API ANSI RP 754
Implementation Conference Call
September 26, 2011
Purpose of RP 754 Conference Calls
• To drive broad adoption of API 754 throughout the
Refining and Petrochemical industries
• To drive consistency in Tier 1 and 2 metrics reporting in
order to establish credibility and validity
• To share learning's regarding the effective
implementation of Tier 3 and 4 leading metrics
2
2010 PSE Data Collection - Overview
• Both API and NPRA are collecting RP 754 data
• You do not have to be an API or NPRA member to submit RP
754 data and receive their report
• Refineries and petrochemicals may submit data
• Only those submitting data receive the report
• 2010 statistics:
API (US Refining only):
• 17 companies reported
• 76 refineries
NPRA (US Refining only):
• 39 companies reported
• 107 refineries
2010 PSE Data Collection - Conclusions
• Both API and NPRA 2010 PSE data reports are now
issued.
• The “PSE Rates” are different because there are two
different data populations.
• Proceed with caution when using these industry PSE
rate numbers for internal benchmarking purposes
for a few years until data consistency and validity is
deemed sufficient.
Goal is to make a US Refining industry-aggregated “PSE Rate” publically
available in 2013.
Data Inconsistencies in 2010 submittals
•
Three areas from the 2010 data collection
require further education to ensure data
consistency:
1) PRD Discharges
2) Contractor hours
3) Consequences
Data Inconsistencies – PRD Discharges
Two ways to have a PSE involving a PRD (Pressure Relief Device):
1.
A LOPC from a PRD that results in:
•
•
•
•
or
•
•
2.
an employee, contractor or subcontractor “days away from work” injury and/or fatality; or
a hospital admission and/or fatality of a third-party; or
an officially declared community evacuation or community shelter-in-place; or
a fire or explosion resulting in greater than or equal to $25,000 of direct cost to the Company
an employee, contractor or subcontractor recordable injury; or
a fire or explosion resulting in greater than or equal to $2,500 of direct cost to the Company
A PRD discharge that both exceeds the Threshold Quantity (Tier 1 or 2)
rate* and has one or more of the following four consequences:
•
•
•
•
Liquid carryover
Discharge to a potentially unsafe location
On-site shelter-in-place
Public protective measures (e.g. road closure)
* The Threshold Quantity rate is calculated at the PRD.
PSE Tiering for Releases from Pressure Relief Devices
(PRDs)
When one of
these releases,
and causes one of these:
- an employee, contractor or subcontractor “days away from work”
injury and/or fatality; or
- a hospital admission and/or fatality of a third-party; or
- an officially declared community evacuation or community shelter-inplace; or
- a fire or explosion resulting in greater than or equal to $25,000 of
direct cost to the Company
it is a Tier 1 PSE.
But if it causes one of these:
- an employee, contractor or subcontractor recordable injury; or
- a fire or explosion resulting in greater than or equal to $2,500 of direct
cost to the Company
it is at least a Tier 2 PSE, but it might still be a Tier 1
PSE if....
When one of
these releases,
to here,
here,
or here,
and causes
or, discharge to a potentially hazardous location,
or, an onsite shelter-in-place
or a road closure
then you must estimate
the quantity released
through the Pressure
Relief Device to determine
the PSE Tier.
If the quantity
released from this
is greater than this,
the event is a Tier 1 PSE.
If the quantity
released from this
is greater than this,
the event is a Tier 2 PSE.
When one these
releases,
and none of the consequences on the previous
slides occurs,
record the event as a Tier 3 PSE regardless
of the quantity released.
Data Inconsistencies – Contractor Hours
• Contractor hours include:
– Embedded contractors
– Specialty contractors
– Project hours (if not major construction)
• Contractor hours do not include:
– Delivery drivers
– Large-scale projects that are typically fenced-off
and not connected to the existing process (i.e.
major construction)
Data Inconsistencies - Consequences
•
List all consequences for the Tier.
•
–
Exception: If the event is a fire or explosion, the
chemical-released quantity is not required to report.
•
•
e.g. list both Threshold Release Quantities and Number of Days
Away from Work or Fatalities
Basis: Chemical released is consumed by the fire/explosion.
However, if the fire/explosion results in secondary release points
the site shall report threshold quantities of other chemicals
released.
Do not list Tier 2 consequences in Tier 1 except for
those related to human impact (i.e. employee,
contractor, or sub-contractor recordable injuries ).
International Adoption
•
•
•
API and NPRA are reaching out to
international organizations to encourage
data collection alignment.
However, each organization will have its own
report out.
Examples: ACC, CEFIC, CONCAWE, UKPIA
RP 754 - Broad Access [Nationwide] Public Reporting
API & NPRA Public Reporting Plan – Tier 1 and 2
Annually, each Company publicly reports:
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2010 data – Implementation
2011 data – Data validation
2012 data – Industry aggregated result (public)
2013 data – Industry and Company blinded results (public)
2014 data – Industry and Company transparent results (public)
NOTE - Tier 2 reporting may lag Tier 1 by one year
2011 Data Collection
• Improvements have been made to the data collection
spreadsheet
• Still one spreadsheet used by both API and NPRA
• Spreadsheet will be distributed by 4th quarter 2011 for
sites to begin collecting 2011 data
Conclusions
• It will take a few years to ensure data consistency and
validity - as was expected.
• Don’t over-focus on the 2010 PSE rate but instead build
confidence in your data through consistent reporting.
• Trends over time are more valid than specific rates.
• The true value comes from determining PSE causal factors,
implementing corrective actions, and sharing lessons
learned to prevent future events.
API website
• API RP 754 Fact Sheet
• Series of four webinars presented in fall 2010 (available for
viewing)
• Listing of FAQ’s that help you properly classify a PSE
• API Guide to collecting PSE data
• Read-only access to API RP 754
http://www.api.org/ehs/health/measuring/index.cfm