Accident Epidemiology Project Paul R. Kleindorfer The Wharton Center for Risk Management and Decision Processes The University of Pennsylvania Robert A. Lowe Center for Policy and Research in Emergency Medicine Oregon Health & Science University Irv Rosenthal The Wharton Center for Risk Management and Decision Processes The University of Pennsylvania Center Advisory Committee Meeting: 06/16/06

Accident Epidemiology Project* Rule 112 (r) of the Clean Air Act Amendments requires filing of accident history data for facilities in the U.S. The resulting RMP and accident history data can be used, with other data, to test a number of hypotheses regarding the precursors and consequences of accidents in the U.S. Chemical Industry. Results can provide valuable insights about environmental policy, but also about process safety (OSHA) and security issues (DHS). Today we focus on the EPA/OEM issues. * This research was carried out with the support and participation of U.S. EPA/OEM

Overview of Research First tranche of data covered the period , and became available for analysis in This gave rise to a number of studies at the Risk Center. Second tranche of data began arriving in We are currently analyzing this, both on its own and as a comparative study with the results of the data. In addition to statistical work, we have also been studying the use of the accident epidemiology framework as a means of evaluating management systems for predicting and controlling accidents.

The big picture for data-I Many facilities appear to have failed to re-file as mandated There appear to be significant differences between the data reported for the and the periods regarding two key RMP issues; -Hazardousness - Accident rates

The big picture for data -II By several measures, facilities reporting in the 2004 RMP data collection round were at a somewhat higher level of ‘hazardousness’ than those the 1999 round Accident rates reported for 2nd period were lower than those reported in the 1st round: –Drop may be real or reflect change in industry interpretation of accident consequences that determine RMP reportabality i.e., what constitutes a ‘worker injury’ Substantive data concerns that could affect the ultimate study findings are remain under study

Choosing The Population for Tracking the Impact of The RMP Regulation Unresolved issues remain as to character of the facilities that apparently failed to meet 2004 registration requirements and investigation of this issue will continue Our study of the cultural, facility and business factors influencing the occurrence, character and consequences of RMP reportable accidents will focus on the facilities that filed in both and , a Cohort of 10,446 facilities

Did Cohort ‘hazardousness’ change over time? Hazardousness increased (as measured by maximum inventories of RMP regulated substances relative to threshold levels) % covered by CAA Title V increased % covered by EPCRA 302 increased % covered by OSHA PSM did not change significantly Trivial change in maximum RMP program level Number of chemicals did not change Need to account for level of Economic Activity

Number of accidents by year: our cohort (N = 10, 446)

Number of accidents by period: our cohort (N =10,446)

Did facilities’ interpretation of criteria for reportable RMP accidents change, or did accidents actually decrease? How would we know if reported accident reduction was due to facility reinterpretation of threshold reporting criteria? The number of accidents with consequences that couldn’t be easily hidden would not decrease substantially; therefore, the % of accidents with such serious consequences such as public evacuations, medical treatment of community members, etc. would increase. What if accidents actually decreased? Number of accidents with serious consequences would decrease at least as much (proportionately) as total number of accidents; therefore, the % of accidents with serious consequences would remain the same or decrease

Other questions being studied How do the consequences of reported accidents compare across the two five-year periods? (what we discussed above was just related to frequency of reported accidents) What have been the trends in worker and public responder injuries? In property losses? Have there been fundamental changes in accident rates or consequences for major sectors of the chemical industry when comparing to ?

A BIG question for EPA/OEM/OMB: Has RMP Regulation been Cost/effective? –Cost of implementation? –Value of Reduction in accidents/injuries? –Value of Reduction in worst case footprints? –Improvements in communication and response patterns for emergency responders? –Improvements in the interaction of EPA and facility managers with communities and NGOs? –Improvements in Management Systems for major accident prevention?

Some Questions for the Day How can this on-going research be best communicated to industry and other stakeholders interested in process safety and environmental performance? There is a question about the role of reporting behavior as one of the reasons for the apparent downward trends in the RMP data. –What is your general perspective on the incentives on companies regarding external reporting, using RMP as an example? –E.g., Have the incentives for underreporting, noted in earlier research, been off set by pressures for greater transparency and better governance since Sarbanes- Oxley? The RMP data suggest that “hazardousness” has not decreased. Assuming that this is the case, and given the pressures to improve this (both for security reasons, as well as for chemical safety), why hasn’t this occurred. In particular, what are the strategic costs and benefits of reducing the potential for reasonable worst-cast consequences?