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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities 4 Assessment of Other Metrics Potentially Applicable to Chemical Agent Disposal Facilities To accomplish the last two items on its statement of task, the committee assessed the development and use of leading and lagging indicators by various government and private organizations, including any new initiatives that the committee learned about in the course of its fact finding. Although it conducted this assessment the committee developed no related recommendations for implementation by the chemical agent disposal facilities (CDFs). Each such facility is in a unique situation with respect to site-specific geography, agent and munitions to be disposed of, demographics, culture, management, and regulatory climate. As a result, each site needs to be able to determine the metrics that are most appropriate for it. A top-down prescription for a standard set of metrics to be used at all CDFs would be less than helpful in the committee’s view. Instead, the committee presents a general overview of the types of metrics that might provide general guidance to the CDFs for the continuing development of their safety and environmental programs and culture. The committee assessed metrics that are currently used by the Department of the Army and the Federal Aviation Administration. They also assessed those of the Center for Chemical Process Safety of the American Institute of Chemical Engineers (AIChE), Corning, Dow Chemical, Motorola, and Praxair. The discussion of applicable metrics that follows is based on information compiled in Appendix B. Data on environment, safety, and health (ESH) matters have historically been collected to provide management with quantifiable outcomes such as actual and hidden costs, lost time, and worker illness and injury. These data were often tied to regulatory compliance and/or worker compensation costs. The data used were almost exclusively lagging indicators—that is, they were collected after an incident, to determine strategies based on recorded outcomes to prevent future incidents. While lagging indicators serve useful purposes, they need to be supplemented with leading indicators to ensure continuous improvement of an ESH program. Also, lagging indicators are of minimal use for an organization such as the Chemical Materials Agency (CMA), whose mission is changing, moving from disposal of chemical agents to plant closure and disposal of hazardous and secondary waste. Companies and organizations like the CMA that want to be the best in the field have recognized the limitations of lagging indicators and are seeking to use leading indicators to anticipate possible incidents within the ESH categories. While the literature is replete with information on leading indicators, their actual implementation to achieve continuous improvement is limited at best. Notwithstanding this, leading indicator models appear to have certain elements in common: Identifying hazards through risk assessment, Communication, Training, Documentation, Periodic review by top management, Follow-up on findings and corrective action, Analysis of near misses, Sharing of lessons learned, Worker involvement, and Audits and assessments.
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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities While the definitions of lagging and leading indicators varied from one organization to the next, when the combined information from these organizations was considered some common themes for developing a system for using leading indicators became apparent. The definitions developed by this committee (see Appendix A) capture the intent of all of the organizations reviewed. The entire committee agrees that measurement is the precursor to control, and that the usual lagging indicators (e.g., those used by CMA and reviewed in Chapter 3) should not be neglected as they ultimately lead to improvement in safety performance outcomes. Any measurements and derived indicators must be part of an overall system—an environmental policy or a commitment to continuous improvement—if they are to be effective in driving improvement. This system must possess a control philosophy (whether it is called risk management or safety management or is a business strategy such as Six Sigma), the commitment of top management, and specific goals for each indicator. Input measures are the precursors to good safety performance. They include ensuring that safety is designed into all equipment and procedures, timely and effective training for all personnel, setting and meeting individual safety goals, and completion of tasks set (e.g., corrective actions, preventive actions, and permits issued). These inputs do not in themselves guarantee a safe organization, but they are a sign of how ready an organization is to achieve and improve safety. Process measures are indicators that the organization and its workforce are performing their duties in a safe manner. Again, they do not guarantee safety, but without such indicators, reported levels of safety may reflect chance avoidance of rare events rather than safety levels achieved as a result of design and control. Typical process measures of safety include the number of near misses or incidents, behavior-based safety observations, rates of compliance with written procedures, participation in pretask hazard assessments, and audits or assessments of task performance and workplace factors. Note that assessments can be self-assessments, which provide useful training and involve the workforce, or independent assessments, which provide unbiased assurance of the state of processes. Ideally, all of these leading process measures should have been validated against outcome (lagging) indicators to ensure that they are indeed necessary conditions for safety performance, a step that is often neglected. Process measures include the actual physical processes of each task on a production line as well as completion of all preventive maintenance associated with the production line. The task processes are often evaluated by means of a job hazard analysis/process analysis as required under the Occupational Safety and Health Administration Voluntary Protection Programs (VPPs). While preventive maintenance may not in itself be an ESH direct indicator, the failure of a mechanical system may lead to an event that can produce an injury, exposure, or environmental insult. To this end, keeping to the preventive maintenance schedule and monitoring the completion of the tasks in that schedule are leading indicators of ESH. Analysis of measured data is vital to ensuring evidenced-based control of safety. Analyses could entail the more thorough investigation of incidents and/or near misses to ensure that the causative factors have been identified; application of standard methodologies such as root-cause analysis; generation of indices in terms of rates rather than absolute numbers; and application of quality control techniques for visualizing trends. Such analyses provide a bridge between the raw data and management action, so that management has a clearer understanding of what needs to be changed and the potential effects of its actions on safety performance. Accountability at both the organizational and individual levels is essential. Many organizations require the evaluation of support for and actual performance of ESH matters in employee and supervisor appraisals. In the organizations that excel in ESH, accountability includes penalties for specifically defined substandard performance. Overall, much can be learned from the practices of industrial and government organizations about the derivation and use of leading indicators that could be applied to chemical demilitarization operations. Again, because of the unique circumstances in which each chemical agent disposal facility finds itself, the committee generalized its assessment to assist facilities in furthering their safety and environmental programs and cultures. The International Civil Aviation Organization summarizes overall safety management as follows: A safety management system …, as a minimum, identifies safety hazards, ensures that remedial action necessary to maintain an acceptable level of safety is implemented …, provides for continuous monitoring and regular assessment of the safety level achieved …, and aims to make continuous improvement to the overall level of safety.1 1 Elwyn Jordan, Aviation Safety Inspector, Federal Aviation Administration, “Introduction to safety management systems (SMS),” presentation to the Federal Air Regulation 135 Seminar on April 19, 2007.