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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 performance. 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 group). 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 performance. 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. Describe 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 metrics. 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 volatility.) 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 documentation. 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 overpressure) 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 metrics. 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 regulated) Describe any other information – type/cause/other data that is a N/A breakdown of the parameter Step 4 satisfied? (Yes/No) Yes Comments: 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 details. 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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