Roundtable Meeting — June 2-3, 1999

Irv: Don’t keep records and if we are looking at a public health problem which is greater than just the particular well performing companies, incidents data is necessary.

Bob Perry: Center for Chemical Process Safety. Following up on that last comment, the discussion, and that’s where we’ve been led, is how many times do people get run over. I would suggest that chemical process safety is amenable to process safety management. The one person that is not represented here is Peter Drucker, but this is basically a management problem. I wonder if rather than trying to approach it from how many people are being run over, we should drop back and try to measure the application of management systems. That’s very amenable to measurement if the company has a management of process safety management structure than they should be measuring not how many things blow up, but how many times they deviate from that management structure. Because that is taking two steps backward and away from the accident. And I would submit that we should be looking at how well are we applying a management structured process safety.

Irv: We’ll discuss that in point four. And I’m just going to take one last comment from Paris if he wants to make it before we move on because I’ve got about thirty questions in about fifteen minutes each, or I think I’ll overrun my time.

Paris from Factory Mutual: I just wanted to point out that Factory Mutual does have a large database, There are a couple of significant problems in that we are only collecting data that is reported to Factory Mutual, which means it involves a certain deductible. So that’s perhaps skewed. The other significant thing I wanted to mention is that I guess at this point Factory Mutual is not at liberty to share that data. I will share with you some data, which has been sanitized tomorrow.

Irv: Well I’m afraid to ask the second question on this topic. The second question, do we have a measure now of all the increased regulatory activities, OSHA’s PSM standard has been in place for a while, has it resulted in the savings that were projected in your financial analysis, was it a billion dollars that was figured in the PSM rule? Potential savings in the economic analysis?

Ray Skinner: I’m not prepared to answer that as such, but I can guarantee you one thing, it has been well worth the effort in the savings of lives.

Irv: I believe you, but I would have to say that if I presented that answer at a technical meeting I would not be able to maintain it. I think we’ll have to cut that off Dave, to go onto the next one because this is only one of seven. Let’s go on then and say that I think that we need to consider an actual data system that will allow us to accomplish these points. You may want to do more or less, we want to be able to know the incidents of things the extent of the consequences in order to answer the question of whether what we’re doing is accomplishing what we’ve projected to do. But more than that we need a database that will allow us to do for accidents, epidemiologically, what we have done so powerfully with regard to disease. Where we have been able to uncover disease factors. The relationship between blood pressure and heart attacks or between weight and cholesterol, have been based on epidemiological studies that have related incidents and outcomes to the demographics of the population. We do not have such a database now. I suggest that’s something we might consider. The nearest thing we have to it, forthcoming, if we don’t louse it up with security and other concerns, is the RMP info database. Alright lets go on to the second goal, which I think addresses some of the problems raised by John and others, is a near miss data system. We have a problem with respect to the reporting of near misses. The problem is one of these things that while we say we want to hear from you, in many organizations the guy who raises near misses is the troublemaker. And unconsciously he is resented. I raise this question to you, is the problem of collecting near misses on a company basis one that each of you think is solved, I think John has answered that in part, but Dave do you want to comment on that?

Dave: I am quite confident that if I asked what are we talking about, near misses, that I would get, if I went around the room here, a whole hodge-podge of answers that a lot of which were not similar.

Irv: Anybody here familiar with the civil aviation and aeronautics administration’s system for collecting accident reports and near misses anonymously. Jerry do you want to comment on it?

Jerry: Only question in the data at one time, if two pilots came close, two planes came close, one was guaranteed to lose their license. So, in the data that you presented, very few reported it. They’d land, talk it over a cup of coffee, then decide neither one was going to report it and go on. Now that you have a system where you’re not going to lose your pilot's license or you’re not going to be penalized, people are willing to report that stuff. That’s going to be a tough hurdle, What we’re talking about. Reporting to the government, and reporting to all the other organizations that want to look and count data and report on the performance of companies.

Irv: Thousands of incidents are reported by people who are at risk because the system has worked to preserve them anonymously. It’s searchable; it allows people to learn about equipment failures and near misses and accidents that would not show up in a public nature because if you have a release of a flammable and there is no admission, other than if it’s a reportable you have to turn it in anyway, but otherwise no one knows about it. If the incident is the failure of the pumps at the Shell Company, the one’s that were connected with their explosion when the impeller blew out the seal had been publicized it might have prevented a reoccurrence. This is just a question that has to be raised with what it is we are doing here.

Makris?: So you know I am a big believer in the issue of near misses perhaps helping us to avoid future non misses. One thing I’m curious about is, Jerry just mentioned reporting to government agencies, what has prevented the industry itself from a powerful and cohesive effort to exchange anonymously or however, near-miss information., you don’t have to report it to OSHA, don’t have to report it to the EPA, report to each other, presumably there is no public liability if an event didn’t happen and therefore there was no harm. Presumably, it is possible to have an objective discussion about a near miss. Presumably what held in my place might not hold in yours, therefore the accident might happen at your place. If you knew that there was another probability you might be able to fix it. I’m wondering what the block is, I realize what the government block is. We don’t have the authority, legislation, all that stuff. But what is the block within the private sector for developing some powerful near miss activity?

Irv: Anyone want to respond to it? I give you one instance in which I belong to a technical association, in which lawyers felt that the accumulation of the file of materials might present the problem with regard to future potential liabilities, but that’s an issue that ought to be discussed. Let’s hear about it.

Steve Cable: I know that in our case, the biggest roadblock in front of our members is job fear. They are very afraid of retaliation. Very few cases, even though an anonymous report can be made, there are few cases that somebody can’t figure out at the plant level or where it had come from ­ at least what department, what work group, that type of thing. The whistle blower protection that’s available is very limited, very ineffectual in actual practice, and I think people are very afraid of retaliation.

?: I would agree with the comment about attorneys. We’ve all got them, and unfortunately, it’s not going to make a difference. Some of this has been going on there is a group called the international process safety group that was set up, actually after Flixbourough, many, many years ago, there’s about 40 member companies, it’s not extremely prohibitive to belong. I think it’s about 1000 pounds a year, it’s headquartered out of Britain. We don’t bring our attorneys and there are some pretty frank discussions about near misses and about incidents. But in keeping with what Irv said, there’s not a lot of notes taken, there’s a lot of learning, but again that’s maybe 40 of the major chemical producers in the world.

Irv: I’ll go on with the next subject David.

Makris?: I just want to second the fact that the problem is often internal, in terms of all of a sudden if you really get to reporting incidents management who like to be happy on Monday mornings and go home nice on Friday nights there’s all this crap going on in the plants. They say, " My God! Stop all these incidents!" Well you know, you just spent a year trying to uncover them. And once you finally uncover them it scares the hell out of management. Management doesn’t want to hear about it anymore. And the real key is how can we, in terms of where we’re going, how can we educate management to the fact that it’s good if they find it out when it’s just an incident, it’s bad if they actual have an event. So, this is a little bit more complex of an issue.

Irv: Let me say that the Chemical Safety Board is considering whether action ought to be taken in this area. But the question the group ought to consider…. Excuse me.

Harry West: Just one point that’s kind of like Irv’s and John Susil’s, I was involved in a natural gas special interest group, which we would talk about near misses, and you do create a national system of near miss reports. I think it would have to be by subgroups, because if I’m in the LNG business I don’t care what happens in refineries. If I’m in the phosgene group, I don’t care what’s happened here. So these kinds of special interest groups will create their own near miss reports, maybe then I know that we never wrote anything down, we wouldn’t let anybody in there, especially if they had an LL-B after their name. They wouldn’t be allowed in the meetings. But still the idea of recording those, what I’m afraid of the stuff that we did in the late 60s and 70s is now lost to the young people who are now trying to figure these things out now in the 90s.

Irv: I’m going to move on and say that this is an issue that during the course of the meeting that’s to be discussed. I’m trying to elicit some of the preliminaries on it. The question is should it be done, would it make a contribution, who should do it, I’ve mentioned it’s one of the things being considered by the chemical safety board, but some one else might be better able to do it. Let’s go on to the third item. I had a discussion with one of my colleagues on the subject just this morning. People ascribe all sorts of things to every time there is change. But this is an issue I think that has to be explored if we are to look at terms of seeking improvements in actual safety. And again there are a number of questions that come up. What are the impacts if any on process safety from economic mergers, from downsizing, loss of a firm's competitive position. Has the increase in out-sourcing led to increases in process safety malfunctioning? I know that two of the last major accidents that occurred, both in oil refineries, included not only contract labor, but in a couple of instances something, which in my youth was unheard of, there were contract chemical operators. That is not something that I experienced during my time. What are the effects of these practices on chemical process safety, should we set goals around either the management of this type of function, should we do studies on it? Any comments? Jerry?

Jerry Scannell, National Safety Council: I’m going back to when I was assistant secretary of OSHA. Every one of the major fires and explosions, the common denominator was restructuring. All they were doing was downsizing, they never reengineered properly and it was obvious. And those were the only ones that I got personally involved in, of the 500 that occurred in 5 years, that I had reported I would venture to guess that most of them had as one cause the fact that they restructured without reengineering. How can you, the one that we opened up with where 23 people died, there were 900 contractor employees on that property every day that replaced company employees, and I’m not knocking contractors, but there was a 50% turnover of those contractors, tell me how you train contractors with a 50 % turnover to the level of company employees. Very difficult.

Sam Mannan: Irv! Irv! I think we need to give some attention to this side too.

Jerry Poje: There are a couple of aspects that I’d like to point out that I can’t get away from a meeting without talking about other influences that the technology development and the penetration of new technology also brings a valid restructuring. Year 2000 technology issue is one that will probably demonstrate a fairly significant amount of failure that may have health and safety ramifications and may also have a much larger business continuity ramification. But those are issues as well for restructuring that aren’t very well conceptualized within this larger system of safety. A second issue this year Exxon/Mobil merger, is such a monumental merger activity, and others John at the end of this table put BP in front of his Amoco name, there’s BP-Amoco-Arco that has ramifications. So the Chemical Manufacturing Association's technical group on process plant operations is now absorbing most of occupational safety and health related issues is having consolidation of technical expertise within that association that has a ramification on safety. API has downsized as a result of new structures that are likely to be falling and are losing staff, does that translate into lesser amount of expert staff and lesser amount of sweat equity from experts within the facilities. That may also have a ramification on the larger questions of the system of safety.

Unidentified Female: Irv, my comment is that I don’t see this as separate from the number one issue where you talk about demographics, and I’m not sure that makes your life any easier or harder, but that’s one important component that ought to come out of looking at trends. I think we’re jumping to a likely conclusion at this point, but it is related to the data issue and tracking and verifying that’s going on.

Irv: Folks I haven’t concluded that it has an effect I’m just saying that everyone is talking about it and no one has investigated it we just hear this person say that this unfortunate, this accident was caused by this thing we don’t know anything about it. My own view is that the chemical industry is an extremely competitive industry. Managers have a hell of a time getting and maintaining the jobs, which are probably the most vital contribution to employee’s health. The single most determinant of employee health is wealth and if you don’t have a job and you can’t make a living that is terribly damaging. So, I’m not condemning the functions I’m just noting that this activity appears to be happening institutions are changing, so other institutions have to respond to this. It may be the associations, it may be government, I’m just raising the issue without concluding.

Johnny Wright with BP-Amoco: One of the first goals that the merger team put together was to try to stabilize morale by middle of this year, with the merger being announced in August. I guess they have accomplished that, it depends on how you view the term stabilized. However, I should note that we did have an increase in minor injuries almost across the board because people were so distracted by the issue of the merger. Fortunately, I don’t believe we had any issues with fatalities or serious ones, but we did have really a large increase in minor injuries.

Irene Jones with Huntsman: A question that comes to mind in dealing with management again is the issue of project vs. process. If you recall the very issue of the quality process, ISO 9000 and now ISO 14000, has a become a business issue, which many companies have taken on and on a world wide scale has served them very, very well. We see though that there still is a natural tendency in the business culture to deal with things in terms of a project, in other words, something that has a beginning and an end. And during these times when there are fewer people to do more and more and more things, whether it be technical things whether it be turning the valve whether it be watching for evidence of drips or slips, there’s still as an issue of when does a project begin and when does it end. The process and the culture of management systems seems to be pushed farther and farther into the background. This is an issue that I think is underneath this issue of restructuring, it’s also an issue which Irv has mentioned as a financial issue. But calls together many of the concerns that we have here, thinking that once this is addressed it goes away. And unfortunately, it does not go away, it continues and it’s the recognition that it must continue, we must continue looking at these items that we will actually achieve possibly some of these preferred objectives.

Irv: I will go on to the next issue. I’m sorry but I’m running behind time and I have until 10:30 and I’m just hitting 4, and so you’ll excuse me for my rudeness in proceeding. I’d like to go onto this issue which Bob has touched on, a number have touched on, the implementation of process safety management principles. In the paper I try to make a case to the fact that most of the accidents, process safety accidents, that occur are not due to unique technical failures. In fact depending on who I talked to I would get numbers from 70 to 90% of all process accidents arise from the failure to carry out that which the company intended to do or which was known in the literature. And I was only contradicted once by the manager of a DuPont facility who said you’re dead wrong it’s 95%. So, we’re talking then in terms of looking at what we’ve accomplished. CCPS has put out more than 40 books, and I think the fact the product of those books, more than the books themselves, have been the fact that each of them has involved 40 engineers studying the subject who’ve gone back educated as a result of the process of writing the book. So, we are dealing with an issue then of how do we get people to do that which they know they want to do. Sam used the question of the medical checkup and the doctor who gives you a set of rules of what to do. Let me ask a question, which I’ve asked some of you before. Are all of you doing the things that you know you want to do to maximize your own health? Are any of you doing it? That first one’s old, is any of you doing it, are any of you doing it? No one? This means that you have a tremendous discount rate for future benefits. A tremendously high discount rate for future benefits. There’s no question of where the loss of the gains are, and yet you’re not doing it. So, now we look at a company and we say why aren’t they doing everything they ought to do? For the same reasons that you’re not doing all the things you ought to be. Your immediate pressures, your immediate needs, there’s in the case of a company the vision of benefits and gains. I would suggest then that there are a number of barriers to achieving this very simple thing, doing that which we know we ought to do. Doing that which we write down on paper sometimes, when we ought to do it, when the actions occur to embarrasses us. Doing the things that trained workers ought to do, so I’ve raised a number of questions here. They are, what is the prevailing thinking in the regard to the roles of the importance of lack of technical hours vs. management system failures as a cause of accidents, and I think I’ve addressed that. That’s a factual one. I’d like to raise this question, does the application of established process safety management techniques require special skills, is it a question that we don’t know how to do it? I’ve put in there some excellent quotes from a paper from a fellow Tweedale. In the paper which I suggest you read, this is going back to ’91. His statement in essence says that if we manage costs or quality the way we manage safety we would be in deep, deep doo-doo. Then, a third thing that I’ve heard people say all the time, and I question it, does safety always pay? At what level does safety always pay? And we say this, but in my statements with insurance companies I’ve tried a number of times when I was in a company, I said look "I’m running this plant, and I do this quantitative risk assessment and I’m down to a point where my chances of having a major accident and killing somebody outside the plant is 1 in 10,000." I can reduce the probability of this occurring why my systems calculations to 1 in 100,000. How much are you going to reduce my premium? Anyone want to volunteer an answer as to how much premium I’m going to get for that?

Paris: Zero.

Irv: Zero. So, how come if safety pays, it doesn’t pay through the insurance company.

Dave Willette: I got 50%.

Irv: You got 50%.

Dave Willette: It’s not something that you get by walking up and say I’m going to do all this junk and I want a 50% reduction. You don’t get it that way. You get it by living it. One of the barriers we got is the fact that most of our graduating chemical engineers currently, this is the reason for the center, do not. That middle management who are now graduated a number of years ago, and they don’t have the concepts in mind that we’re teaching here or that we are trying to have at our lower level engineering technical people practice at the plants. Some of our middle management you know, division directors and folks like that, are clueless on the subjects and they have no value for it, and that’s a legacy that we’ve got to work through.

Irv: You who volunteered to answer Jerry, you want to repeat it?

No.

Paris: Zero.

Irv: Jerry do you have any comment on that issue?

Jerry: I’d say if you raise the deductible, you’d get a decrease in premiums. What you said that you did a minimum level of systems to decrease the stock.

Paris: From the property-insurance point of view, what I’d like to say is that there are incentives there, always have been. Apply for a recommendation in order to reduce your premium. Now since the insurance market is so tight the revenues for the insurance companies are very small, there are not too many of those incentives. The incentives that we have, is that if you don’t comply with that recommendation your deductible will be increased.

Irv: The point that I wanted to make, is this, there may be a disparity between the public's demand for a level of safety and that which is justifiable on a strictly cost-benefit analysis. It was not, I’m not saying it was good or bad, but not all the costs of meeting what the public feels want to be a level of safety are necessarily internalized within the economic framework. And a company’s first thing, the thing that we as a society created companies for was to create economic value within a defined system. The companies are, and I’m not the Chicago schooled economist, but to a degree, companies are not charitable institutions. They are competing and they have to make a living, and we set the rules. And if companies volunteer to do too much beyond what the rules are and what they pay they go out of business.

Jim Overman: I think we need to understand the industry as a whole is forgetting. I think we need to understand that the industry as a whole is beginning to get the idea that the driving force, the basic driving force, for everyone of us here is public perception. And it’s actually irrelevant whether that public perception is right or wrong. The key driving force for us, the key driver is public perception. My CEO recently said that, to the community that we have no intrinsic right to be here. We were only here when we were good citizens of, and accepted as neighbors in this community, otherwise we will not be here in the long run. I think this is a realization that industry is coming to that it didn’t have 10, 15, 20, 30 years ago. And that’s going to change that equation a lot, Irv.

Irv: Jim your point is well taken. Are any of you familiar with the method of calculating or figuring the strategy for environmental cost? Barry wrote a paper in which he used the several tiers of calculations of cost. He said the 0^th tier was one in which you looked at direct cost. Level 1 tier was where you put in, in terms of environmental effects, you integrated direct costs of complying with environmental regulations. Level 3 tier across for those who dealt with things such as liability payments, in other words, how much did you avoid in terms of liability payments. If you made this improvement what are your saving potentials. And level three was what was the value of public franchises, in essence. Now, clearly Dow is an identified company whose franchise is extremely important and is extremely identifiable. Therefore, are all companies like Dow?

Jim Overman: No. But I think that realization is occurring because people like my neighbor here, Fred, are doing an excellent job of increasing public awareness, and putting that pressure on other companies. I think that is a change that is happening, and that’s going to make that equation change for everybody in the industry eventually.

Irv: And that is one of the theories I think the board might consider as a means of facilitating going slower with proving the goals of, strengthening that process or going in a different direction. I’m just bringing out the fact that there is not always a direct financial benefit to every company in doing levels of safety that are such that they would meet the public expectation.

Jim Overman: You know I totally agree with the concept of franchise offering but there is another thing that needs to be said, process safety is really inseparable from good operation of your facility. A good process safety program is directly translatable into good operation, and if you can achieve in your facility a 1 or 2 or 3% improvement in capacity productivity because the place is running better, that’s zero capial investment. So, there’s another way to look at this. Dow being a good example, I suspect that Dow can pretty much prove, as a matter of fact I’ve heard people from Dow make that statement being in CCPS, that they can equate good operational performance, good process safety performance, to a 2, 3, 4, 5% improvement in productivity of their facilities. And that pays to their total process safety program, quite far from any insurance savings or anything else. So, this is a management problem. It’s more than culture; you can’t separate process safety from good operation period.

Irv: Alright, apparently some people have managed to do it because we continue to have . . . and the problem is how do we convince people of what you know to be the truth.

Unidentified Male: I’d like to make one comment. OSHA has a VPP Star program, which is a culture like we’ve been talking about. It completely results in a change from blaming people to finding out what’s wrong and correcting it. And this improved culture takes place like religion in a facility, everyone looks out after everyone’s benefit, and there’s no question that improved people are working safer. You cannot necessarily equate a figure to all the suffering and all that, but we know these plants are safer, we know that these plants have a greater morale, and we know that productivity is higher.

Irv: OK, that’s one of the approaches that might be taken. We’ll move ahead. The next one we are talking about is the fifth area to look at is merely a subpart of the fourth area. That is we’ve said that really the major cause of process safety failures is the failure to do what we already know how to do. And this is exactly analogous to the situation that occurs with regard to seat belts. The seat belts are in the cars, and we know that if we wear them, they reduce fatalities and injuries. And people weren’t wearing them, because of culture, because they didn’t feel right. Faced with this problem, a number of organizations, and the National Safety Council was one and the insurance industry was another, and the car manufacturers were a third element, went together on a voluntary program with the National Advertising Council, and went after changing peoples culture and beliefs and motivation. And it was very successful. I just have done rough calculations, if I remember correctly, Jerry, and I forgot that you were there when they wrote the rule, was it $1 billion that you estimated you saved with the result of PSM program? I know EPA’s was $200 million on top of yours.

Jerry Scannell: That’s approximately right.

Irv: So, let’s say we’re talking about $1 billion. And if we could save that and that’s the result of 90% of that and I’ll use 100% of fair to do that which we know and we can change that motivation 10%, so that’s $100 million in accidents we’ll prevent. On the way down the insurance companies are going to collect those premiums to cover those losses and eventually they’ll stabilize so there’ll be money in the pocket for the insurance companies since there’ll be reduced losses, divided approximately $100 million a year that will be saved. Can we get $10 million for the participants for campaign aid and advertising the technical literature through companies in the technical association meetings that will cause people to feel a little more uncomfortable when they fail to do that which they knew they should do. When one of the three batteries is not operating instead of saying, well go ahead we’ll make this batch, we’ll stop and fix it after the next one, they’ll feel a little more uncomfortable if 10% of the time they won’t do it. I raise that as an issue, there have been a number of people that we’ve had some discussions with, Paris is one, Jerry and Lee and others around this issue. What do you think? Is this an area that is worth doing something on?

Dave Willette: I think it’s already been mentioned. When I first saw the program I didn’t believe it was worth much, but now I believe in it very heartily. When I first got engaged with the OSHA Star Program, which if you really implement that it let’s you take your employees from a health and safety perspective and put them anywhere you want them to be. It empowers them so that they can go do it, and it commits them to achieving the goals. When I was with Oxy we went as far in plastics and did was we got the building in Dallas certified as an OSHA Star Site, as far as I know it’s the only office building that is so certified, and we found it was just that good. It has benefits way beyond just health and safety. It deals with the employee and the employees’ perception of the company. That’s one model that I can say that does exist that has amazing benefits and will get put into whatever it is you want to achieve.

Irv: Anyone else. Jerry?

Jerry Poje: One reason that the seat belt campaign and air bag campaign, has been successful is we have data. We were able to drive it through data, and through focus groups and all. So to have a campaign of nice warm and fuzzy won’t work. So we’ve got to have data, and we need the data, we don’t have the data. Jerry Scannell who was around OSHA when that VPP program began, Don at the end, Oxy’s just said it’s got some real accomplishments in the star program. When we were trying to implement the risk management planning program and used some of the volunteer practices like Star and VPP, there was a lot of debate about how that would be inappropriate because of the failures of good data. That really demonstrated the things that you said that you know. I would be interested in carrying that just a little bit further sometime in the next few days.

Irene Jones: I would gladly address that. I know because I have the data specifically for certain plants. I participated in a partnership meeting in Washington for Huntsman Chemical Company had specific data that proved safety and health paid at a VPP star site. And they went through a number of parameters, and that data Huntsman Chemical Company will gladly share. And it clearly shows that safety and health paid for their work sight.

Irv: Maybe I didn’t phrase my question correctly. It’s a terrific answer. I guess the question I was trying to pose is do you know that it’s made a difference in terms of accident rates and how do we know that, because within this Star voluntary program very well maybe the clues to some of these settings of goals we are talking about and some of the clues to the measurements.

Unidentified Male: We had a site that used to have tremendous labor management problems. And had a tremendous cost for workers’ compensation. And it was a large amount of data that reflected what was going on in that plant. And they have charts and data that showed how they matured as they became a VPP Star site and actually put these practices into place whereby it reflected in a safer plant, a plant where people were motivated and believed in safety and health and the plants got better.

Irv: We’ll have to move on, but my epidemiology friends would say is that association or cause and effect. We need statistical data to do that, not critical observation, but it may be very true. Let’s go on to the next one, and I think this is quite important. And again I want to thank Jerry for his thoughts on this one, Jerry Poje that is, not Jerry Scannell. And that’s the establishment of national process safety centers of excellence. Similar like functions in the environmental areas, where we have these all around the country where there are centers established at the universities that promote certain activities. And in this case I think it’s training particularly training for smaller to medium sized firms. Firms that don’t have the benefit of having institutions like the laborers to go into union firms and hold the organizing sessions. I don’t think there are many non-union firms that would invite Paul to give his safety talk though he might not mention the union at all. But do we need centers of excellence that are training centers for small to medium sized firms scattered around the country. Is there a need for some basic engineering research, particularly the areas such as inherent safety where no one, no particular firm stands to gain from general reference in this area? And that I raise as another area for consideration. And we’ll take one comment from Jerry and then proceed on because the co-author of this paper is getting impatient with my long-windedness.

Jerry Poje: The theme that you’ve raised Irv, a number of times is from the medical epidemiology model. It is very important for everybody to understand that the reason why that model is explored and works is because the National Institutes of Health funded it $13 billion a year. Has cancer institutes all over the country, has heart, lung and blood institutes all over the country, has kidney institutes all over the country. So, if you want to know about the risk factors for these diseases it’s because the engines of exploration and understanding of those problems, and the clinical trials to intervene to find out methods by which you can ameliorate, or solve, the problems are happening all over this country by that major venture. The U. S. Environmental Protection Agency has a major pollution prevention strategy that they have developed, but it is poorly articulated in the area of inherent safety. Areas that I think get the practicalities of how could this audience help set goals that might penetrate into this sphere. Jim has done a marvelous job as a federal agency planting seeds that a number of institutions have tackled major topics that move us forward, but his resource base is woefully deficient to launch something as monumental as this. CCPS has done a great job in putting forward a whole host of best practices and organizing the cutting edge of the industry. But to get further I think we really have to think a lot more broadly about how does this society address health related issues in a much more monumental way.

Irv: Thank you, I’ll go on to the, oh excuse me Hank…

Hank: Hank Austin with American Society of Safety Engineers. I would just suggest real quickly that engineering issues are evident and absolutely they need to be worked on. However, I think it has been pointed out by several individuals that the real basis of a lot of these problems, as is across the broad spectrum of the safety issues, they’re all one in the same, it’s a management issue. Then perhaps we should also consider getting centers set up that implement training into the business and management skills as well. Our business managers today have absolutely no knowledge or training in safety.

Irv: Good point. Quickly notice, ok….

Unidentified Female: The National Institute of Standards and Technology has these manufacturing centers that are set up for small and medium sized businesses which typically look at management issues but it could be the kind of thing that could be extended to helping smaller companies with these kinds of issues.

Irv: Well, I don’t know where these would be setup. The nice thing about setting them up in places like Texas A&M is that you might be able to get the money if Texas A&M got a part of it they might be willing to support getting some of it. The last issue we want to take a look at.

Dave Willette: Before you leave that, a couple of years ago when we really had a real strong OSHA mission I happened to be at a Chamber of Commerce meeting and I was talking with one of the local car dealers, and I found out where the dump OSHA stuff was coming from. And I started to question this guy as to why would you want to do that, and what I found out is because he really didn’t understand what the agency was trying to accomplish for his business or would accomplish for his business. And for small and mid sized firms involved in many diverse industries we need something that can help those guys, because they’re at sea and they don’t know what to do.

Irv: The last issue we want to take a look at, is a question of prioritized assistance annual auditing focussed on improved compliance with regulatory good practice codes. What I call higher at risk firms. There are firms which by their very nature of their business are liable to do certain practices which would not ordinarily be considered good practices. At least when I was active in the area, one of these signs of a business that you may watch carefully was a cash cow. A business, of which management has essentially said we can’t justify any future investment, we’ll run this business as long as we can and get a return, a positive cash flow out of it. That’s a cash cow in a large firm, but there are many small firms that are marginal. And for such firms we have to face the issue that there may have to be, what I call euphemistically more assistance or auditing, that is maybe EPA has to do more than 1% visits and maybe they have to be concentrated, prioritized at certain types of firms. If we have the data and the ability to be able identify them, maybe OSHA as it’s tried to do, was thrown out by the courts with the Focus Program, recently has to be able to identify and focus on this. Not everything, not everyone is in a position to be able to look at potential risks of 1 in 10,000 if staying alive and staying in business is a month to month proposition. And that was the last thing that I suggest that we consider as possible means that if we accomplish will lead to changes in the incidences of process safety accidents. Thank you very much.

Coffee Break