Roundtable Meeting — June 2-3, 1999

Eboni: The major causes of incidents for the most part are operator error/poor maintenance, and they have grouped these two together although I’m not sure if that’s a good thing to do because operator error could mean anyone changing or fixing something in the control room and poor maintenance may not exactly be an operator mistake..…….How is improper installation and repair different from poor maintenance?

John Susil: It looks to me like, Eboni, that they’re trying to separate people failures from equipment failures.

Eboni: So, even the improper installation and repair wouldn’t that be a person doing that?

John Susil: A different group of people.

Eboni: OK a different group of people, say maybe contractors for the repair.

John Susil: The people that are operating the facility would be doing the operator error and poor maintenance whereas somebody probably from outside came in and did the installation or a different part of the company or something else, it’s a different group of people.

Irv: Did you attempt to contact either the National Institute of Pressure Vessel Inspectors or our friend from Hartford Steam Boiler and ask them …..?

Eboni: No I did not attempt to contact our friend or the National Board of Pressure Vessels, all the information that I got was from the internet and any reading that I did as far as this particular database. And the reason why I did that too obviously I want to be as thorough as possible as far as getting information, but if I couldn’t find information in the database and I’m trying to find out what accident databases are telling us then that’s kind of auxiliary information. To have to go to secondary sources means that the accident databases aren’t providing the information that I need.

Paris ?: I would venture to say that most of the accidents involving boilers take place through pre-startup with boilers.

Eboni: In the start-up?

Paris: Yes, obviously it’s going to be an operator error most of the time.

Eboni: Most of the accidents occur during start-up and therefore subsequently it would be due to operator error. Most of the time.

Noronha: A lot of them end up going through maintenance and the start up, the ASA is involved in new project start up.

Bob Perry: Eboni, there’s a whole category that will deal with base control boiler water properties, and the water that’s in the unit and that will be a major source of failure.

Eboni: All those points are very well taken and definitely that shows that we need more information in these databases. In essence of time what I’m going to do is, because you can note in your tables that all I’m really going to say as far as the other boilers are, what the main causes of accidents are. And those are noted in my paper before you, but I really wanted to make sure I got to the larger databases at the end of my presentation. If anybody has an issue with that, please let me know. Basically the information about the pressure vessels and things are fairly straightforward and we obviously could have a discussion about that later. The next database I’ll look at is the emergency response notification system, firstly lets define what this system is. It is a collection of initial release reports, and by definition that means that is the first thing that is reported about a particular release. And as you well know anytime someone's first impression is given about any particular event, it is usually erroneous, or really doesn’t give you much detail about what exactly goes on. So, therefore, the data tends to be very general, and the quality of data is questionable due to the fact that there is transcription errors and multiple reports. Because this information is taken over the telephone there is obviously a telephone number that any facility can call to let them know that initially maybe 100 pounds of ammonia or something like that was released. And maybe later on after further investigation maybe it was only 75 pounds or maybe it was ammonia and another substance. So, this data is very questionable as far as its quality, because we can have multiple reports if someone in the community around a particular plant notices an odor and is effected by that. They too may call this particular organization and say there’s a release when someone maybe on site has already done so. So, let’s just keep that in mind. And obviously it’s divided into the ten EPA regions, and if you’ll look in the paper before you I’ve noted what those regions are. But in the essence of time, and also importance as well, I felt like if we looked at the three largest and or active regions and used those as a model then we could take care of or at least try to make whatever improvements for those subsequent regions. So, those regions are Regions IV, VI, and IX that I discuss. Firstly, we need to say that the injury figures tend to increase from ’91 to ’94 and then decline from ’95 to ’97. Basically all this increasing and decreasing says is that we don’t have a clear handle of what’s going on. But if we look at 1994, as far as injuries which are in the pink, 994 injuries were incurred and we really have no idea the specific details of that. As you can imagine this database is huge, and I used Microsoft Access to compile and get it to answer the question that I wanted. Which was basically how many injuries, how many deaths, and how many incidents occurred. And because of that I don’t have any detail about what occurs as far as the specifics of how those injuries were incurred. Whether it was exposure, whether it was some kind of impact or contact with objects, but what we do know is that all these are initial reports so these numbers may not be as high as we initially thought.

Dr Angela Summers: I had a question. Looking at that, looking at the fatality numbers are they typos in your report or are they errors in the database? For example Region IV in ’88 there were 638 deaths in a different Region, Region VI and VII, there are 1015 deaths and that doesn’t make sense, so……

Eboni: Well that is a possibility that the kinds of typos that are made in the database itself. And looking at the database data, looking at all these different basically spreadsheets of data and how things are, I mean I caught numerous typos as far as the year, because I knew what year we were looking at. And the year was wrong or the, you know words were misspelled. So, obviously a transposition of a number could be there too. But I don’t really think that that could be it as well, because Region IX, I believe is a very large region, which includes Texas I believe if I’m not mistaken. VI is the one that includes Texas, obviously the facilities in Texas would be more than, maybe the small region of Region IV. I guess my answer to your question would be yes and no, typos are possible but in the likelihood of the regions that we’re looking at it may not be. Yes sir?

Unidentified Male: The ERNS database, you focussed in on with this an initial notification database. What kind of compilation activity that’s been done by EPA, by these regions, really pushing that data in the direction that wasn’t designed to serve. I’m not sure, you’ve already noted the multiple notifications, I’d be deeply suspicious about drawing conclusions from the ERNS database.

Jim Overman: Just for your information, Region VI does make an attempt to correct information if the facility, our facility for instance sends a letter after each event with corrected information and details. That information does get entered someplace in the data system, I’m not sure where. But we have noted corrections, cause I call it up every once and awhile and look up my facility, and I’ve noticed there have been a few corrections.

Irv: One thing I’d bring to your attention, is that ATSDR on a limited area, has an independent database on accident consequences, which the data is verified with the state public health authorities. You might want to make comment on that during the discussion period.

Eboni: Someone over here wanted to say something before we begin, no. Yes?

Dr. Mannan: Why don’t you summarize your conclusions, so that we can have a discussion.

Eboni: Conclusions

Dr. Mannan: One thing I want to point out that Eboni could probably have used all day today and quite a bit of tomorrow going through all she has done, she’s done a lot in terms of looking at data. I know and some of my research group members know, having sat through meetings where she was doing presentations of different things. But one of the themes that comes out continuously and over and over again, very common things. Number one, the thing that we already talked about earlier, that these databases you really have to get your teeth into it and get deeper and deeper to understand exactly what’s in there and how to use them. So, let’s not throw these live hand grenades around carelessly. If we’re to use them, let’s know what’s in there and let’s use them properly. The other two things that come across real loud and clear, is number one that there is a big problem with integrity and accuracy of the data in many cases. Some of the data are very good. For example, National Boiler Data is very good, but in some cases some of these databases have a big problem with integrity and accuracy. And a third and main problem that I personally find is the taxonomy of the data. In some cases it does not have the parameters you need to be able to help even establish goals or establish measurement systems, or move towards a measurement system. My challenge to you, suggestion to you, comment to you, is that we need to look at this database effort as one of the major parts of this program. Because if we are going to do something about the patient, we better be able to tell the parameters that could determine the condition of the patient. Right now we don’t, that’s my opinion so we need to come up with the framework of how we go about doing this. Whether we use existing databases, clean them up, do whatever, combine them, but we as stakeholders, need to agree on a common platform to do that. Then that becomes some kind of a tool to assess the status of the chemical safety program. I think it is very important to do that, otherwise will have situations where people will be using these databases according to whatever their motivation is.

Irv: I guess I’ve got the mike next. The first thing is I’m going to pass along to you an old family admonition that my mother used to give to me, when you said, "Is it fair for small businesses." My mother used to ask me this question, where is it written that life has to be fair? I think that in terms of most of these types of things certainly reported accident statistics is a relatively simple thing compared to having reported accident investigation, which does require some time. But responding to more substantive issue, I believe that the best database, at least as far as process accidents is concerned, the one that has the greatest promise, is the one that has been developed by the EPA; the RMP info database. However for a number of reasons, one is they define what is important. Two they have a population base in which you require that each facility report a number 0 or some number of incidents, so you can sum number of accidents. And three is they choose to do it and I think this is extremely important. If there’s some attention paid to showing the regulated population that EPA is serious about getting reasonable data, and therefore a less than certain number of orders are done and the quality of the data is established at where it is not there after judicious warning and time and everything like this, some actions aren’t taken, that database will deteriorate. But if that approach and that database does hold the promise that I think it has, it may provide the opportunity for moving forward and extending it to other institutions along similar lines.

John Susil with Celanese: Eboni, I think did a wonderful job and struggling through these databases as you did. And I think it makes the point very clearly that there isn’t a database out there for our purposes. We’ve been sitting here this morning talking about chemical releases which is the foundation of both the EPA RMP rule, and the OSHA PSM rule, and about things that impact the neighbors and fires and explosions. And when you look at some of these databases and here’s a hazardous chemical exposure that killed 110 people when the jet plane went down and you’re trying to use that kind of data to talk to your neighbors about how safe or unsafe industry is and it’s ludicrous. So, I would agree, someone this morning I don’t remember whether it was Jim or Fred, someone on that part of the table, mentioned how poor the databases were, exactly right. And I think I would agree with what Irv just said. We’re just at the starting phase of getting valid databases, the EPA RMP database is a start, and I think we ought to question whether there’s others that deal specifically with chemical releases, which is what we’re all here about today.

Bob Perry: That’s what I was going to mention. By the way CCPS is not me, CCPS is some ninety companies that comprise CCPS. CCPS only has 4 full-time employees, so I appreciate the compliments, but it’s Dow and Celanese, and it’s HSB and it’s a lot of companies. But in any event, Exxon was willing to give to CCPS their process safety incident release database that they have developed internally. CCPS has now modified that to create a, what you might call a proprietary database. There are some 25 companies now participating. They are constrained to enter at least 10 incidents a year. It’s very sophisticated, it has a data field that I think all of you would find to be extensive enough for your uses. It is statistically significant I think. We’ve got now something like 300 incidents have been entered into the database. We’re learning how to use it. But like I say there are 25 companies participating, some of them several of them in this room. The information is confidential to the companies that input data. If a company does not input data they are not privy to any of the information in the database. It is totally anonymous, Dow cannot tell what Exxon has entered, cannot tell what Union Carbide has entered, etc. So, I don’t think the data from that is going to do this group any good, but I do, and I’m not making a commitment, but I think it’s something that we should explore, the database itself without the information that’s entered. Just the software collection system, which was originally based on an Exxon database that has now been improved and modified, could be something that could be of interest to this group. It would be devoid of information, but it would be a darn good starting place from which to gather data and is probably something that ought to be explored as to how that could be done. We found an interesting thing, when we first started down this, the legal people within the companies, the lawyers, said oh we can’t play. We could never put, I mean this is real data it’s full description it’s lessons learned it’s root causes it’s a lot of information, so we can’t put data into that, too much legal liability. As we got a few companies in, now the lawyers are saying well you know we can’t afford not to be there, because suppose we have an incident and it’s found that this tool was available to us and we weren’t using it. So, it’s totally switched now, I think there’s a movement to participate. I don’t know how that could be of use, I don’t know how the data could ever be revealed to you because of the confidentiality agreements, but I think the database could be made available.

Steve Cable Pace National Union: We looked at this problem for quite a while now, too. We’ve researched a lot of these databases and came to the same conclusions that you did. That they’re almost worthless in what they offer because they are so incomplete. And we fell back to the basics, that before you can develop any kind of trend analysis like we’ve tried to do with some this stuff, you have to have a good collection, data collection process in place. So, we’ve worked with a lot of different people, we came up with one we call it, it’s part of our top program called top rate, and we’ve tried to come up with something that is based on numbers and the information that is readily available it’s already there, and it’s beginning to gain some acceptance with some of the groups that we represent. We have several companies voluntarily now coming on, and using this rate so that they can look and get a better picture of their safety and I don’t know if it would be applicable to anyone else. But it’s based on, we decided first of all this isn’t something that can just be voluntary, that they’re going to send one incident out of 20 and report this kind of things, you’re never going to get a good picture. So it has to be something where they look at every incident that happens, everything that’s reported. We modeled it after one of the things we call the OSHA Incidence Rate that’s something we’re all familiar with. It gets calculated out every time something happens, but it’s a very poor indicator because it’s a narrow focus. So we broadened it to include incidents that for example fires and explosions that require any type of emergency response, any type of release that’s recordable under SARA Title III. The Plant OSHA Recordables are currently taken, but also may include a contract recordable, and also any injuries to the community that requires medical attention like the emergency room or even a physician, something that’s turned into our medical department for insurance coverage that type of thing. So these were all numbers that are available that are already currently out there but they give a much better picture of the safety condition of the plant, what’s going on out there. And then with reports that are associated with each of these, it gives you this broad spectrum of data that you can use to gather, that you can put together some of this trend analysis that I see here.

Pam Kaster Citizens for a Clean Environment: And you touched on a point that I wanted to bring up, these databases totally confuse me. What would make the most sense to me was if there’s information from the medical community. What are the types of injuries that people are most apt to see, where are those reported, where are they treated, that makes more sense to me on whether or not the work place has gotten safer or not. And Irv I’d like to caution a little bit, I know maybe the world’s not fair, but if we want to change the mentality of small businesses we’re going to drive them underground if we’re not sensitive to their needs. Right now they already have the opinion, "Catch me if you can," and if we’re not sensitive they’ll even be harder to catch. And if I understand what Eboni said, most of our accidents may be mechanical contacts between people and equipment. And it may be the small businesses that have most of those accidents, so we need to really include them in this effort if we want to get a clear picture of safety.

Jim Overman: I’d like to second that last remark. I think if you look at the companies and the labor organizations represented here today, you will see incredibly small rates, however you want to measure rates, relative to industry as a whole or even chemical industry as a whole because the rates are low. And the companies that are here, and particular have spent a great deal of time and effort working on that. We measure things like OSHA Recordable Rate, reportable spills, like I said earlier spills that are not reportable to agencies but internally meet that criteria, process safety incidents that cause more than $25,000. Lots of things we measure locally. There needs to be a carrot and stick to get other players in here. Because if we look just at the companies in this room, or your group, certain parts of labor we are going to get a very wrong view of what’s really happening out there. I think the solution is to find an organization like Sam’s organization here, need to support our host, and then have a carrot and stick situation that will encourage companies to report. And then we need to take a close look at the information that we need to have. Whether it’s a CCPS database, your database, a combination of them, it makes no difference, because we need to look at the data we need to have then we need to find somebody to do it so that it’s not threatening to any institution, organization, or company. And that’s the key issue, and you do it, and you do it with respect for an organization like this one, where there is anonymity, and the information is available to you. So, I think we need to move in that direction. If we can accomplish a consensus opinion on that over the next two days, we’ve made a long step in reducing incidents because we’ll know where we are to start with.

Haskell Monroe: As a friend of the court, I’d like to ask what kind of carrot can you offer?

Jim Overman: Well, I hate to go back to our friends in the regulatory area, there are carrots that are offered if you are in the VPP Program. If you’re in the VPP Program from OSHA you get things like fewer, no surprise compliance audits, scheduled audits, lots of things, and Ray could go on and on forever, besides the fact that you get a personal benefit from getting to fly the star flag. And let me tell you that’s a matter of pride for anybody that does it.

Ray Skinner: And these companies consider their contractors, their injuries, their illnesses, on their same records.

Jim Overman: Absolutely, there’s no separation at our companies, and probably not most of them ever claim contractors and company employees. I think that’s the kind of carrot that’s got to be out there. There’s got to be some relief where you show if you ………..

George Rotter: B doesn’t either, C doesn’t either, D is the one that’s closest. D measures the days away from work. Severity rating we mostly go with. Days away from work per 200,000 hours. That’s the only one that correlates with cost. So, some year’s ago I had a discussion with some OSHA people and I said when Clinton came in the topic was, it’s the economy stupid, I said what you and OSHA ought be thinking about now is it’s the fatalities stupid. Start focusing on where are you having the fatalities and I’m glad to see that OSHA is currently looking for where are the fatalities occurring like in transportation, even though it muddies the things and they have to go into work with DOT and other organizations. At least they are looking at now measuring themselves by how are the numbers doing at the plants and places where they interface now. Well, I just wanted to show that it’s not the total recordable rate, it’s not the lost time restricted and away from work, loss work the case rate as OSHA does it, or the loss time frequency rate. It’s the severity rate. And what I’m doing when I measure the plants in our company on a monthly basis, I measure and rank them on the basis of the severity rate. I know most companies typically do it on total recordable rate, but I look at it as is that really a way to measure things? If I had a $100 bill and gave it to this guy, and $10 to this person, and $5 to that one, and $1 to that one, they’d all be getting a piece of paper currency. And that’s what total recordables is, it treats them all the same. A fatality is no different than a medical. So, within my company I try to push the severity rate, and stress the difference.

Delilah Barton: What’s the bottom axis on that chart?

George Rotter: In this particular one, it could be years, it could be anything.

Delilah Barton: You don’t specify then.

George Rotter: No. In this case it happened to be the fibers part of Akzo Nobel, the pharma part of Akzo Nobel, the salt part of Nobel, and the chemicals part. And this some years back in ’91, but I’ve done this several times and it, and I’ve talked to Du Pont and they agreed, severity rate is really the one that measures it most closely. But, I just wanted to bring up this point, that I think sometimes that we talk about total recordable rate and we don’t look at severity rate.

Delilah Barton:: Can I ask you another question about that one? You’re drawing a correlation between days away from work and the workers compensation. So, are you saying that the more days away from work or the less days away from work?

George Rotter: More days away from work is going to increase your cost. And in fact, going through using the workers comp data cost, I’ve determined, I usually take three year averages, and last time I did it, the average, well we’ve only, since I got started in safety, we only had two fatalities in our company in North America. None of them in our plants, one on an airliner that crashed outside of Pittsburgh, just west of Pittsburgh in ’94 I think it was. Another one a driver in Mexico City, who took a load of product out to a customer came back to, was heading back to our plant, and crashed on one of the main roads in downtown Mexico City, and killed himself. So, those are the only two fatalities we had within the company, none in the plant. Did you have another question?

Delilah Barton: I’m being really dense here. I really I’m missing your point of this graph.

George Rotter: These are the incident rates, well D is the severity rate for the fibers portion of Akzo Nobel in a given year, probably 1990. This is the severity rate for pharma, salt was bad that year and their costs were high also.

Delilah Barton: Maybe I’m not understanding what you mean by days away from work. Does that mean guys off on vacation or because ….?

George Rotter: No, no, how many days are they off the job due to work related incidents.

Jerry Poje: Thank you very much. First I would like to congratulate Eboni on the work you’ve been doing, it’s not easy to work with databases and some of us have belonged in that kind of business over the last number of years. And I could give you a URL for another database, and that’s the National Analysis of Trends and Emergency Systems, that’s our spills database that goes back to 1973. And we just have some really interesting discussions and debates on how to use that data. And, so I’d like to draw a couple of points from that, the data that we’ve talked about in all of the database sets that we’ve talked about in the presentation deal with failures. None of them so far have dealt with any of the positive issues that we’re trying to do across the country whether it’s the United States or Canada, to improve safety. They’re all negative aspects. And I think we’ve learned over time that negative results are not a surrogate for positive initiatives. And I think that’s where we need to start reflect when we move from company level activities, and I saw the Dow paper on the goals to reduce, to reduce, to reduce, and in order to reduce you need to measure certain activities. When we get to the national level, what our goal is, is yes to reduce the number of failures, but the direct activity that we want to measure is improvement in process safety management, or improvement at the community level and emergency preparedness. And so far we haven’t talked about that yet. I think the accident case history that EPA is going to have starting time in two and a half weeks will start to provide the accident bench marking to maybe go further from there. How are we going to measure how many companies have good PSM plans and systems in place on the OSHA requirement and how are we going to measure whether companies are just as big in risk management plans as group quality programs. And I think until we can start to develop a trend and show the improvement in those positive initiatives than I think we’re going to, we’ve to come back ten years from now. As we did I think in 1990 and the National Advisory Council looking at chemical databases, and I can remember the same argument and maybe Jim can remember that as well, that we’re having around this table because failures are not a surrogate for good safety.

Jim Overman: I want to lay a specific proposal on the table. It’s a challenge to Mr. Makris down there and some other people here. That if a company voluntarily participates in a database program, such as the one that I just mentioned, they will be exempt from OSHA, EPA RMP inspections for the duration of their participation unless they have a significant release resulting in fatality or multiple injuries. That very similar to VPP. The challenge is in your court Jim.

Jim Makris: I will take that it into consideration. I can tell you that that’s a good deal Overman, my email will be buzzing by Monday. So, I think that’s why we’re here, we’re here to do just that kind of, I think, bold thinking that might really work in this process. And part of the bias is that we all want to present data that meets our purposes and I think if we could all agree, as Sam said this morning, that there’s a common goal. And the common goal is reduction in risks in industrial accidents. We all have that same common goal, we ought to try to figure out a way that we can all measure against something to see how we are doing together. And I think that’s really the key. I frankly think there’s no better place to do it than here. All the rest of us have a chance and we haven’t done it yet. We’ve already proven that we don’t know how to do this in a way that is fair, whether it’s EPA or OSHA or States or whatever. I’d say Sam’s it’s a good market to lay down in and we’re going to have some private discussion on this I guess tomorrow afternoon.

Dave Willette: A lot of industry has audits or something else in place to measure how effective their programs are in PSM and other things. And we do have the bottom line results like: Did you really have an event in fact that somebody, and a lot of us also have near miss measures that are available to us. It seems to me that if we want to look at, how can we measure where we are, let’s measure what we’re trying to use to get to where we want to be. And to do that we’re not adding any additional things that we need to do, we’re as I said old John or Bart idea, let’s make it congruent with good practices. So, let’s measure good practices as they are being performed, and then let’s create a way in which that information can be measured by which it can be normalized. And let’s then start doing it.

Fred Millar: It seems to me there are two main options here, either, if people are serious about trying to measure safety in any kind of decent set of metrics. I remember when I first got into HAZMAT work years ago, I learned about the Dow Index, and how important that was and how people were copying that and imitating that all over the place. I mean it seems to me to have a meeting like this without at least ten companies to show their kinds of measurements, excuse me that’s one way to go, another way to go is to have the government do it. Right now we’re talking in kind of an abstract level. It seems to me that it’s just I mean either we’re going to do it voluntarily and companies are going to chip in with their responsible care type responsibilities, and say here’s our measurement systems and if you can do better let’s see yours you know. I mean like the man from Escotes, you know what I mean, let’s see what people have got. I’m flabbergasted that we have to sit here in sort of a miasma of ignorance about what it is that all the different companies are doing, we should try to come up with something new. That either we do it that way, in fact if we do see that in fact a lot of companies that what companies do have cannot be blended into a common system that we all think is useful than of course we’d have to have the government do it. But you can’t have it both ways, you can’t say you know we’re not going to show you the government stuff or we’re not going to show you the industry stuff because everybody’s got their own system right. And we’re not going to have a government either, you know. You can’t pretend to be serious about safety and not do it one of those ways.

Sam Mannan: There’s I think a total of eight companies that have submitted goals and how they measure their progress towards those goals. I think it is totally unfair, if I can use that term, because Irv cautioned us against using that term. It is unfair to say that these companies are not sharing. In fact Conoco has told me that they will give us how they measure projects. But I will also caution you, is that if we really want ourselves to be credible and want everyone to accept what we do, we should use that only to evaluate what we are doing, not use that as a starting point. Do you see what I’m saying? There’s a slight distinction between the two. But if we do have access to some of what people have done, and it’s all there in your binder.

Fred Millar: I’ve read the binder and I don’t think, I mean if we were being serious about this, we would have like one hour presentations from people about their real guts of their real safety metric system. We’re not getting that, I mean to have a couple of pages in the binder is not the same thing. It’s not taking it very seriously, and a few people can say we’re doing it as a voluntary consensus way, and we’re really not getting the guts of what people are really doing. That’s my impression, I don’t think this the serious way to approach it. And on the other hand, people don’t seem to want the government to do it either, right. So, it feels to me like that’s sort of like a double bind here because we’re not doing it either way.

Jim Overman: Fred, we submitted what Sam asked us to submit.

Fred: I agree with that. I’m not saying….

Jim Overman: That doesn’t mean we’re not willing to share anything else that you want to know about our metric system. This was what we were asked to submit.

Fred: I’m not saying that you didn’t respond to what you were requested. I’m saying that the request is not being made of companies to submit a serious metric system that the rest of us could have a look at and say here’s what really works for our purposes. Now, why should we have to reinvent the wheel and do that if there’s all these talented people out here who have been working on it for decades. I wouldn’t want to have to reinvent the Dow index, would I? I mean I want to look at it, and then say I’ll go from there. I mean that’s the equivalent of what we’re not looking at here as far as I’m concerned.

Jim Overman: Fred, what I heard you say is we’re not being serious because we don’t have all this lined up. Hey this is the first step; this is not an overnight process.

John Noronha: Sam asked me to comment. First, a very good point you brought up. And in fact in our paper benchmarking, phase 1 has precisely what we’re going to do. It’s Figure 8, we’ll take all available data offered to us and analyze them from a starting point. So we discus the database of chemical process safety, so some data points, everything is welcome, that we appreciate it. So, we can discuss it offline. It’s in Figure 8 of our paper. Thank you.

15 minute break

Noronha: Section 12 a change ­ Cover page says Eastman Kodak Company, I would appreciate it if you would delete it because I’m retired and all. On the last page, it says appendices, and on page 8, we only listed the appendices and will include them in future drafts.

Continues presentation of his paper.