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Suggested Citation:"5 Findings and Recommendations." National Research Council. 2009. Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities. Washington, DC: The National Academies Press. doi: 10.17226/12580.
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Suggested Citation:"5 Findings and Recommendations." National Research Council. 2009. Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities. Washington, DC: The National Academies Press. doi: 10.17226/12580.
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Suggested Citation:"5 Findings and Recommendations." National Research Council. 2009. Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities. Washington, DC: The National Academies Press. doi: 10.17226/12580.
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Page 23
Suggested Citation:"5 Findings and Recommendations." National Research Council. 2009. Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities. Washington, DC: The National Academies Press. doi: 10.17226/12580.
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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 of OSHA and all conform to the International Organi- Finding. The chemical agent disposal facilities collect 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. 21

22 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 are not combined or analyzed and, again, many of the • Projected use of energy, materials, and water; reported metrics are simply lists. • Time to correct violation and devise preventive action; Recommendation 3. The chemical agent disposal • Content of environmental training courses and facilities should take full advantage of injury data to frequency with which they are offered; and develop, employ, and communicate additional related • Observations of small spills or improper disposal 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- cators for injuries, although they are also lagging indi- Finding. Metrics used at the chemical agent disposal 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 into a metric that allows true department-to-department Recommendation 7. Chemical agent disposal facilities 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 indicators. Recommendation 8. The chemical agent disposal 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.

FINDINGS AND RECOMMENDATIONS 23 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 the current metrics and targets may not be appropriate Finding. Incidents are not classified and no metrics are 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 metrics and targets, as well as a plan for communicat- Finding. None of the chemical agent disposal facilities ing information to workers and the public. The metrics develop or employ process safety metrics. in use for operational processes should be reviewed for appropriateness and target levels. Additional metrics Recommendation 11. The chemical agent disposal 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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By the end of 2009, more than 60 percent of the global chemical weapons stockpile declared by signatories to the Chemical Weapons Convention will have been destroyed, and of the 184 signatories, only three countries will possess chemical weapons-the United States, Russia, and Libya.

In the United States, destruction of the chemical weapons stockpile began in 1990, when Congress mandated that the Army and its contractors destroy the stockpile while ensuring maximum safety for workers, the public, and the environment. The destruction program has proceeded without serious exposure of any worker or member of the public to chemical agents, and risk to the public from a storage incident involving the aging stockpile has been reduced by more than 90 percent from what it was at the time destruction began on Johnston Island and in the continental United States.

At this time, safety at chemical agent disposal facilities is far better than the national average for all industries. Even so, the Army and its contractors are desirous of further improvement. To this end, the Chemical Materials Agency (CMA) asked the NRC to assist by reviewing CMA's existing safety and environmental metrics and making recommendations on which additional metrics might be developed to further improve its safety and environmental programs.

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