PROPOSED PS INDICATOR EVALUATION

Center for Chemical Process Safety (CCPS) “Process Safety Incident” (also used by API and ACC
as a Process Safety Incident metric)
STEP 1: Test for Relevance & Use                                                       Comments/Justification
How will this indicator improve or drive process safety                     The CCPS (API/ACC) “Process Safety Incident”
improvement? Is it meaningful?                                              (PSI) metric is a collection of all unintentional
                                                                            releases of chemical or energy from a
                                                                            petroleum or chemical process which exceed
                                                                            defined threshold quantities, or results in
                                                                            either a serious injury, fire, or explosion. An
                                                                            additional element of the CCPS Process
                                                                            Safety Metrics is a normalized “Process
                                                                            Safety Total Incident Rate” (PSTIR) metric
                                                                            which normalizes the count of incidents by
                                                                            the company man-hours and the “Process
                                                                            Safety Incident Severity Rate” (PSISR) metric
                                                                            which is a severity adjusted and man-hour
                                                                            normalized measurement of process safety
                                                                            As holistic metrics of all incidents which
                                                                            cause harm, or had the potential to cause
                                                                            harm, these metrics are excellent overall
                                                                            indicator of process safety performance for
                                                                            the entity that is collecting the metric (e.g.,
                                                                            by plant, by site, by company, or by industry
                                                                            Collection of these metrics and benchmarking
                                                                            of performance between companies and
                                                                            industry sectors should drive the same level
                                                                            of performance improvements that were
                                                                            achieved across industry in personal safety
                                                                            performance after the implementation of a
                                                                            common injury/illness metric.
Is this indicator applicable to different facilities and countries (e.g.,   This indicator should be applicable to all
refining, chemicals, pipelines, exploration and production,                 types of facilities inclusive of those not
PSM/major hazard facilities, unregulated facilities)? Which ones?           covered by PSM regulations.
Data quality - General ability to count or measure. Is the data          The injury and direct-cost measurement of
objective, can it be consistently reported by knowledgeable              damages from fires or explosions are easily
people?                                                                  identifiable and measured. The chemical
                                                                         release thresholds are defined in advance
                                                                         and are of sufficient quantity that it should
                                                                         be unmistakable whether a release of the
                                                                         chemical has indeed occurred. (In many
                                                                         countries, if the chemical release meets or
                                                                         exceeds the PSI threshold levels they would
                                                                         also meet external reporting thresholds
                                                                         under environmental or safety regulations.
                                                                         The most challenging aspect of this metric is
                                                                         to accurately measure the flowrate and
                                                                         amount released – especially for vapor
                                                                         releases, to determine if the released amount
                                                                         exceeded the reporting threshold.
Is there sufficient data to be statistically relevant? At which levels   The threshold quantities of the new CCPS
(industry, company, site)?                                               (API & ACC) metrics are lower than have been
                                                                         used statistically by ACC and API. Estimates
                                                                         by some companies have been that the
                                                                         number of reporting incidents will be
                                                                         approximately 2 to 3 times the number
                                                                         reported under the previous metrics
                                                                         (collected since the mid-1990s). There will
                                                                         certainly be sufficient data to compare
                                                                         performance or determine statistical shifts in
                                                                         performance at a industry, company, or site
                                                                         level. There may not be sufficient incidents
                                                                         to determine statistical shifts in performance
                                                                         at a plant unit level; however, the use of
                                                                         other company internal metrics, or “leading”
                                                                         metrics should be sufficient for determining
                                                                         which plant unit has improving or declining
What are potential the potential downsides (unintended                   Since the reporting thresholds of the new
consequences) of this indicator?                                         definitions are lower than historical
                                                                         thresholds, there will be a greater number of
                                                                         reported incidents. This could lead to a false
                                                                         impression by the public, media, or
                                                                         regulators that the performance has declined
                                                                         when statistics based upon the new metrics
                                                                         are first reported.
Would this indicator be considered Leading or Lagging indicator?         Lagging.
Can this indicator be consolidated with others to provide an        Yes, this metric is a holistic metric of
indicator for an entire pyramid tier?                               unintentional releases of chemicals or
                                                                    energy, including fires and explosions that
                                                                    exceed pre-defined thresholds. Therefore, it
                                                                    represents the entire upper portion of the
                                                                    incident pyramid. Stratification of incidents
                                                                    into higher and lower severity categories
                                                                    within the upper portion of the incident
                                                                    pyramid can be accomplished by application
                                                                    of the incident severity classification.
Step 1 satisfied? (Yes/No)                                          YES.
Comments: The CCPS Metric definitions (Count of Process Safety Incidents, Process Safety Total Incident Rate, and
Process Safety Incident Severity Rate) have been adopted as metrics by the American Chemistry Council, the
Canadian Chemical Producers Association, and a trade group in Latin America. API has adopted two of the three

STEP 2: PARAMETER DEFINITION                                        MEASUREMENT DETAILS
Define what is being measured:                                      Metric #1: Count of “Process Safety
                                                                    Incidents” (PSI)
                                                                    All unintentional releases of chemical or
                                                                    energy from a petroleum or chemical process
                                                                    which exceed defined threshold quantities, or
                                                                    results in either a serious injury, fire, or
                                                                    explosion. The injury threshold is a “lost-
                                                                    time” injury or an off-site injury resulting in
                                                                    hospitalization. The fire or explosion
                                                                    threshold is $25,000 of direct cost impact
                                                                    from the fire/explosion. The chemical
                                                                    release threshold is a series of seven
                                                                    threshold levels in proportion to the inherent
                                                                    toxic or flammability hazard of the chemical
                                                                    or mixture. The threshold values are defined
                                                                    on the basis of the United Nations Dangerous
                                                                    Goods classification system. (These
                                                                    definitions were selected over other
                                                                    potential rating systems due to the
                                                                    international applicability and the better
                                                                    differentiation of acute toxic inhalation
                                                                    hazards based upon both toxic properties and

                                                                    Those criteria are:
                                                                    "Process Safety incident" threshold quantity:
                                                                    TIH Hazard Zone A materials    5 kg (11 lbs.)
                                                                    TIH Hazard Zone B materials 25 kg (55 lbs.)
                                                                    TIH Hazard Zone C materials 100 kg (220 lbs.)
                                                                    TIH Hazard Zone D materials 200 kg (440 lbs.)
Define what is being measured:                            Other "Packing Group I"    500 kg (1100 lbs.)
                                                          materials & “Flammable Gases/Vapors”
                                                          Other "Packing Group II" 1000 kg (2200 lbs.)
                                                          materials & “Flammable Liquids”
                                                          Other "Packing Group III" 2000 kg (4400 lbs.)
                                                          materials & “Combustible Liquids” & Division
                                                          2.2 Nonflammable, Nontoxic Gases

                                                          Metric #2:
                                                           “Process Safety Total Incident Rate” (PSTIR)
                                                               Total PS incidents x 200,000     .
                                                          Total employee & contractor work hours

                                                          Metric #3
                                                          Process Safety Incident Severity Rate” (PSISR)
                                                          Total severity score (all PS incidents) x 200,000
                                                             Total employee & contractor work hours
                                                          In determining this metric, 1 point is assigned
                                                          for each Level 4 incident attribute, 3 points for
                                                          each Level 3 attribute, 9 points for each Level 2
                                                          attributes, and 27 points for each Level 1
                                                          attributes. Theoretically, a PSI could be
                                                          assigned a minimum of 1 point (i.e., the
                                                          incident meets the attributes of a Level 4
                                                          incident in only one category) or a maximum
                                                          of 108 points (i.e., the incident meets the
                                                          attributes of a Level 1 incident in each of the
                                                          four categories.
                                                          For more details, see CCPS web page

Describe limits/parameter/key rules (What is included)?   A number of other interpretations and
                                                          implementation guidelines are available in
                                                          the CCPS Metric documentation or API Metric
What is excluded?                                         Current CCPS/API/ACC definitions exclude
                                                          PSV discharges of vapors which meet the
                                                          design requirements of API RP 521.
                                                          Transportation related incidents, including
                                                          chemical releases which may occur from a
                                                          transportation device (truck/railcar) within
                                                          the plant if that device is not connected to
                                                          the process at the time of the incident.
Describe any other information – type/cause/other data that is a     A four-by-four matrix of different severity
breakdown of the parameter                                           criteria, i.e., four different levels of
                                                                     differentiation for the four categories:
                                                                          Safety/Human Health
                                                                          Fire or Explosion (including
                                                                          Potential chemical impact
                                                                          Community/environment impact
Step 2 satisfied? (Yes/No)                                       Yes
Comments: A comprehensive set of definitions has been developed, vetted, piloted, and published for these

STEP 3: Determine if KPI is for public use or internal guidance      Comments/Justification
Publicly Reported Indicator (Shall)                                  All of the above

Internal Use to Company / Site (Should)                              All of the above
Step 3 satisfied? (Yes/No)                                           Yes
Comments: These metrics were developed (and harmonized between the major US trade associations) specifically
for the purpose of use as an industry-wide process safety lagging metric. These metrics are useful for internal and
external metrics.

STEP 4: Reporting Format, Categorization & Frequency                 Measurement Details
Establish reporting format (pareto, bar graph, etc.)                 These metrics can be reported in a number of
                                                                     formats. For example, in tabular format, bar
                                                                     graphs, or line charts.
Establish reporting frequency (monthly, quarterly, annually,         Internal reporting – Monthly
other)                                                               External reporting – Quarterly or Annually
PARAMETER to be reported by:
   General Refining/petrochemical Industry --site, company,         This indicator is applicable to PSM covered
    industry, combination, or all                                    and non PSM covered facilities.
   By type (PSM regulated facility, Chemical, Refining, non
Describe any other information – type/cause/other data that is a     N/A
breakdown of the parameter
Step 4 satisfied? (Yes/No)                                           Yes

STEP 5: Detailed – Final Definition                                  Detailed Definition
Provide finalized definition of KPI                                  To detailed to include in this format. See
                                                                     CCPS or API metrics publications for full
                                                                     To detailed to include in this format. In
                                                                     excess of 50 FAQs were provided in the CCPS
Provide frequently asked questions and answers                       and API metrics publications.

STEP 6: Cumulative Test
What are the key critical few indicators that will drive process      All three of these metrics are important for
safety forward?                                                       improving or comparing performance.
                                                                      Within any given company, the count of
                                                                      Process Safety Incidents would probably be
                                                                      sufficient as a tracking metric of improving or
                                                                      declining performance since the man-hours
                                                                      are relatively stable. However, the trend of
                                                                      the severity adjusted metric (Process Safety
                                                                      Incident Severity Rate) will do an even better
                                                                      job internally since it will indicate to a
                                                                      company if the severity of incidents has
                                                                      increased or declined.
                                                                      For measuring and driving industry-wide
                                                                      process safety performance, all three metrics
                                                                      are very important to measure statistical
                                                                      shifts in performance (both frequency and
                                                                      severity of incidents)
What indicators should be considered as performance improves?         The threshold levels, as currently established,
                                                                      should allow these metric definitions to be
                                                                      useful for many years. But should industry
                                                                      improve to a point where these metrics are
                                                                      near zero – consideration should be given to
                                                                      lowering the thresholds or transitioning to a
                                                                      pure LOPC metric.
Test - KISS - Keep it simple
For public KPI's - General public, industry & regulators - Are they    Once the public and regulators become
understandable by target audience?                                    convinced that these metrics are being
                                                                      reported consistently and accurately, they
                                                                      will accept that these three metrics are valid
                                                                      indicators of industry’s performance trend.

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