U.S. Chemical Safety and Hazard Investigation Board 

2175 K Street NW, Suite 400, Washington, DC 20037-1809 

Phone 202-261-7600 Fax 202-261-7650 

www.csb.gov 

Gerald V. Poje, Ph.D. Carolyn Merritt Andrea Kidd Taylor, Dr. P.H. 

Board Member Chairman and CEO Board Member 

Irv Rosenthal, Ph.D. John Bresland 

Board Member Board Member 

MEETING NOTES 

ROUNDTABLE ON DEVELOPING IMPROVED METRICS ON 

ACCIDENTAL CHEMICAL PROCESS RELEASES

Washington, DC November 14, 2002 

The meeting at convened at 9:40 AM 

Mr. Charles Jeffress, CSB COO, welcomed the participants to the meeting and 

summarized the purpose of the roundtable and agenda for the day. 

Ms. Carolyn Merritt, CSB Chairman, presented opening remarks and goals of the 

roundtable, summarized below: 

The roundtable discussion provides an important opportunity for regulators and 

industry. Although the goals are the same, EPA, OSHA, CSB, and industry lack a 

single yardstick for measuring our performance in the area of continuous safety 

improvement. It became apparent in the CSB Reactives Study that although each 

agency has its own database, none provides sufficient information to quantify 

safety performance metrics. Intuitively, we feel safety is better but we have no 

objective method to measure our progress. Better data will help improve safety. 

The thoughts and observations captured in this meeting are important to the 

development of the metrics needed to measure regulatory and industry 

performance in continuous safety improvement. 

Mr. Craig Matthiessen, EPA Sr. Chemical Engineer, welcomed participants on behalf of 

EPA with the following comments: 
The new agency Strategic Plan is due out in December 2002. It emphasizes that 

outputs will be results driven. Accurate metrics are key to the ability of the 

agency to measure performance. EPA is fully committed to working with 

industry and the other agencies to identify and implement improved metrics. 

Mr. Frank Frodyma, OSHA Policy Director, welcomed participants on behalf of OSHA 

and stated: 

The OSHA Strategic Plan is due out in March 2003. Although the chemical 

industry has low occurrence of work-related fatalities, injuries and illness, the 

consequences of an accident can be significant. The agency needs metrics to 

determine where to apply their resources such that they maximize their 

effectiveness in improving worker safety. OSHA is fully committed to working 

with industry and the other agencies on this important topic. 

Dr. Kathleen Rest, NIOSH Deputy Director for Programs, was introduced as the 

Moderator/Facilitator of the roundtable and introduced Dr. Michael Elliott for the first 

presentation. 

Dr. Michael Elliott, Wharton School, presented “Review of Present RMP*INFO Data and 

System.” He summarized how the existing data are being used for accident 

epidemiology. Shortcomings of using the database include: 

The D&B numbers entered are often in error. The identity of the company 

owning the covered facility/process is needed to conduct financial analyses of 

RMP covered facilities. A possible solution is to use both the D&B number and 

the stock market ticker symbol. 

There is no linkage to the OSHA reports. Possible solution is to add the OSHA 

facility number. 

It is difficult to evaluate community demographics using only latitude/longitude 

data, some of which are entered inaccurately. Possible solution is to use the 

Census Tract number. 

Trend analysis cannot be effectively performed with the current five-year 

reporting period, as some facilities drop out of the database during that time. 

Possible solution is to require annual reporting. 

Dr. Irv Rosenthal, CSB Board Member, presented “Improved Metrics for Chemical 

Process Safety,” a strawman proposal that was distributed to participants prior to the 

meeting. The strawman argues that available no data systems cannot generate metrics 

that can be used to evaluate progress in preventing (reducing) the number of chemical 

releases and incidents that have led to the current environmental laws and regulations. 

Better metrics will also help the CSB direct their limited resources at those industry 

sectors that pose the greatest risk. Metrics are needed to answer the following questions: 
1. Are the incident rate and frequency of pertinent accidental releases 

increasing or decreasing? 

2. Are the consequences of such accidents increasing or decreasing? 

3. What industry sectors pose the highest risk of an accidental release? 

Dr. Rosenthal proposes two changes to the EPA RMP rule. 

 Require annual reporting of accidental releases at covered facilities. 

 Add a data element to capture approximate information on the level of 

operation of the facility during the year. 

He also suggested that this might be an opportunity to add other “practical” short term 

and long-term improvements in the database such as: 

 Information on whether the process involves batch, continuous, or storage 

operations. 

 Inclusion of OSHA Occupational Injury and Illness information (OII) for 

the covered process 

 Census Tract number 

 OSHA facility number 

 Stock Ticker Symbol 

Any new or improved database must meet the “Practicality” criteria: 

 Will provide the data needed to generate a minimum set of metrics useful 

to the Board 

 Has strong stakeholder support 

 Can be implemented within three years 

 Is acceptable to Congress, OMB, EPA, and OSHA 

Roundtable Participant Comments 

An important concept in data collection and analysis is differentiating between tracking 

just “improvement” (e.g., the fatality rate has decreased over the past X years) and 

tracking “what caused the improvement.” 

Need to establish short-term and long-term goals. Short-term goals (1-3 years) must 

consider the long-term value. Keep goals simple and achievable. Are the two proposed 

changes too simple and will working on them interfere with long-term improvements? 

The CSB should look at the bigger picture and improve existing systems, not create new. 
Data Quality - More frequent reporting should help improve the quality of data. Need to 

clarify and/or add guidance on the definitions of when a release must be reported. Need 

better training of the users. 

Difficult to create a single system that fits all stakeholder needs. Causal factors managed 

on a national level are problematic. 

Data collection regulations must carefully consider Confidential Business Information 

(CBI). Annual production rates, up-time, annual sales volume or other production related 

metrics are likely to generate CBI challenges. 

The regulatory reporting burden on small business is significant. In the event of an 

incident, there are “massive reporting requirements.” Consideration should be given to 

conducting a study of all available/required data collection tools before deciding to 

implement proposed changes to RMP*INFO. 

Efforts should be focused on understanding the causes of accidents, thereby eliminating 

fatalities, injury and illness, and less on trend data. 

RMP - Is the threshold bar on reportable incidents set too low/high? Current reporting 

requirements fail to capture the “good performers” data. Need to improve the definitions 

of reportable incidents, process change, etc. 

Much discussion on other types of data could be valuable, in particular Near-Miss (NM) 

data. NM data could be useful in preventing accidents through continuous improvement 

from lessons learned. FAA has a voluntary and anonymous NM data collection system in 

place that is managed by a third party. However, unlike the airline industry NM 

reporting requirements would be difficult to standardize across all of the chemical 

process industries (CPI). Subjectivity would be a problem. NM data collection might 

better be managed through industry groups. 

At the conclusion of the morning comment session, consensus was that improvement in 

frequency of data collection and data quality is definitely needed and would be useful to 

all stakeholders. 

Afternoon Participant Discussion 

The afternoon focused on discussing other improvements or alternatives that might be 

useful. It began with a summary of EPA and OSHA rulemaking processes. The process 

can be relatively short (9-12 months) if changes are simple and broadly supported, or it 

can be very arduous and protracted if changes are more burdensome and stakeholders are 

divided. Simple changes are good, but should also consider the opportunity to make 

additional improvements in same rulemaking. Need to address four items: 

 What does the proposed change accomplish? 

 What are the consequences of not making the change? 

 Are there other options? 
 What is the cost benefit? 

An option might be for OSHA to consider augmenting the IMIS database to achieve the 

proposed improvements. This could be done, but would involve a major database 

enhancement. 

Short-Term data elements and reporting improvements were discussed. They include: 

1. Instantaneous reporting of severe incidents (e.g., less than 30 days as opposed to 

six months) using simplified/unified/consistent reporting requirements. 

2. CSB facilitate industry groups to develop method(s) to collect aggregated data. 

3. Provide a unique facility identifier with data submission to link multiple 

databases. 

4. Establish the order of importance of activities: 

a. Consistency and quality 

b. Report interval 

c. Improved training 

d. Expand non-prescriptive criteria 

e. Collect meaningful population data 

f. Collect normalizing data 

5. Collect Stock Ticker and Census Tract information 

6. Develop a smart data entry process that performs basic error checking of data. 

7. Use publicly available, easy-to-use data to correct the denominator for the 

“denominator” rather than CBI. 

8. Differentiate between “normal process data” and “maintenance by others.” 

9. Consider use of economic activity data in the Dept of Commerce census of 

manufacturing data for each NAICS for each sector, FTE data, etc. 

10. FAA model for Near Miss tracking is an excellent target for extra-regulatory 

implementation. 

11. Need to address how to manage dynamics of facilities with multiple processes / 

multiple covered chemicals. 

12. Revisit the RMP criteria for reportable incidents. Consider publishing guidance 

on “injury,” “shelter-in-place,” and “property damage.” Consider reducing 

thresholds for reportable incidents and differentiating thresholds for flammable 

and toxic incidents. 

The above list was consolidated into the following Short Term list of key target areas. 

Short Term Target Areas 
1. Shorten the reporting interval for RMP*Info incident reporting 

2. Provide guidance on defining incident thresholds. 

3. Work with industry associations 

4. Add unique facility ID# to existing databases 

5. Consider floating additional data elements in proposed rulemaking. 

6. Evaluate benefit/impact of reporting frequency on small businesses. 

Intermediate to long-term activities requiring five or more years to accomplish are 

summarized as follows: 

1. At industry level, use existing precursor information (e.g., near miss data) 

and development of leading indicators for plant, company, industry, and 

group use in driving continuous improvement. Sharing Lessons Learned 

is critical to achieving these long-term objectives. A good start would be 

sharing within the company. The Wharton School has held NM 

definitions workshops. This could be useful starting point to reducing NM 

complexity. 

2. Develop a single-point reporting database. (Note: The Mary Kay 

O’Connor Process Safety Center has reviewed available databases and 

will submit their list of recommended improvements to each of the 

database owners.) 

The medium to long-term goals must be considered when addressing the short-term target 

areas. These goals are: 

Medium-Long Term Goals 

1. Industry should develop leading indicators (precursor activities) to be 

used for achieving continuous improvement. 

2. Industry should establish protocols for sharing lessons learned. 

3. Compare existing databases to improve data collection and eliminate 

duplication. 

4. Consider developing a model similar to the FAA model for reporting 

near miss data. 

5. “One-stop” accident reporting in place of separate reports to multiple 

agencies on the same incident. 

At the conclusion of the discussions, Charles Jeffress and Kathy Rest summarized the 

day’s activities: 

Sharing of industry data with all stakeholders can be a valuable tool in continuous 

safety improvement. 
The positive reaction to the strawman proposal and the energetic participation 

from the roundtable attendees provided very good feedback to OSHA and EPA on 

the commitment from the stakeholders to long-term regulatory action. 

There appeared to be strong support for more frequent reporting to RMP*IFO of 

accidents covered under the EPA RMP standard: annual or even more frequently 

rather than every 5 years as presently required. 

Industry is encouraged to take the lead on the short and long-term activities. The 

roundtable format, sponsored by CSB or others, may be a useful format. 

The CSB is responsible for investigating incidents to establish the root causes and 

develop 

recommendations to prevent future incidents. Although studies of accident data 

contained in RMP*INFO and similar databases may not in and of themselves 

directly result in recommendations for safety improvements, the CSB needs these 

studies to effectively steer its investigative activities toward industry sectors with 

the highest risk consequences. 

The CSB will consider the usefulness of Near Miss data in selecting, conducting, 

and analyzing incident investigations. 

The roundtable was adjourned at 3:30 PM. 

Notes prepared by John B. Vorderbrueggen, PE CSB Office of Investigations