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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities Summary The U.S. Army’s Chemical Materials Agency (CMA) is responsible for the destruction of the nation’s chemical agent and munitions stockpile, except at two sites that fall under a separate Department of Defense program.1 To meet this goal, CMA has built and operated incineration-based chemical agent disposal facilities (CDFs) on Johnston Atoll, in the Pacific Ocean; near Anniston, Alabama; Pine Bluff, Arkansas; Tooele, Utah; and Umatilla, Oregon. It has also built and operated neutralization-based CDFs near Aberdeen, Maryland, and Newport, Indiana. The CDFs on Johnston Atoll and Aberdeen have been closed, and the CDF near Newport is undergoing closure. The CDFs near Anniston, Pine Bluff, Tooele, and Umatilla are still in operation. When Congress mandated the destruction of the chemical weapons stockpile, it specified that destruction operations must be executed with maximum protection for the workers, the public, and the environment. In the initial years of disposal operations, the National Research Council’s longtime Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program, in its reports, repeatedly encouraged the Army and its contractors to pay attention to safety and to engage in continuous improvement.2 The Army and its contractors have responded to this encouragement, and the operating CDFs enjoy exemplary safety records at this time. Table 2-1 gives site injury rates as of October 31, 2008, and Tables 2-2 and 2-3 provide environmental statistics for the sites. Even so, the Army and the CDFs are desirous of further improving safety and environmental performance and have asked the National Research Council to review the safety and environmental metrics used by the CDFs. Specifically, the ad hoc Committee on Evaluation of the Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities was established to carry out the following tasks: Review and evaluate existing safety and environmental metrics employed at CMA facilities, Examine commercial and industrial operations for potentially applicable safety and environmental metrics, and Assess new initiatives at national organizations (i.e., National Safety Council, Occupational Safety and Health Administration, etc.) that could be used by CMA. As part of their ongoing effort to improve worker safety and environmental compliance, the CDFs employ a variety of metrics to measure performance and guide improvement efforts. Table 3-1 gives the categories of safety metrics used at the CDFs. The metrics include both leading indicators, which are forward looking and seek to identify problems before they occur, and lagging indicators, which are retrospective and lead 1 The stockpiles at the Blue Grass Army Depot, in Kentucky, and the Pueblo Chemical Depot, in Colorado, fall under the Assembled Chemical Weapons Alternative Program. 2 In 2006, the Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program was replaced with the current Committee on Chemical Stockpile Demilitarization.
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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities to corrective action after injuries or incidents have occurred. This committee reviewed the status of safety and environmental programs and performance and the metrics used at the Anniston, Newport, Pine Bluff, Tooele, and Umatilla CDFs. The committee noted that all CDFs engage in extensive data gathering, but the specific metrics derived from the data varied considerably from one facility to the other. This is not surprising, since each CDF has its own destruction mission, geography, and culture. The committee gathered information on metrics and assessed new initiatives used by other government organizations, industry as a whole, and professional organizations, with an eye toward identifying metrics that might be useful to the CDFs. The government organizations surveyed include the Department of the Army (other than the CMA) and the Federal Aviation Administration. The private entities surveyed include the Center for Chemical Process Safety of the American Institute of Chemical Engineers (AIChE), Corning, Dow Chemical, Motorola, and Praxair. Many of the metrics employed by these organizations are detailed in Appendix B but not discussed in the body of the report. The committee believed that discussing the results of its fact finding and assessment would be more appropriate than recommending specific metrics. The terminology used in this report is defined in the glossary that makes up Appendix A. While the definitions in the glossary may not necessarily conform to those of the CDFs or other organizations, the committee believes that they will afford the reader a clear idea of the meanings intended here. For the reader’s convenience, the committee’s findings and recommendations, located in Chapter 5, are presented here as well. Finding. Safety and environmental performance at the operating Chemical Materials Agency chemical agent disposal facilities has continuously improved and is currently significantly better than the national average industry as measured by lost workday cases and the recordable injury rate. Three of the five facilities are compliant with third-party accreditation requirements. All but one of the facilities have been certified with the Star designation by the Voluntary Protection Programs of OSHA and all conform to the International Organization for Standardization (ISO) 14001 environmental requirements. Recommendation 1. The chemical agent disposal facilities should continue the process of continuous improvement to achieve levels of safety and environmental performance equivalent to those achieved by comparable industries. Third-party certifications should be continued and encouraged. All chemical agent disposal facilities should comply or obtain the Star designation of the OSHA Voluntary Protection Programs, and all should continue to comply with the most current ISO environmental management standards. Finding. The terminology used to describe various metrics and related activities is not consistent across the chemical agent disposal facilities or within the Chemical Materials Agency. This makes it difficult to compare the sites in a meaningful way or to accurately analyze programwide data. Recommendation 2. The Chemical Materials Agency should require the development of a system of clear and consistent definitions that can be applied across all chemical agent disposal facilities. Although each facility should have the flexibility to apply safety and environmental approaches that meet any unique needs, a particular metric should be defined consistently to allow for direct comparisons among the facilities. Finding. The chemical agent disposal facilities collect extensive data on injuries, and most engage in some injury analysis. However, no facility takes full advantage of the data to create additional and potentially more sensitive metrics. The focus has been on lost workday cases and the recordable injury rate. Other possible metrics, such as medical treatment cases and first aid case rates, are not universally employed or communicated. The analyses simply list outcomes and incidental variables (e.g., department and day of week) and as such are not very useful metrics. Further, they fail to include some essential information such as the task being performed when the injury occurred and the location within the facility where it took place. Finding. In addition to collecting data on injuries, all chemical agent disposal facilities collect extensive incident data, but there does not appear to be an incident investigation system that would enable the sites to analyze the data and extract from them indicators for preventive action. Insofar as they are reported, “metrics” are simple lists.
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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities Finding. The chemical agent disposal facilities have many observation programs in place, but as with data on incidents, no metrics appear to be developed from them. Observations derived from the various programs are not combined or analyzed and, again, many of the reported metrics are simply lists. Recommendation 3. The chemical agent disposal facilities should take full advantage of injury data to develop, employ, and communicate additional related metrics. All of the facilities should engage in injury analysis, and the analyses should include all relevant data and be structured so that meaningful indicators can be derived from them. Recommendation 4. Incident data can be leading indicators for injuries, although they are also lagging indicators for conditions and behaviors that could result in injuries. The chemical agent disposal facilities should develop metrics from incident data—one such might be an unsafe acts index that could support the analysis of trends and point out a need for preventive action. Recommendation 5. Chemical agent disposal facilities should stop reporting on and communicating data that are simple enumerations unless there is a clear understanding of the context for the data or a demonstrated connection to the continuous improvement of safety and/or environmental performance. For example, reporting absolute numbers of injuries by department conveys no information that can be translated into action, because the data have not been transformed into a metric that allows true department-to-department comparisons (i.e., departmental injury rates). Finally, the facilities should cease collecting data that are not used to develop metrics or meaningful indicators. Finding. Key environmental metrics used by the chemical agent disposal facilities are based on the formal written notification that an applicable statutory or regulatory requirement promulgated by the Environmental Protection Agency or other authorized federal, state, interstate, regional, or local environmental regulatory agency has been violated. These metrics are lagging indicators. Recommendation 6. The chemical agent disposal facilities should develop a broader set of leading environmental metrics. For example, incident reporting and analysis and observation programs could be extended to the environment area. Metrics could be developed that resemble leading safety metrics and could include the following: Projected use of energy, materials, and water; Time to correct violation and devise preventive action; Content of environmental training courses and frequency with which they are offered; and Observations of small spills or improper disposal of chemicals. In addition, it is recommended that all available data be examined for patterns that might turn out to be useful leading indicators. Finding. Metrics used at the chemical agent disposal facilities are mainly lagging ones that record relatively rare, undesirable outcomes such as recordable injuries. This practice does not yield good information on the real-time status of important leading variables such as physical conditions and work practices. As a result, workers and managers do not receive timely feedback on how well they are doing in maintaining a work environment that is free of conditions or behaviors that increase the risk of injury. Chapter 4 of this report provides examples of outstanding safety programs in the private sector and government. These programs focus on positive—that is to say, desirable—working conditions and practices, leading indicator variables, and the ongoing measurement of positive process variables. Recommendation 7. Chemical agent disposal facilities should establish metrics that directly measure safety program effectiveness in near real time. These initiatives to establish metrics should focus on identifying leading variables that (1) set high standards for safe working conditions and (2) are a sign of a positive safety culture—for instance, 100 percent compliance in wearing personnel protective equipment; 100 percent compliance with correct use of lockout and tag out procedures; and the documented participation of management in the safety and environmental programs. Recommendation 8. The chemical agent disposal facilities should conduct their own review of the best practices of the entities discussed in Chapter 4 to determine whether there are practices and metrics that would complement their own metrics and, in turn, benefit their own safety and environmental programs.
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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities Finding. Chemical agent disposal facility processing operations generally consist of routine, repetitive, and much-practiced procedures. Safety will continue to be a key consideration as site activities transition to decommissioning, demolition, and handling and shipping of secondary wastes. Closure operations involve new and much more varied procedures. The award fee criteria may have different targets for closure because the current metrics and targets may not be appropriate for the closure phase. Recommendation 9. The Chemical Materials Agency should establish a framework for developing metrics for the decommissioning and demolition of chemical agent disposal facilities. This framework should be used for all the facilities but on a site-specific basis. The framework should include safety and environmental metrics and targets, as well as a plan for communicating information to workers and the public. The metrics in use for operational processes should be reviewed for appropriateness and target levels. Additional metrics should be identified from the best practices for decommissioning and decontaminating industrial facilities and for the Environmental Protection Agency’s Superfund program. The following findings and recommendations might be useful for the CDFs to consider. The committee does not wish to prescribe these for all the CDFs because the degree to which they would be useful will vary based on each facility’s safety and environmental culture, regulatory environment, and stage of agent processing. The committee believes that the management of each CDF can best weigh the potential utility of these recommendations. Finding. Incidents are not classified and no metrics are derived from incident data. Recommendation 10. Chemical agent disposal facilities should consider classifying incidents (one such class might be “incident with serious potential”) to enable the development of additional metrics and help with prioritizing incident investigations. Finding. None of the chemical agent disposal facilities develop or employ process safety metrics. Recommendation 11. The chemical agent disposal facilities should consider developing and implementing leading and lagging metrics for process safety. They should consider using the American Institute of Chemical Engineers’ Center for Chemical Process Safety document entitled Process Safety Leading and Lagging Metrics to guide implementation of process safety metrics.