5
Findings and Recommendations

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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5 Findings and recommendations Finding. Safety and environmental performance at the Recommendation 2. The Chemical Materials Agency operating Chemical Materials Agency chemical agent should require the development of a system of clear disposal facilities has continuously improved and is and consistent definitions that can be applied across currently significantly better than the national average all chemical agent disposal facilities. Although each industry as measured by lost workday cases and the facility should have the flexibility to apply safety and recordable injury rate. Three of the five facilities are environmental approaches that meet any unique needs, compliant with third-party accreditation requirements. a particular metric should be defined consistently to All but one of the facilities have been certified with the allow for direct comparisons among the facilities. Star designation by the Voluntary Protection Programs Finding. The chemical agent disposal facilities collect of OSHA and all conform to the International Organi- zation for Standardization (ISO) 14001 environmental extensive data on injuries, and most engage in some requirements. injury analysis. However, no facility takes full advan- tage of the data to create additional and potentially Recommendation 1. The chemical agent disposal more sensitive metrics. The focus has been on lost facilities should continue the process of continuous workday cases and the recordable injury rate. Other improvement to achieve levels of safety and environ- possible metrics, such as medical treatment cases and mental performance equivalent to those achieved by first aid case rates, are not universally employed or comparable industries. Third-party certifications should communicated. The analyses simply list outcomes and be continued and encouraged. All chemical agent dis- incidental variables (e.g., department and day of week) posal facilities should comply or obtain the Star des- and as such are not very useful metrics. Further, they ignation of the OSHA Voluntary Protection Programs, fail to include some essential information such as the and all should continue to comply with the most current task being performed when the injury occurred and the ISO environmental management standards. location within the facility where it took place. Finding. The terminology used to describe various Finding. In addition to collecting data on injuries, all metrics and related activities is not consistent across chemical agent disposal facilities collect extensive the chemical agent disposal facilities or within the incident data, but there does not appear to be an inci- Chemical Materials Agency. This makes it difficult to dent investigation system that would enable the sites to compare the sites in a meaningful way or to accurately analyze the data and extract from them indicators for analyze programwide data. preventive action. Insofar as they are reported, “met- rics” are simple lists. 

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 EVALuATiON OF SAFETy ANd ENViRONmENTAL mETRiCS Finding. The chemical agent disposal facilities have to the environment area. Metrics could be developed many observation programs in place, but as with data that resemble leading safety metrics and could include on incidents, no metrics appear to be developed from the following: them. Observations derived from the various programs • Projected use of energy, materials, and water; are not combined or analyzed and, again, many of the • Time to correct violation and devise preventive reported metrics are simply lists. action; • Content of environmental training courses and Recommendation 3. The chemical agent disposal facilities should take full advantage of injury data to frequency with which they are offered; and • Observations of small spills or improper disposal develop, employ, and communicate additional related metrics. All of the facilities should engage in injury of chemicals. analysis, and the analyses should include all relevant data and be structured so that meaningful indicators can In addition, it is recommended that all available data be be derived from them. examined for patterns that might turn out to be useful leading indicators. Recommendation 4. Incident data can be leading indi- Finding. Metrics used at the chemical agent disposal cators for injuries, although they are also lagging indi- cators for conditions and behaviors that could result in facilities are mainly lagging ones that record relatively injuries. The chemical agent disposal facilities should rare, undesirable outcomes such as recordable injuries. develop metrics from incident data—one such might be This practice does not yield good information on the an unsafe acts index that could support the analysis of real-time status of important leading variables such as trends and point out a need for preventive action. physical conditions and work practices. As a result, workers and managers do not receive timely feedback Recommendation 5. Chemical agent disposal facili- on how well they are doing in maintaining a work ties should stop reporting on and communicating data environment that is free of conditions or behaviors that that are simple enumerations unless there is a clear increase the risk of injury. Chapter 4 of this report pro- understanding of the context for the data or a demon- vides examples of outstanding safety programs in the strated connection to the continuous improvement of private sector and government. These programs focus safety and/or environmental performance. For example, on positive—that is to say, desirable—working condi- reporting absolute numbers of injuries by department tions and practices, leading indicator variables, and the conveys no information that can be translated into ongoing measurement of positive process variables. action, because the data have not been transformed Recommendation 7. Chemical agent disposal facilities into a metric that allows true department-to-department comparisons (i.e., departmental injury rates). Finally, should establish metrics that directly measure safety the facilities should cease collecting data that are not program effectiveness in near real time. These initia- used to develop metrics or meaningful indicators. tives to establish metrics should focus on identifying leading variables that (1) set high standards for safe Finding. Key environmental metrics used by the chem- working conditions and (2) are a sign of a positive ical agent disposal facilities are based on the formal safety culture—for instance, 100 percent compliance in written notification that an applicable statutory or regu- wearing personnel protective equipment; 100 percent latory requirement promulgated by the Environmental compliance with correct use of lockout and tag out Protection Agency or other authorized federal, state, procedures; and the documented participation of man- interstate, regional, or local environmental regulatory agement in the safety and environmental programs. agency has been violated. These metrics are lagging Recommendation 8. The chemical agent disposal indicators. facilities should conduct their own review of the best Recommendation 6. The chemical agent disposal practices of the entities discussed in Chapter 4 to deter- facilities should develop a broader set of leading envi- mine whether there are practices and metrics that would ronmental metrics. For example, incident reporting and complement their own metrics and, in turn, benefit their analysis and observation programs could be extended own safety and environmental programs.

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 FiNdiNGS ANd RECOmmENdATiONS Finding. Chemical agent disposal facility processing not wish to prescribe these for all the CDFs because the operations generally consist of routine, repetitive, and degree to which they would be useful will vary based much-practiced procedures. Safety will continue to on each facility’s safety and environmental culture, be a key consideration as site activities transition to regulatory environment, and stage of agent process- decommissioning, demolition, and handling and ship- ing. The committee believes that the management of ping of secondary wastes. Closure operations involve each CDF can best weigh the potential utility of these new and much more varied procedures. The award fee recommendations. criteria may have different targets for closure because Finding. Incidents are not classified and no metrics are the current metrics and targets may not be appropriate for the closure phase. derived from incident data. Recommendation 9. The Chemical Materials Agency Recommendation 10. Chemical agent disposal facili- should establish a framework for developing metrics ties should consider classifying incidents (one such for the decommissioning and demolition of chemical class might be “incident with serious potential”) to agent disposal facilities. This framework should be enable the development of additional metrics and help used for all the facilities but on a site-specific basis. The with prioritizing incident investigations. framework should include safety and environmental Finding. None of the chemical agent disposal facilities metrics and targets, as well as a plan for communicat- ing information to workers and the public. The metrics develop or employ process safety metrics. in use for operational processes should be reviewed for Recommendation 11. The chemical agent disposal appropriateness and target levels. Additional metrics should be identified from the best practices for decom- facilities should consider developing and implement- missioning and decontaminating industrial facilities ing leading and lagging metrics for process safety. and for the Environmental Protection Agency’s Super- They should consider using the American Institute fund program. of Chemical Engineers’ Center for Chemical Process Safety document entitled Process Safety Leading and The following findings and recommendations might Lagging metrics to guide implementation of process be useful for the CDFs to consider. The committee does safety metrics.

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