1. RESULTS 1 ISO IMPACT ON INDUSTRIAL SAFETY STATS: MCAR: Major Chemical Accidents or Releases Since Industrial Safety Ordinance Passed 1998: It is difficult to separate impact of the ISO (or HF program) on plant safety given overlapping laws. The county & EPA are developing new safety performance indicators. See website in References box for definitions of accident severity. RESULTS 2 EXAMPLES FROM SUCCESSFUL PROGRAMS: 1. Equipment Design: Considered getting “the biggest bang for the buck” by one PSM manager, using HF in equipment design has led to: better ergonomics placement of values control panel design, e.g. consistently using green = go and red = stop on buttons better labeling and placement of equipment, improving access by maintenance workers 2. MOOC and Emergency Response: Management of Organizational Change (MOOC), measures the impact on safety due to changes in level of staffing/reorganization. One refinery matched proposed lower staffing levels with necessary roles during emergencies; found jobs could not be cut. Trend toward centralized control rooms with reduced staff make such analyses critical. 3. Operating Procedures: Improving operating procedures (routine and emergency) is a multi-year process; some refineries have already seen positive results. New written procedures use uniform format, are clearer, more sequential, and make it easier to identify potential hazards; also aids operators bidding into new units get up to speed. INTRODUCTION Following several refinery accidents, Contra Costa County passed a new Industrial Safety Ordinance (ISO) in December 1998. One element of the ISO requires refineries & chemical plants to establish a Human Factors (HF) Program within a broader Safety Plan. It also requires basic HF training for employees. LOHP developed and provided HF awareness training to refinery employees during 2000/01, using TOT method and rank-and-file workers as trainers. BACKGROUND ON HF ORDINANCE: The purpose of the ISO is to prevent the accidental release of hazardous chemicals and improve accident prevention programs. Human Factors is defined by the county as “a discipline concerned with designing machines, operations, and work environments so that they match human capabilities, limitations, and needs.” ISO builds on two existing federal laws: the OSHA Process Safety Standard (PSM) and EPA Risk Management Plan (RMP) under the Clean Air Act, and the CalARP Program. Covered plants must consider human factors during: 1. Process Hazard Analysis (PHA) 2. Root Cause Incident Investigation 3. Operating Procedures 4. Management of Organizational Change (MOOC) WORKER INVOLVEMENT AND TRAINING: The Human Factors component was added to ISO due to efforts of the PACE Local Union (Paper, Allied-Industrial, Chemical and Energy Workers International Union), which represents workers at all four refineries in the county. Employee representatives must be involved in developing the written HF plan and all employees must be trained on the plan. AREAS FOR IMPROVEMENT: 1. Refresher and Specialized HF Training: Rank and file workers need basic HF refresher training; computer-based training does not appear to be as effective as initial classroom training with discussions and activities. Current rank-and-file awareness of HF principles and their plant’s HF program varied widely. Team members (for PHAs,II, MOOC, etc.) need specialized training in HF principles and using the Latent Conditions Checklist, as well as a leader with strong facilitation skills. 2. Improved Use Latent Conditions Checklist (LCC): County audits recommend companies make a greater effort to train employees using the LCC to: understand it is a brainstorming tool to prompt further discussions contemplate and fully understand the specific reason behind each question record justifications, examples, and/or comments to explain a “Yes” or “No” DISCUSSION Recent county audits suggest that ISO/HF programs have improved but still many deficiencies. Management commitment at the top is essential; some companies have embraced the ISO/HF program and provided staff oversight and training, while others appear to have essentially paper programs. A unique strength of the ISO is that the county has secure funding (through user fees) and a staff of experienced inspectors to carry out mandated audits every 3 years) and worksite access. Oversight by the County of Board of Supervisors and communities around the plants aid in the overall climate of expectation that industrial companies operate safe plants. Beyond the county, the ordinance has sparked discussions within the broader union, corporate, and safety communities about HF, safety culture and management safety systems. Even where companies have resisted the program, union members say “at least human factors is now on the table and part of our ongoing discussions.” Use of inherently safer technologies (part of ISO) was proposed in 2 federal bills introduced last year. REFERENCES 1.) Industrial Safety Ordinance Guidance Document, Contra Costa Health Services, December 1999. Includes Attachment A: Latent Conditions Checklist (LCC). 2.) Industrial Safety Ordinance Annual Performance Review and Evaluation Report, Contra Costa Health Services, October 19, 2004. 3.) text of ISO 98-48. The above 3 sources can be found at: www.cchealth.org/groups/hazmat. 4.) Audit reports of two refinery ISO programs by Contra Costa Health Services. HUMAN FACTORS AND THE RELATIONSHIP TO WORKPLACE HEALTH AND SAFETY: A VEHICLE FOR SAFETY? Gail Bateson, MS, Pamela Tau Lee, BS, and Laura Stock, MPH University of California, School of Public Health Labor Occupational Health Program (LOHP) SURVEY METHODS This survey was to evaluate the impact of the ordinance in the refineries since it went into effect in 2001. Health and safety representatives from the union, company PSM managers, and county oversight staff were interviewed. Documents reviewed included two recent county refinery audits/inspections and the annual report on the ISO program to the County Board of Supervisors.