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

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Summary The U.S. Army’s Chemical Materials Agency (CMA) and its contractors have responded to this encourage- is responsible for the destruction of the nation’s chemi- ment, and the operating CDFs enjoy exemplary safety cal agent and munitions stockpile, except at two sites records at this time. Table 2-1 gives site injury rates as that fall under a separate Department of Defense pro- of October 31, 2008, and Tables 2-2 and 2-3 provide gram. To meet this goal, CMA has built and operated environmental statistics for the sites. Even so, the Army incineration-based chemical agent disposal facilities and the CDFs are desirous of further improving safety (CDFs) on Johnston Atoll, in the Pacific Ocean; near and environmental performance and have asked the Anniston, Alabama; Pine Bluff, Arkansas; Tooele, National Research Council to review the safety and Utah; and Umatilla, Oregon. It has also built and oper- environmental metrics used by the CDFs. ated neutralization-based CDFs near Aberdeen, Mary- Specifically, the ad hoc Committee on Evaluation land, and Newport, Indiana. The CDFs on Johnston of the Safety and Environmental Metrics for Potential Atoll and Aberdeen have been closed, and the CDF Application at Chemical Agent Disposal Facilities was near Newport is undergoing closure. The CDFs near established to carry out the following tasks: Anniston, Pine Bluff, Tooele, and Umatilla are still in operation. • Review and evaluate existing safety and environ- When Congress mandated the destruction of the mental metrics employed at CMA facilities, chemical weapons stockpile, it specified that destruc- • Examine commercial and industrial operations for tion operations must be executed with maximum pro- potentially applicable safety and environmental tection for the workers, the public, and the environment. metrics, and In the initial years of disposal operations, the National • Assess new initiatives at national organizations Research Council’s longtime Committee on Review (i.e., National Safety Council, Occupational and Evaluation of the Army Chemical Stockpile Dis- Safety and Health Administration, etc.) that could posal Program, in its reports, repeatedly encouraged be used by CMA. the Army and its contractors to pay attention to safety and to engage in continuous improvement. The Army As part of their ongoing effort to improve worker safety and environmental compliance, the CDFs employ a variety of metrics to measure performance and guide The stockpiles at the Blue Grass Army Depot, in Kentucky, and improvement efforts. Table 3-1 gives the categories of the Pueblo Chemical Depot, in Colorado, fall under the Assembled safety metrics used at the CDFs. The metrics include Chemical Weapons Alternative Program. both leading indicators, which are forward looking In 2006, the Committee on Review and Evaluation of the Army and seek to identify problems before they occur, and Chemical Stockpile Disposal Program was replaced with the current Committee on Chemical Stockpile Demilitarization. lagging indicators, which are retrospective and lead  

 Evaluation of Safety and Environmental Metrics to corrective action after injuries or incidents have Recommendation 1. The chemical agent disposal occurred. This committee reviewed the status of safety facilities should continue the process of continuous and environmental programs and performance and the improvement to achieve levels of safety and environ- metrics used at the Anniston, Newport, Pine Bluff, mental performance equivalent to those achieved by Tooele, and Umatilla CDFs. comparable industries. Third-party certifications should The committee noted that all CDFs engage in be continued and encouraged. All chemical agent dis- extensive data gathering, but the specific metrics posal facilities should comply or obtain the Star des- derived from the data varied considerably from one ignation of the OSHA Voluntary Protection Programs, facility to the other. This is not surprising, since each and all should continue to comply with the most current CDF has its own destruction mission, geography, and ISO environmental management standards. culture. The committee gathered information on metrics Finding. The terminology used to describe various and assessed new initiatives used by other government metrics and related activities is not consistent across organizations, industry as a whole, and professional the chemical agent disposal facilities or within the organizations, with an eye toward identifying metrics Chemical Materials Agency. This makes it difficult to that might be useful to the CDFs. The government compare the sites in a meaningful way or to accurately organizations surveyed include the Department of the analyze programwide data. Army (other than the CMA) and the Federal Aviation Administration. The private entities surveyed include Recommendation 2. The Chemical Materials Agency the Center for Chemical Process Safety of the American should require the development of a system of clear Institute of Chemical Engineers (AIChE), Corning, and consistent definitions that can be applied across Dow Chemical, Motorola, and Praxair. Many of the all chemical agent disposal facilities. Although each metrics employed by these organizations are detailed in facility should have the flexibility to apply safety and Appendix B but not discussed in the body of the report. environmental approaches that meet any unique needs, The committee believed that discussing the results of its a particular metric should be defined consistently to fact finding and assessment would be more appropriate allow for direct comparisons among the facilities. than recommending specific metrics. The terminology used in this report is defined in the Finding. The chemical agent disposal facilities collect glossary that makes up Appendix A. While the defini- extensive data on injuries, and most engage in some tions in the glossary may not necessarily conform to injury analysis. However, no facility takes full advan- those of the CDFs or other organizations, the committee tage of the data to create additional and potentially believes that they will afford the reader a clear idea of more sensitive metrics. The focus has been on lost the meanings intended here. workday cases and the recordable injury rate. Other For the reader’s convenience, the committee’s find- possible metrics, such as medical treatment cases and ings and recommendations, located in Chapter 5, are first aid case rates, are not universally employed or presented here as well. communicated. The analyses simply list outcomes and incidental variables (e.g., department and day of week) Finding. Safety and environmental performance at the and as such are not very useful metrics. Further, they operating Chemical Materials Agency chemical agent fail to include some essential information such as the disposal facilities has continuously improved and is task being performed when the injury occurred and the currently significantly better than the national average location within the facility where it took place. industry as measured by lost workday cases and the recordable injury rate. Three of the five facilities are Finding. In addition to collecting data on injuries, all compliant with third-party accreditation requirements. chemical agent disposal facilities collect extensive All but one of the facilities have been certified with the incident data, but there does not appear to be an inci- Star designation by the Voluntary Protection Programs dent investigation system that would enable the sites to of OSHA and all conform to the International Organi- analyze the data and extract from them indicators for zation for Standardization (ISO) 14001 environmental preventive action. Insofar as they are reported, “met- requirements. rics” are simple lists. 

SUMMARY  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. 

 Evaluation of Safety and Environmental Metrics 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.