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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities
2
Summary of Current Safety and Environmental Metrics at Chemical Agent Disposal Facilities1
In this chapter, the collection, analysis, communication, and use of safety and environmental metrics are summarized, first at the level of the Chemical Materials Agency (CMA) and then at the level of the chemical agent disposal facilities (CDFs), in alphabetical order. These metrics are reviewed and evaluated in more detail in Chapter 3.
The term “safety metric” refers to a standard of measurement used to maintain an accident- and injury-free workplace, while “environmental metric” refers to a standard of measurement for chemical and handling processes relating to public health and the environment.
Metrics are characterized by:
What kinds of data are being collected—for example, number of injuries and number of regulatory noncompliances;
How the data are converted to metrics. This is typically done by dividing by a measure of exposure—for example, number of injuries per 200,000 working hours or number of regulatory noncompliance occurrences per month;
How this information is aggregated over departments or over time—for example, injury rates by department or by month or average annual rates of regulatory noncompliance;
How the information is used to improve safety—for example, detailed analysis of recent injuries to find opportunities for improvement or understanding the root causes of regulatory noncompliance to modify change procedures; and
How the information is communicated to management, safety professionals, the workforce, contractors, the public, and other sites.
Metrics can also be characterized by whether they are based on events that have already occurred, usually called lagging indicators, or on measured precursors to events, usually known as leading indicators. While lagging indicators give information of direct concern to management, the workforce, and the public, they can only be used for improvement after the fact. In contrast, leading indicators point the way to possible improvements in safety and environmental performance.
CHEMICAL MATERIALS AGENCY
CMA is responsible for the safe storage and destruction of most of the nation’s chemical weapons stockpile. It oversees the activities in the five CDFs that are covered in this report. The headquarters management team, as well as scientific, communications, and 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 the chemical weapons stockpile, its contractors are responsible for ensuring that the congressional mandate
1
Information gathering for this report ceased on October 31, 2008. The most current information is available at http://www.cma.army.mil.
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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities
for safety is fulfilled. To encourage exemplary performance, CMA has established award fee criteria so its contractors can be financially rewarded for safety and environmental performance over and above contract values. These criteria establish five categories in which performance will be measured and establish percentage ranges for each. The performance categories are these:
Management, 15-25 percent
Safety and surety, 25-35 percent
Environmental, 20-30 percent
Cost performance, 10-20 percent
Schedule performance, 10-20 percent
With 45 to 65 percent of the total available award fee based on safety and environmental performance, there is significant incentive for CMA’s contractors to excel in these areas.
The award fee criteria identify specific safety and environmental performance criteria against which contractor performance is assessed. Two safety criteria are specified: cases with days away from work, also known as lost workday cases (LWCs), and recordable injury rates (RIRs). The specified criteria for environmental performance are regulatory compliance actions, notices of noncompliance, and required submittals. CMA has established scoring and rating systems to assess performance against the award fee criteria.
ANNISTON CHEMICAL AGENT DISPOSAL FACILITY2,3,4
The Anniston Chemical Agent Disposal Facility (ANCDF) is located near Anniston, Alabama. It began destruction operations in August 2003 and currently employs 761 people. Since commencing operations, 50 percent of the agent stockpile has been destroyed (1,127 tons of the nerve agents GB and VX, and mustard). The estimated completion date for chemical weapons destruction is 2012. This, however, does not include the disposal of hazardous and secondary waste.
Safety and Environmental Performance and Metrics
Safety statistics for ANCDF and the four other sites can be found in Table 2-1 and environmental statistics for them can be found in Tables 2-2 and 2-3. The safety and environmental performance record at ANCDF is excellent and, in the committee’s opinion, is the result of a leading safety culture. Various metrics are used in an effort to achieve continuous improvement.
ANCDF uses a number of what it calls leading safety and health indicators:
The number of assessments performed by safety professionals;
The number of assessments performed by a safety representative, a first-line supervisor, or a member of an employee-led committee;
The number of assessments involving review of job safety analysis;
The number of supervisors attaining Safety Trained Supervisor Certification; and
The number of open actions and near-miss reports.
The safety metrics reported by ANCDF as lagging indicators include these:
The overall injury rate,
The total RIR,
The lost time injury rate,
Hours without an LWC,
Number of reportable cases,
Number of LWCs,
Number of inspections,
Regulatory citations, and
Near misses.
It should be noted that the 2008 overall injury rate was almost half that in 2007—4.84 versus 8.32. See Table 2.1 for safety statistics.
The environmental metrics reported by ANCDF include these:
Surveillances,
Self-reported noncompliances,
Resource Conservation and Recovery Act (RCRA) remedial actions,
2
Cheryl Maggio, Deputy Project Manager, Chemical Stockpile Elimination, “Chemical stockpile elimination project overview,” presentation to the committee on September 24, 2008.
3
Robert Brook, Safety Manager, URS, “Safety metrics presentation,” presentation to the committee on September 24, 2008.
4
Ralph Nolte, Environmental Compliance Manager, URS, and Brian Thrasher, Deputy Environmental Manager, URS, “ANCDF environmental metrics,” presentation to the committee on September 25, 2008.
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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities
TABLE 2-1 Chemical Demilitarization Site Injury Rates as of October 31, 2008
Facility
Employee Hours Worked Since Last LWC (hr)
Current 12-Month RIR
Highest 1-Month RIRa
Lowest 1-Month RIRb
Highest 12-Month RIRc
Lowest 12-Month RIRd
ANCDF
3.9 million (850 days)
0.73
5.18
0.0
1.73
0.27
NECDF
1.2 million (392 days)
0.52
4.45
0.0
1.95
0.33
PBCDF
1.0 million (250 days)
1.05
3.32
0.0
1.15
0.63
TOCDF
5.7 million (1102 days)
1.28
14.54e/ 11.26
0.0
4.82
0.71
UMCDF
3.9 million (850 days)
1.16
3.83
0.0
2.13
0.95
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
Facility
Fiscal Year
Average
Standard Deviation
Total
2004
2005
2006
2007
2008a
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
engineering stop feeds,
Nonregulatory inspections, and
Maximum Achievable Control Technology (MACT) exceedences.
Communication of Metrics
Information on safety metrics, as well as other safety information, is made available to manage-
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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities
TABLE 2-3 Environmental Noncompliances by Site
Facility
Low
High
2008a
ANCDF
5
45
5
NECDF
2
11
1
PBCDF
5
16
8
TOCDF
1
2
11
UMCDF
16
52
13
aAs of October 31, 2008.
SOURCE: Drew Lyle, Chief, Environmental Office, CMA, “Environmental performance measurement,” presentation to the committee on September 24, 2008; information provided by CMA.
ment from Prostat.5 Information reported at ANCDF includes the number of reportable cases, the number of LWCs, the hours since the last LWC, the number of inspections, regulatory citations, and near misses, and an explanation of any Occupational Safety and Health Administration (OSHA) recordable injury (RI). The Safety Digest is a newsletter sent to the supervisory team so that members can disseminate safety information at employee meetings. Monthly injury statistics are used internally by the safety department, while statistical process control data on injury trending are made available to senior ANCDF management. Additionally, self-evaluation results under the Voluntary Protection Programs (VPP) are supplied to the regional VPP administrator as a measure of the safety program’s effectiveness in meeting the stringent requirements established by OSHA’s VPP.
Environmental information is provided through plan-of-the-day reports and schedule analysis packages. Additional environmental information is supplied for meetings of the Team for Environmental Awareness Compliance and Health and the Non-Compliance Review and Validation Squad.
NEWPORT CHEMICAL AGENT DISPOSAL FACILITY6,7,8
The Newport Chemical Agent Disposal Facility (NECDF) is located in Newport, Indiana. It was constructed between November 2000 and July 2003 and began destruction operations in May 2005. It currently employs 454 people. During its operation, 100 percent of its agent stockpile (1,269 tons of VX stored in 1,690 ton containers) was destroyed by caustic hydrolysis. All agent and waste products generated by agent hydrolysis 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 (through August 2008), a total of 25,900 employee-based safety (EBS) observations were made. Three hundred and thirty-eight of the observations noted behaviors that could have placed the employees and people around them “at risk,” and the remainder noted safe behaviors.
The safety and environmental metrics in place during closure could reasonably be expected to differ from the metrics during the operational phase of a facility. Although it is reasonable to assume that certain key metrics used during operations will continue to be employed during closure, no specific set of closure metrics was reported to the committee. The following discussion examines metrics that were used during the operational phase.
On a daily basis, the safety metrics included lost workdays, RIs, first aid cases (FACs), and days since last FAC. The safety metrics reported every week included lost workdays, RIs, FACs, days between FACs, near misses, injury by location on the body, number of EBS observations, number of findings of safe behavior, number of findings of “at risk” behav-
5
Prostat is a statistical analysis and data presentation tool used at all four CMA incineration sites. See http://www.polysoftware.com/stat.htm for more information.
6
Cheryl Maggio, Deputy Project Manager, Chemical Stockpile Elimination, “Chemical stockpile elimination project overview,” presentation to the committee on September 24, 2008.
7
Tulanda Brown, Risk Management Quality Assurance Director, Parsons, “NECDF safety metrics,” presentation to the committee on September 24, 2008.
8
Scott Rowden, Environmental Manager, Parsons, “Environmental metrics at NECDF,” presentation to the committee on September 25, 2008.
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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities
ior, and safe behavior ratio. The monthly metrics include both lagging indicators (EBS observations) and leading indicators (supervisor safety inspections, safety contacts, and management observations). The facility manager said there were trigger points for action for certain metrics—for example, an RIR greater than 1.0.
During the facility’s operational phase, three safety and environmental improvement programs were initiated. Ninety-five observers were trained for the EBS program. The management observation program was set up as a three-tier integrated system, and all supervisors and managers participated in human performance training.
Communication of Metrics
Information about safety and environmental metrics is communicated via a safety Web site, sitewide safety committees, and all-hands meetings. The meetings emphasize injuries and lessons learned and recognize and reward exemplary behavior and good safety metric performance.
PINE BLUFF CHEMICAL AGENT DISPOSAL FACILITY9,10,11
The Pine Bluff Chemical Agent Disposal Facility (PBCDF) is located at the Pine Bluff Arsenal in Pine Bluff, Arkansas. It began destruction operations in March 2005 and currently employs 773 people. Since commencing operations, 16.4 percent of the agent stockpile has been destroyed (631 tons out of the original total 3,850 tons of GB, VX, and mustard; PBCDF is preparing to dispose of mustard stored in ton containers). The estimated completion date for chemical weapons destruction is December 2011. This does not, however, include the disposal of hazardous and secondary waste.
Safety and Environmental Performance and Metrics
PBCDF safety statistics can be found in Table 2-1 and environmental statistics in Tables 2-2 and 2-3. PBCDF employs a variety of safety and environmental metrics to continuously improve its safety and environmental programs. The safety metrics are compiled daily, weekly, monthly, quarterly, and annually. The daily metrics include a contract deliverable that provides a short description of any safety-related events that have occurred during the previous 24 hours. Weekly metrics include FACs, RIs, and near misses.
Monthly metrics include a contract deliverable that is distributed to management. It summarizes hours worked, cases reported, OSHA RIs, LWCs, and FACs. The facility tracks monthly injury trends by body part or cause. Leading indicators are also compiled monthly, including safety assessments that are performed by management, safety professionals, first-line supervisors, or by employee representatives.
Quarterly and annual tracking of metrics involves a compilation of injury trends, near misses, and safety observations that are submitted to management and the regional VPP administrator. All of the safety data collected are utilized to develop strategies for continuous improvement in safety performance at PBCDF.
The environmental metrics at PBCDF aim to minimize environmental enforcement actions and enhance the environmental culture at the facility. The facility reports site metrics weekly and reviews award fee metrics monthly with the project field office. These metrics include an assessment of the environmental culture and environmental compliance. The environmental culture is measured using a system that subjectively weighs environmental management system certification, training conducted, audits conducted, innovations, and articles published in an employee newsletter. Environmental compliance is measured using a system that weighs enforcement actions and both major and minor noncompliances. PBCDF examines other metrics as well, including self-reported noncompliances, environmental surveillances, and RCRA remedial actions. Facility staff also collects environmental data that are not transformed into metrics, including RCRA information (e.g., AWFCOs) and Clean Air Act information (e.g., fuel usage and furnace operating conditions). The facility’s environmental management system conforms to the International Organization of Standardization (ISO) 14001 series of standards.
9
Cheryl Maggio, Deputy Project Manager, Chemical Stockpile Elimination, “Chemical stockpile elimination project overview,” presentation to the committee on September 24, 2008.
10
Marty Buell, Washington Demilitarization Company, Safety Manager, URS, “Safety metrics presentation,” presentation to the committee on September 24, 2008.
11
Greg Thomasson, Washington Demilitarization Company, Environmental Manager, URS, “PBCDF environmental metrics,” presentation to the committee, September 25, 2008.
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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities
Communication of Metrics
Metrics are communicated at PBCDF in a number of ways. The facility publishes a weekly newsletter for employees that includes information on the safety record of the facility and any safety-related events. Quarterly and annual compilations of injury trends, near misses, and safety observations are communicated to management and the regional VPP administrator. All of the environmental metrics are communicated to an employee environmental leadership committee, the plant management, and the project manager.
TOOELE CHEMICAL AGENT DISPOSAL FACILITY12,13,14
The Tooele Chemical Agent Disposal Facility (TOCDF) is located at the Deseret Chemical Depot, near Tooele, Utah. It began destruction operations in August 1996 and currently employs 1,020 people. Since commencing operations, 71.8 percent of the agent stockpile has been destroyed (9,593 of 13,361 tons of GB, VX, and mustard; TOCDF is currently destroying mustard stored in ton containers). The estimated completion date for chemical weapons destruction operations is March 2012. This does not, however, include the disposal of hazardous and secondary waste.
Safety and Environmental Performance and Metrics
TOCDF safety statistics can be found in Table 2-1 and environmental statistics in Tables 2-2 and 2-3. TOCDF uses a variety of metrics to assess the performance of its safety and environmental programs. These metrics include both lagging indicators (e.g., RIs and environmental events) and leading indicators (e.g., near misses, observations, and inspections). These metrics are compiled and reported daily, weekly, monthly, quarterly, and annually.
Lagging safety metrics at TOCDF include counts of LWCs, RIs, and FACs. For recordable injuries, an RIR is calculated each month and used to update the 12-month rolling-average RIR for the facility. Days since the last RI and safe work hours (time since the last LWC) are updated and reported regularly to TOCDF personnel.
TOCDF also utilizes a number of leading metrics. An employee-based safety observation program has been implemented; the resulting metric is the number of observations performed per month, reported on a trend chart. The TOCDF Safety Department performs zone inspections to identify unsafe physical conditions and unsafe work practices. The number of zone inspections completed per month is used as a metric, and monthly histograms are produced showing counts of specific unsafe conditions and work practices. In addition to injury metrics, TOCDF also counts safety near misses and reports this metric on a weekly trend chart.
TOCDF performs total injury analysis on all RIs and FACs. Univariate histograms break down injury counts by a variety of categories (e.g., department, shift, injury type, and day of week). The facility also tracks the aging of safety work orders, including the number of open work orders less than 45 days old and the number of open work orders more than 45 days old. TOCDF submitted a VPP application to the OSHA Regional Office in Denver on September 30, 2008.
Lagging environmental metrics at TOCDF include state-identified noncompliances and self-reported (RCRA and Title V) noncompliances. These are counted on a monthly basis and the 12-month rolling average is updated monthly.
Leading environmental metrics include counts and timing (day of week) of RCRA inspections (performed by operations personnel) and regulatory inspections performed by the TOCDF Environment Department. Inspection findings are summarized in histograms by category (e.g., noncontainerized waste and container integrity) on a weekly basis, and trend charts are generated. In addition, TOCDF counts environmental near misses and reports this metric on a weekly trend chart.
TOCDF tracks the aging of RCRA work orders on a weekly basis, including the number of newly opened work orders and work orders closed. In addition, the trend in number of still-open work orders is given by week. MACT alarms are counted weekly for the metal parts furnace, and weekly counts of the reason for the alarms are charted in a histogram. AWFCOs are tracked for each furnace.
12
Cheryl Maggio, Deputy Project Manager, Chemical Stockpile Elimination, “Chemical stockpile elimination project overview,” presentation to the committee on September 24, 2008.
13
Paul Anderson, Safety Manager, EG&G, “Safety metrics,” presentation to the committee on September 24, 2008.
14
Elizabeth Lowes, Deputy General Manager for Closure Integration, EG&G, “TOCDF environmental metrics,” presentation to the committee on September 25, 2008.
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Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities
TOCDF is a self-certified ISO 14001 facility. Non-regulatory environmental metrics tracked by TOCDF include the following:
Annual natural gas usage,
Water usage,
Scrap metal recycled,
Paper recycled, and
Secondary waste processing/disposal.
Communications at Metrics
TOCDF staff prepares a daily status review and a daily progress report. There is also a weekly newsletter that includes key rates and daily counts. Days since the last RI are included in the daily safety management report that is distributed to all management and through the weekly Safety Action Team publication SAT Newsletter. Safe work hours are communicated very broadly on large signs around the site, the TOCDF intranet, in weekly and monthly management reports, and to all employees on the Safety Action Team. Safety metrics are reviewed on a quarterly basis. While not a metric, safety-related lessons learned are published and distributed to the demilitarization community.
Site-level metrics are communicated to all employees on a weekly, monthly, and quarterly basis and are available on the TOCDF intranet. Metrics are presented to the Site Environmental Leadership Committee, Departmental Corrective Action Review Boards, and the Site Corrective Action Review Boards.
UMATILLA CHEMICAL AGENT DISPOSAL FACILITY15,16,17
The Umatilla Chemical Agent Disposal Facility (UMCDF) is located at the Umatilla Chemical Depot in Hermiston, Oregon. It began destruction operations in September 2004 and currently employs 819 people. Since commencing operations, 35.5 percent of the agent stockpile has been destroyed (1,319 out of 3,719 tons of GB, VX, and mustard). The estimated completion date for chemical weapons destruction is July 2011. This does not, however, include the disposal of hazardous and secondary waste.
Safety and Environmental Performance and Metrics
UMCDF safety statistics can be found in Table 2-1 and environmental statistics in Tables 2-2 and 2-3. 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, and days worked since LWC. On a weekly basis it looks at the 12-month RIR and the LWC rate, FACs, near misses, and the total recordable rate. On a monthly basis it reviews the OSHA 300 log, the project’s total work rolling RIR, operations and maintenance rolling RIR, operations and maintenance subcontractor RIR, hours and days without a LWC, and FACs.18
Additionally, plant managers and the safety manager conduct and document weekly safety inspections of targeted work areas. Department safety professionals also conduct and document weekly safety assessments. The goal is for 80 percent or more of the assessments to result in no findings, and 100 percent of any findings to be resolved within one week. First-line supervisors and the shift safety representative conduct monthly inspections of work areas under their control.
UMCDF also uses a variety of environmental metrics. The metrics reviewed include self-reported non-compliances, surveillances, AWFCOs and engineering stop feeds, RCRA aging open items, regulatory and internal inspections, and MACT exceedences.
Safety metrics are reviewed daily, weekly, and monthly. The reviews are used for the annual award fee program and to identify areas of opportunity. Areas of opportunity identified are
Better reporting of near misses;
Behavior modification to help reduce unsafe acts;
More attention to detail; and
Increased identification and hazard control when the work involves fingers and hands, focusing on sharp objects and bodily motion.
15
Cheryl Maggio, Deputy Project Manager, Chemical Stockpile Elimination, “Chemical stockpile elimination project overview,” presentation to the committee on September 24, 2008.
16
Emily Milliken, Safety Manager, URS, “Safety metrics,” presentation to the committee on September 24, 2008.
17
Jim Wenzel, Environmental Manager, UMCDF, “UMCDF environmental metrics,” presentation to the committee on September 25, 2008.
18
The OSHA 300 log is the document where recordable injuries are noted and documented. For more information, see http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=12805.
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Communication of Metrics
Safety metrics are communicated in a variety of ways. One is a daily injury and illness report containing information on near misses, FACs, and recordables for the last 24 hours. A weekly operations analysis includes a review of the 12-month rolling RIR along with metrics on which the award fee is based: RIRs, FACs, and near misses. A weekly safety synopsis is delivered to project management, the field office, and the corporate office. In addition, there is a monthly report, which is a contract deliverable, including data from the OSHA 300 forms, a summary of near misses and FACs, and contract data requirements. A monthly corporate report is provided to the entire site via a Web site. A monthly report on injury trends by department is posted to the Web site and sent to management for use in identifying injury trends and controlling injuries. The annual trend report posted to the Web site contains information on root cause, hazard category, body part, day of week, time of injury, shift, department where near misses occur, and injuries and illnesses.
Environmental metrics are communicated to the Environmental Process Improvement Team, to quarterly meetings of supervisors and the project general manager, to “welcome back” briefings every Tuesday, and articles in Today.19
19
Today is UMCDF’s internal communication document.
