Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities (2009)

Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

2 Summary of Current Safety and Environmental Metrics at Chemical Agent Disposal Facilities1 In this chapter,the collection, analysis, communica- 4. How the information is used to improve safety tion, and use of safety and environmental metrics are —for example, detailed analysis of recent injuries summarized, first at the level of the Chemical Materials to find opportunities for improvement or under- Agency (CMA) and then at the level of the chemical standing the root causes of regulatory noncompli- agent disposal facilities (CDFs), in alphabetical order. ance to modify change procedures; and These metrics are reviewed and evaluated in more detail 5. How the information is communicated to man- in Chapter 3. agement, safety professionals, the workforce, The term “safety metric” refers to a standard of contractors, the public, and other sites. measurement used to maintain an accident- and injury- free workplace, while “environmental metric” refers Metrics can also be characterized by whether they to a standard of measurement for chemical and han- are based on events that have already occurred, usually dling processes relating to public health and the called lagging indicators, or on measured precursors environment. to events, usually known as leading indicators. While Metrics are characterized by: lagging indicators give information of direct concern to management, the workforce, and the public, they can 1. What kinds of data are being collected—for only be used for improvement after the fact. In contrast, example, number of injuries and number of regu- leading indicators point the way to possible improve- latory noncompliances; ments in safety and environmental performance. 2. How the data are converted to metrics. This is typically done by dividing by a measure of chemical materials agency exposure—for example, number of injuries per 200,000 working hours or number of regulatory CMA is responsible for the safe storage and destruc- noncompliance occurrences per month; tion of most of the nation’s chemical weapons stock- 3. How this information is aggregated over depart- pile. It oversees the activities in the five CDFs that ments or over time—for example, injury rates by are covered in this report. The headquarters manage- department or by month or average annual rates ment team, as well as scientific, communications, and of regulatory noncompliance; support staff are based at the Edgewood Area of the Aberdeen Proving Ground in Maryland. Each CDF is government owned and contractor operated. While CMA is responsible for the destruction of Information gathering for this report ceased on October 31, the chemical weapons stockpile, its contractors are 2008. The most current information is available at http://www. cma.army.mil. responsible for ensuring that the congressional mandate  

SUMMARY OF Current Safety and Environmental Metrics  for safety is fulfilled. To encourage exemplary perfor- destruction is 2012. This, however, does not include the mance, CMA has established award fee criteria so its disposal of hazardous and secondary waste. contractors can be financially rewarded for safety and environmental performance over and above contract Safety and Environmental Performance and Metrics values. These criteria establish five categories in which performance will be measured and establish percent- Safety statistics for ANCDF and the four other sites age ranges for each. The performance categories are can be found in Table 2-1 and environmental statistics these: for them can be found in Tables 2-2 and 2-3. The safety and environmental performance record at ANCDF is • Management, 15-25 percent excellent and, in the committee’s opinion, is the result • Safety and surety, 25-35 percent of a leading safety culture. Various metrics are used in • Environmental, 20-30 percent an effort to achieve continuous improvement. • Cost performance, 10-20 percent ANCDF uses a number of what it calls leading • Schedule performance, 10-20 percent safety and health indicators: With 45 to 65 percent of the total available award fee • The number of assessments performed by safety based on safety and environmental performance, there professionals; is significant incentive for CMA’s contractors to excel • The number of assessments performed by a safety in these areas. representative, a first-line supervisor, or a member The award fee criteria identify specific safety and of an employee-led committee; environmental performance criteria against which con- • The number of assessments involving review of tractor performance is assessed. Two safety criteria are job safety analysis; specified: cases with days away from work, also known • The number of supervisors attaining Safety as lost workday cases (LWCs), and recordable injury Trained Supervisor Certification; and rates (RIRs). The specified criteria for environmental • The number of open actions and near-miss performance are regulatory compliance actions, notices reports. of noncompliance, and required submittals. CMA has established scoring and rating systems to assess perfor- The safety metrics reported by ANCDF as lagging mance against the award fee criteria. indicators include these: • The overall injury rate, Anniston Chemical Agent Disposal • The total RIR, Facility,, • The lost time injury rate, The Anniston Chemical Agent Disposal Facility • Hours without an LWC, (ANCDF) is located near Anniston, Alabama. It began • Number of reportable cases, destruction operations in August 2003 and currently • Number of LWCs, employs 761 people. Since commencing operations, 50 • Number of inspections, percent of the agent stockpile has been destroyed (1,127 • Regulatory citations, and tons of the nerve agents GB and VX, and mustard). • Near misses. The estimated completion date for chemical weapons It should be noted that the 2008 overall injury rate was almost half that in 2007—4.84 versus 8.32. See Table Cheryl 2.1 for safety statistics. Maggio, Deputy Project Manager, Chemical Stockpile Elimination, “Chemical stockpile elimination project overview,” The environmental metrics reported by ANCDF presentation to the committee on September 24, 2008. include these: Robert Brook, Safety Manager, URS, “Safety metrics presenta- tion,” presentation to the committee on September 24, 2008. • Surveillances, Ralph Nolte, Environmental Compliance Manager, URS, and • Self-reported noncompliances, Brian Thrasher, Deputy Environmental Manager, URS, “ANCDF • Resource Conservation and Recovery Act (RCRA) environmental metrics,” presentation to the committee on Septem- ber 25, 2008. remedial actions, 

10 Evaluation of Safety and Environmental Metrics Table 2-1  Chemical Demilitarization Site Injury Rates as of October 31, 2008 Employee Hours Worked Since Last Current Highest Lowest Highest Lowest Facility LWC (hr) 12-Month RIR 1-Month RIRa 1-Month RIRb 12-Month RIRc 12-Month RIRd ANCDF 3.9 million 0.73 5.18 0.0 1.73 0.27 (850 days) NECDF 1.2 million 0.52 4.45 0.0 1.95 0.33 (392 days) PBCDF 1.0 million 1.05 3.32 0.0 1.15 0.63 (250 days) TOCDF 5.7 million 1.28 14.54e/ 11.26 0.0 4.82 0.71 (1102 days) UMCDF 3.9 million 1.16 3.83 0.0 2.13 0.95 (850 days) NOTE: LWC, lost workday case; RIR, recordable injury rate. aWorst 1-month RIR in entire facility operational history, as of October 31, 2008. bBest 1-month RIR in entire facility operational history, as of October 31, 2008. cWorst 12-month RIR in entire facility operational history, as of October 31, 2008. dBest 12-month RIR in entire facility operational history, as of October 31, 2008. eThe higher number includes 11 cases of food poisoning that occurred at a safety celebration picnic. The lower number is calculated without these cases included. SOURCE: Cheryl Maggio, Deputy Project Manager Chemical Stockpile Elimination, CMA, “Chemical stockpile elimination project overview,” presentation to the committee on September 24, 2008; Personal communication between Raj Malhotra, Deputy, Mission Support Directorate, CMA, and Margaret Novack, NRC, study director, December 10, 2008. TABLE 2-2 Number of Environmental Enforcement Actions over the Last Five Fiscal Years Fiscal Year Standard Facility 2004 2005 2006 2007 2008a Average Deviation Total ANCDF 1 0 1 5 3 2 2 10 NECDF 1 1 0 0 0 0.4 0.55 2 PBCDF 0 0 1 0 1 0.4 0.55 2 TOCDF 1 2 2 1 1 1.4 0.55 7 UMCDF 1 4 2 4 0 2.2 1.79 11 Average 0.8 1.4 1.2 2.0 1.0 Standard deviation 0.45 1.67 0.84 2.35 1.20 Maximum 1 4 2 5 3 aAs of October 31, 2008. SOURCE: Drew Lyle, Chief, Environmental Office, CMA, “Environmental performance measurement,” presentation to the committee on September 24, 2008. • Automated waste feed cutoffs (AWFCOs) and Communication of Metrics engineering stop feeds, Information on safety metrics, as well as other • Nonregulatory inspections, and safety information, is made available to manage- • Maximum Achievable Control Technology (MACT) exceedences. 

SUMMARY OF Current Safety and Environmental Metrics 11 TABLE 2-3 Environmental Noncompliances by Site Newport Chemical Agent Disposal Facility Low High 2008a Facility,, ANCDF 5 45 5 The Newport Chemical Agent Disposal Facility NECDF 2 11 1 (NECDF) is located in Newport, Indiana. It was con- PBCDF 5 16 8 structed between November 2000 and July 2003 and TOCDF 1 2 11 UMCDF 16 52 13 began destruction operations in May 2005. It currently employs 454 people. During its operation, 100 percent aAs of October 31, 2008. of its agent stockpile (1,269 tons of VX stored in 1,690 SOURCE: Drew Lyle, Chief, Environmental Office, CMA, “Environmental performance measurement,” presentation to the committee on September 24, ton containers) was destroyed by caustic hydrolysis. All 2008; information provided by CMA. agent and waste products generated by agent hydroly- sis have been disposed of, and it is now in the closure phase. Safety and Environmental Performance and Metrics The site safety statistics for NECDF can be found in Table 2-1 and the environmental statistics in Tables 2-2 and 2-3. During the operational phase of the facility ment from Prostat. Information reported at ANCDF (through August 2008), a total of 25,900 employee- includes the number of reportable cases, the number based safety (EBS) observations were made. Three of LWCs, the hours since the last LWC, the number of hundred and thirty-eight of the observations noted inspections, regulatory citations, and near misses, and behaviors that could have placed the employees and an explanation of any Occupational Safety and Health people around them “at risk,” and the remainder noted Administration (OSHA) recordable injury (RI). The safe behaviors. Safety Digest is a newsletter sent to the supervisory The safety and environmental metrics in place dur- team so that members can disseminate safety informa- ing closure could reasonably be expected to differ from tion at employee meetings. Monthly injury statistics the metrics during the operational phase of a facility. are used internally by the safety department, while Although it is reasonable to assume that certain key statistical process control data on injury trending metrics used during operations will continue to be are made available to senior ANCDF management. employed during closure, no specific set of closure Additionally, self-evaluation results under the Volun- metrics was reported to the committee. The following tary Protection Programs (VPP) are supplied to the discussion examines metrics that were used during the regional VPP administrator as a measure of the safety operational phase. program’s effectiveness in meeting the stringent On a daily basis, the safety metrics included lost requirements established by OSHA’s VPP. workdays, RIs, first aid cases (FACs), and days since Environmental information is provided through last FAC. The safety metrics reported every week plan-of-the-day reports and schedule analysis pack- included lost workdays, RIs, FACs, days between ages. Additional environmental information is supplied FACs, near misses, injury by location on the body, for meetings of the Team for Environmental Aware- number of EBS observations, number of findings of ness Compliance and Health and the Non-Compliance safe behavior, number of findings of “at risk” behav- Review and Validation Squad. Cheryl Maggio, Deputy Project Manager, Chemical Stockpile Elimination, “Chemical stockpile elimination project overview,” presentation to the committee on September 24, 2008. Tulanda Brown, Risk Management Quality Assurance Director, Parsons, “NECDF safety metrics,” presentation to the committee Prostat is a statistical analysis and data presentation tool used on September 24, 2008. Scott Rowden, Environmental Manager, Parsons, “Environmen- at all four CMA incineration sites. See http://www.polysoftware. tal metrics at NECDF,” presentation to the committee on September com/stat.htm for more information. 25, 2008. 

12 Evaluation of Safety and Environmental Metrics ior, and safe behavior ratio. The monthly metrics Safety and Environmental Performance and Metrics include both lagging indicators (EBS observations) PBCDF safety statistics can be found in Table 2-1 and leading indicators (supervisor safety inspections, and environmental statistics in Tables 2-2 and 2-3. safety contacts, and management observations). The PBCDF employs a variety of safety and environmental facility manager said there were trigger points for metrics to continuously improve its safety and environ- action for certain metrics—for example, an RIR mental programs. The safety metrics are compiled daily, greater than 1.0. weekly, monthly, quarterly, and annually. The daily During the facility’s operational phase, three safety metrics include a contract deliverable that provides a and environmental improvement programs were initi- short description of any safety-related events that have ated. Ninety-five observers were trained for the EBS occurred during the previous 24 hours. Weekly metrics program. The management observation program was include FACs, RIs, and near misses. set up as a three-tier integrated system, and all supervi- Monthly metrics include a contract deliverable that sors and managers participated in human performance is distributed to management. It summarizes hours training. worked, cases reported, OSHA RIs, LWCs, and FACs. The facility tracks monthly injury trends by body part Communication of Metrics or cause. Leading indicators are also compiled monthly, including safety assessments that are performed by Information about safety and environmental metrics management, safety professionals, first-line supervi- is communicated via a safety Web site, sitewide safety sors, or by employee representatives. committees, and all-hands meetings. The meetings Quarterly and annual tracking of metrics involves a emphasize injuries and lessons learned and recognize compilation of injury trends, near misses, and safety and reward exemplary behavior and good safety metric observations that are submitted to management and the performance. regional VPP administrator. All of the safety data col- lected are utilized to develop strategies for continuous Pine bluff chemical agent disposal improvement in safety performance at PBCDF. facility,10,11 The environmental metrics at PBCDF aim to mini- mize environmental enforcement actions and enhance The Pine Bluff Chemical Agent Disposal Facil- the environmental culture at the facility. The facility ity (PBCDF) is located at the Pine Bluff Arsenal in reports site metrics weekly and reviews award fee met- Pine Bluff, Arkansas. It began destruction operations rics monthly with the project field office. These metrics in March 2005 and currently employs 773 people. include an assessment of the environmental culture Since commencing operations, 16.4 percent of the and environmental compliance. The environmental agent stockpile has been destroyed (631 tons out of culture is measured using a system that subjectively the original total 3,850 tons of GB, VX, and mustard; weighs environmental management system certifica- PBCDF is preparing to dispose of mustard stored in ton tion, training conducted, audits conducted, innovations, containers). The estimated completion date for chemi- and articles published in an employee newsletter. Envi- cal weapons destruction is December 2011. This does ronmental compliance is measured using a system that not, however, include the disposal of hazardous and weighs enforcement actions and both major and minor secondary waste. noncompliances. PBCDF examines other metrics as well, including self-reported noncompliances, envi- Cheryl ronmental surveillances, and RCRA remedial actions. Maggio, Deputy Project Manager, Chemical Stockpile Elimination, “Chemical stockpile elimination project overview,” Facility staff also collects environmental data that are presentation to the committee on September 24, 2008. not transformed into metrics, including RCRA infor- 10Marty Buell, Washington Demilitarization Company, Safety mation (e.g., AWFCOs) and Clean Air Act information Manager, URS, “Safety metrics presentation,” presentation to the (e.g., fuel usage and furnace operating conditions). The committee on September 24, 2008. facility’s environmental management system conforms 11Greg Thomasson, Washington Demilitarization Company, to the International Organization of Standardization Environmental Manager, URS, “PBCDF environmental metrics,” presentation to the committee, September 25, 2008. (ISO) 14001 series of standards. 

SUMMARY OF Current Safety and Environmental Metrics 13 Communication of Metrics 12-month rolling-average RIR for the facility. Days since the last RI and safe work hours (time since the last Metrics are communicated at PBCDF in a number LWC) are updated and reported regularly to TOCDF of ways. The facility publishes a weekly newsletter personnel. for employees that includes information on the safety TOCDF also utilizes a number of leading metrics. record of the facility and any safety-related events. An employee-based safety observation program has Quarterly and annual compilations of injury trends, been implemented; the resulting metric is the number near misses, and safety observations are communicated of observations performed per month, reported on a to management and the regional VPP administrator. trend chart. The TOCDF Safety Department performs All of the environmental metrics are communicated to zone inspections to identify unsafe physical condi- an employee environmental leadership committee, the tions and unsafe work practices. The number of zone plant management, and the project manager. inspections completed per month is used as a metric, and monthly histograms are produced showing counts tooele chemical agent disposal of specific unsafe conditions and work practices. In facility12,13,14 addition to injury metrics, TOCDF also counts safety near misses and reports this metric on a weekly trend The Tooele Chemical Agent Disposal Facility chart. (TOCDF) is located at the Deseret Chemical Depot, near TOCDF performs total injury analysis on all RIs and Tooele, Utah. It began destruction operations in August FACs. Univariate histograms break down injury counts 1996 and currently employs 1,020 people. Since com- by a variety of categories (e.g., department, shift, injury mencing operations, 71.8 percent of the agent stockpile type, and day of week). The facility also tracks the has been destroyed (9,593 of 13,361 tons of GB, VX, aging of safety work orders, including the number of and mustard; TOCDF is currently destroying mustard open work orders less than 45 days old and the number stored in ton containers). The estimated completion of open work orders more than 45 days old. TOCDF date for chemical weapons destruction operations is submitted a VPP application to the OSHA Regional March 2012. This does not, however, include the dis- Office in Denver on September 30, 2008. posal of hazardous and secondary waste. Lagging environmental metrics at TOCDF include state-identified noncompliances and self-reported Safety and Environmental Performance and Metrics (RCRA and Title V) noncompliances. These are counted on a monthly basis and the 12-month rolling TOCDF safety statistics can be found in Table 2-1 average is updated monthly. and environmental statistics in Tables 2-2 and 2-3. Leading environmental metrics include counts and TOCDF uses a variety of metrics to assess the perfor- timing (day of week) of RCRA inspections (performed mance of its safety and environmental programs. These by operations personnel) and regulatory inspections metrics include both lagging indicators (e.g., RIs and performed by the TOCDF Environment Department. environmental events) and leading indicators (e.g., near Inspection findings are summarized in histograms by misses, observations, and inspections). These metrics category (e.g., noncontainerized waste and container are compiled and reported daily, weekly, monthly, integrity) on a weekly basis, and trend charts are quarterly, and annually. generated. In addition, TOCDF counts environmental Lagging safety metrics at TOCDF include counts near misses and reports this metric on a weekly trend of LWCs, RIs, and FACs. For recordable injuries, an chart. RIR is calculated each month and used to update the TOCDF tracks the aging of RCRA work orders on a weekly basis, including the number of newly opened 12Cheryl Maggio, Deputy Project Manager, Chemical Stockpile work orders and work orders closed. In addition, the Elimination, “Chemical stockpile elimination project overview,” trend in number of still-open work orders is given by presentation to the committee on September 24, 2008. week. MACT alarms are counted weekly for the metal 13Paul Anderson, Safety Manager, EG&G, “Safety metrics,” parts furnace, and weekly counts of the reason for the presentation to the committee on September 24, 2008. alarms are charted in a histogram. AWFCOs are tracked 14Elizabeth Lowes, Deputy General Manager for Closure Integra- for each furnace. tion, EG&G, “TOCDF environmental metrics,” presentation to the committee on September 25, 2008. 

14 Evaluation of Safety and Environmental Metrics TOCDF is a self-certified ISO 14001 facility. Non- tion date for chemical weapons destruction is July regulatory environmental metrics tracked by TOCDF 2011. This does not, however, include the disposal of include the following: hazardous and secondary waste. • Annual natural gas usage, Safety and Environmental Performance and Metrics • Water usage, • Scrap metal recycled, UMCDF safety statistics can be found in Table 2- • Paper recycled, and 1 and environmental statistics in Tables 2-2 and 2-3. • Secondary waste processing/disposal. The facility uses a variety of safety metrics. On a daily basis the site reviews injuries and illnesses, near misses, property/vehicle damage, first aid visits, recordables, Communications at Metrics and days worked since LWC. On a weekly basis it TOCDF staff prepares a daily status review and a looks at the 12-month RIR and the LWC rate, FACs, daily progress report. There is also a weekly newslet- near misses, and the total recordable rate. On a monthly ter that includes key rates and daily counts. Days since basis it reviews the OSHA 300 log, the project’s total the last RI are included in the daily safety management work rolling RIR, operations and maintenance rolling report that is distributed to all management and through RIR, operations and maintenance subcontractor RIR, the weekly Safety Action Team publication SAT News- hours and days without a LWC, and FACs.18 letter. Safe work hours are communicated very broadly Additionally, plant managers and the safety manager on large signs around the site, the TOCDF intranet, in conduct and document weekly safety inspections of weekly and monthly management reports, and to all targeted work areas. Department safety professionals employees on the Safety Action Team. Safety metrics also conduct and document weekly safety assessments. are reviewed on a quarterly basis. While not a metric, The goal is for 80 percent or more of the assessments to safety-related lessons learned are published and distrib- result in no findings, and 100 percent of any findings to uted to the demilitarization community. be resolved within one week. First-line supervisors and Site-level metrics are communicated to all employ- the shift safety representative conduct monthly inspec- ees on a weekly, monthly, and quarterly basis and are tions of work areas under their control. available on the TOCDF intranet. Metrics are presented UMCDF also uses a variety of environmental met- to the Site Environmental Leadership Committee, rics. The metrics reviewed include self-reported non- Departmental Corrective Action Review Boards, and compliances, surveillances, AWFCOs and engineering the Site Corrective Action Review Boards. stop feeds, RCRA aging open items, regulatory and internal inspections, and MACT exceedences. Safety metrics are reviewed daily, weekly, and Umatilla chemical agent disposal monthly. The reviews are used for the annual award fee facility15,16,17 program and to identify areas of opportunity. Areas of The Umatilla Chemical Agent Disposal Facility opportunity identified are (UMCDF) is located at the Umatilla Chemical Depot in Hermiston, Oregon. It began destruction operations • Better reporting of near misses; in September 2004 and currently employs 819 people. • Behavior modification to help reduce unsafe Since commencing operations, 35.5 percent of the acts; agent stockpile has been destroyed (1,319 out of 3,719 • More attention to detail; and tons of GB, VX, and mustard). The estimated comple- • Increased identification and hazard control when the work involves fingers and hands, focusing on 15CherylMaggio, Deputy Project Manager, Chemical Stockpile sharp objects and bodily motion. Elimination, “Chemical stockpile elimination project overview,” presentation to the committee on September 24, 2008. 16Emily Milliken, Safety Manager, URS, “Safety metrics,” pre- sentation to the committee on September 24, 2008. 18The OSHA 300 log is the document where recordable in- 17Jim Wenzel, Environmental Manager, UMCDF, “UMCDF en- juries are noted and documented. For more information, see vironmental metrics,” presentation to the committee on September http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_ 25, 2008. table=STANDARDS&p_id=12805. 

SUMMARY OF Current Safety and Environmental Metrics 15 Communication of Metrics is provided to the entire site via a Web site. A monthly report on injury trends by department is posted to the Safety metrics are communicated in a variety of Web site and sent to management for use in identifying ways. One is a daily injury and illness report containing injury trends and controlling injuries. The annual trend information on near misses, FACs, and recordables for report posted to the Web site contains information on the last 24 hours. A weekly operations analysis includes root cause, hazard category, body part, day of week, a review of the 12-month rolling RIR along with met- time of injury, shift, department where near misses rics on which the award fee is based: RIRs, FACs, and occur, and injuries and illnesses. near misses. A weekly safety synopsis is delivered to Environmental metrics are communicated to the project management, the field office, and the corporate Environmental Process Improvement Team, to quar- office. In addition, there is a monthly report, which is terly meetings of supervisors and the project general a contract deliverable, including data from the OSHA manager, to “welcome back” briefings every Tuesday, 300 forms, a summary of near misses and FACs, and and articles in Today. 19 contract data requirements. A monthly corporate report 19Today is UMCDF’s internal communication document.