PROCESS SAFETY INCIDENTS METRIC

Flowchart provided by The American Chemistry Council (ACC) 2012 Process Safety Incidents (PSI)

Decision logic chart

There is no federal requirement for the collection of process safety information, but the number of process safety incidents has long been recognized as one indicator of how safely companies operate their chemical processes. Sharing the number of reportable process safety incidents for each member company enables others in the industry to benchmark, thereby driving performance improvement across the entire business of chemistry.

Metric Definitions and Instructions

Measurement

Key Definitions

Process Safety Incident: An incident is reportable if it meets all three of the following tests:

1)chemical/process involvement, 2) reporting threshold, and 3) location. Each is described in detail below.

Chemical/Process Involvement Test: An incident satisfies the chemical/process involvement test if the following is true:

An employee injury that occurs at a process location, but in which the process plays no direct part, should NOT be reported. The intent of this criterion is to identify those incidents that are related to process safety, as distinguished from personnel safety incidents that are not process-related. For example, a fall from a ladder resulting in a lost workday injury is not reportable simply because it occurred at a process unit. However, if the fall resulted from a chemical release (or caused a release to occur), then the incident is reportable.

Reporting Threshold Test: An incident satisfies the reporting threshold test if at least one of the following is true:

Examples of days away from work or fatality cases that would be reportable include: a burn from steam released during cleaning, a physical injury from a cap blown off by pressure during a pressure test, or a chemical burn from a spill while taking a sample.

Examples of days away from work or fatality cases that would not be reportable include: a fall from an elevated work station while performing maintenance, a burn from a fire in a laboratory or office building, or a confined-space asphyxiation. None of these cases is directly due to the release of energy or material from the process.

Notes:

  1. The list of Extremely Hazardous Substances is found in the appendices of 40 CFR 355.40. Please note that the extremely hazardous substances listed at 40 CFR 355 (emergency planning and notification under EPCRA) is not the same as the hazardous substances list at 40 CFR 302 (reportable quantities and notification requirements for hazardous substances under CERCLA).
  2. The 5,000 lbs of flammable material is the combined total of the release it does not have to be all one material. The definition of flammable materials is based on OSHA regulations at 40 CFR 1910.106. Flammable materials that should be reported are those with flash points below 100°F (Class I). Flash point information can be found in NFPA 325 and in Material Safety Data Sheets (MSDS).
  3. Episodic releases associated with a single initiating event should be considered a single incident.
  4. Episodic releases specifically permitted by EPA or designated state agencies are not reportable process safety incidents. In addition, releases that are part of normal, routine operations, e.g. NOx formed by flaring, are not reportable.

Location Test

An incident satisfies the location test if the following is true:

All reportable incidents occurring at a location will be reported by the company that is responsible for operating that location. This applies to incidents that may occur in contractor work areas as well as other incidents. At tolling operations and multi-party sites, the company that operates the unit where the incident initiated should file the incident report.


Examples and Frequently Ask Questions regarding the Reporting of Process Safety Incidents

To improve consistency in Process Safety Code Measurement (PSCM) incident reporting, the following clarifying questions and answers have been provided. If you have similar questions, please forward those questions to: help@lcasafe.org.

The answers to the following questions are based upon the majority opinion of the 20-plus members of the ACC Process Safety Subgroup.

Releases from Flares and other Control Devices (e.g. scrubbers):

Q1: If the emissions from a permitted emission source (e.g., flare or other control device) exceed the reporting threshold during the normal or permitted operation of that device (e.g., NOx emissions exceeding 10 lbs.), should this be counted as a PSCM?

A1: If the emission levels are at or below the permitted levels for that emission source or control device, it would not be counted as a PSCM. If the emission levels exceed the permitted levels by an amount greater than the Reporting threshold (e.g., 10 lbs. of NOx or 10 lbs. for Chlorine) – it would be treated as a PSCM. For example, if a flare stack has a permitted NOx emission level of 1000 lbs. per day, yet actually emits NOx in excess of 1010 lbs. in a given day, this would be counted as a PSCM.

Q2: If unburned hydrocarbons are released from a flare due to either incomplete combustion (i.e., poor operation of the flare) or flameout of the flare, is it counted as a PSCM?

A2: If the amount of unburned hydrocarbons released exceeds a 5000 lb. quantity (as defined in the chemical release portion of the PSCM definition), it would be counted as a PSCM.

Loss of Primary Containment:

Q3: If a spill or release in excess of the reporting threshold occurs, but all or a majority of the release is contained within a secondary containment device (e.g., dike around the tank) or is collected and sent to a treatment system (e.g., scrubber or waste treatment system) such that less than the reportable amount is released to the environment, is this counted as a PSCM?

A3: If the release is an episodic (i.e., sudden) release from the primary containment (e.g., vessel, pipe) greater than the reportable threshold quantity of material, it would be treated as a PSCM regardless of whether it is collected and/or treated unless the release is a controlled release directly through a PSV or vent/drain system into a fully contained treatment system such as a flare (see above) or scrubber system which is specifically designed for these controlled releases. [Note: it is recognized that this interpretation of PSCM reporting rules is more conservative than the EPA CERLA reporting requirements. However, this reporting approach more appropriately identifies and reports incidents where at least one layer of protection of the process has been exceeded – thus should be viewed as a process safety concern.]

Q4: If a chemical release exceeds the RQ shown in Attachment A; however, it occurs over a long period of time, should this be counted as a PSCM? (e.g., long-term heat exchanger tube leak which slowly releases a chemical shown in Attachment A, or 5,000 lbs. of flammables, into the cooling water system).

A4: For the purpose of the ACC PSCM reporting, we will use a “24-hour” rule. If a release does not exceed the RQ level over any 24-hour period, it would not be treated as a PSCM.

Fires or Injuries not caused or resulting in a chemical release:

Q5: If a fire within the plants results in >$25,000 in damages, but is neither caused by a chemical release nor resulted in the release of chemical in excess of the RQ, does this count as a PSCM? For example, a fire of an electric motor or motor control system, a fire of a cooling tower, etc.

A5: As a general rule, a fire is reported as a PSCM only if the fire is caused by a chemical release or results in a release in excess of the RQ. Examples are listed below:

  • If an electrical fire, loss of electricity, or any other loss of utility occurs which may cause a plant shutdown and possibly incidental equipment damage greater than $25,000 (e.g., damage to reactors or equipment due to inadequate shutdown) but does not create a chemical release greater than the RQ, or cause a fatality or serious injury, it would not be treated as a PSCM.

  • A bearing fire, lube oil system fire, electric motor failure, or similar fire occurs which does not create a chemical release greater than the RQ, or cause a fatality or serious injury, it would not be treated as a PSCM.