not yet available. In practice missing GHS data were compensated by the use of present classification with hazard symbols. Releases of mixtures, intermediates and products are often easier to classify in the GHS based approach when the currentclassification with hazard symbols is used rather than a GHS classification. GHS classification for mixtures are often not (yet) available.

11. Observations - Incident reporting systems Companies will likely have to expand the scope of current internal reporting to record enough data to use either system fully. A tiered approach has benefits: different levels of reporting, different levels of scrutinizing data. API-754 Tier 1 alone does not provide enough incident data to run improvement programs and be able to demonstrate improvement. Internal to an organisation you want to get as many incidents reported as possible. Quality and accuracy of data collected has a strong influence on the number of results returned – good reporting habits are important. The set of substances used in a workplace influences the coverage of specific types of incidents.

12. Conclusions Not one system catches all hazardous events. Some incidents are reported only in GHS, other incidents are reported only in API-754 T1 and T2. From a technical perspective either GHS or API-754 T1+T2 will work. Tier 1 alone of API-754 returns too few reports and should not be used unless to complement a separate internal reporting system. With an extended dataset it is possible to extract reports according to both approaches at the cost of additional effort. Distinction between the two systems is primarily in quantity of reported data. DRAFT Results sub-group PSI/March 2010

13. The Future EPSC will work together with volunteering companies develop a tool to support using either one of the approaches for classifying process safety incidents. Real world use of both systems will reveal areas of potential improvement and may reveal opportunities to further harmonise the systems for unified global reporting. Whilst it is crucial that external reporting systems for the sake of transparency are carefully defined at their margins it is evident that increasing the definition for internal reporting results in decreasing returns – it would be better to focus on the promotion of such a system across the business and encourage the full and accurate workforce reporting of process safety incidents.

14. Annex Characteristics of UN-DG based approach Characteristics of GHS based approach N.B. Characteristics are presented as needed for the purpose of comparing the approaches and are as understood by the EPSC working party. They do not contain the full scope of definitions and guidance on either one of the approaches. For complete information on the approaches we refer to CCPS, API RP754 and CEFIC publications.

15. Characteristics UN-DG Based Approach Tier 1 represents lost time injury, fatality, event causing significant cost or with significant loss of hazardous material. Tier 2 is a less significant but potentially dangerous event. It uses the same definitions but with lower criteria. Tiers 3 and 4 represent deviations from ideal procedure in equipment and human activities.

16. Graded Scale of Events UN-DG Based Approach Large loss of primary containment (LOPC) event Small loss of primary containment event Challenges to the safety system Operating discipline & management system

17. Thresholds for Reporting Event as Tier 1UN-DG Based Approach

18. Inhalation toxicity and volatilityUN-DG based approach In the UN-DG based approach inhalation toxicity and volatility is taken into account in order to represent accurately the inherent human hazards of a toxic release.

19. A binary system, divides events into Process Safety Incidents (PSI) or not. Intended to be used alongside other reporting systems for internal use and to complement existing reporting systems. Based on Globally Harmonized System for Classification and Labeling of Chemicals. Characteristics of GHS-Based Approach

20. Schematic overview GHS-based Approach

21. Thresholds for Loss of Containment becoming a PSIGHS-Based Approach