U.S. Chemical Safety Board (“CSB”) voted to classify the American Petroleum Institute (“API”)’s response to the CSB’s recommendation to develop an effective system of performance safety indicators as “Open-Acceptable Action.” The API developed Recommended Practice (“RP”) 754, entitled Process Safety Performance Indicators For The Refining And Petrochemical Industries following a 2007 CSB recommendation to develop an effective system of indicators to evaluate performance and implement these measures to continually improve the management and control of process safety risks. “Open-Acceptable Action” means the CSB considers that the API is moving in the right direction, but that more remains to be done to meet the intent of the recommendation. The recommendation resulted from the CSB’s investigation into the March, 2005 explosion and fire at the B.P./Texas City Refinery that killed 15 workers and injured 180 others. The CSB investigation found the root cause of the incident was multiple technical, system and organizational deficiencies. The CSB, B.P. and the oil and refining chemical sectors did not have an effective system of indicators to evaluate their safety performance. B.P. and industry sectors were, instead, typically using personal safety indicators, such as slips or trips-and-falls to measure safety performance. The CSB found that the industry needed effective leading indicators capable of reducing the risks of catastrophic failures.

API RP 754 includes examples of how to categorize incidents according to the RP’s definitions and a second document explaining the basis for categorizing hazardous chemicals by threshold quantities.

However, the CSB also found several serious shortcomings of API RP 754. Specifically, the CSB found that its indicator definitions place undo emphasis on lagging measures that are too infrequent to be useful to drive performance improvements, yet do not comprehensively count and report a likely sizeable number of leading measures that can be considered to be predictors of potentially serious process failures, and could, therefore, play a more critical prevention role.

In short, the CSB found that API is making progress with its RP 754, but that further work still needs to be accomplished.