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This book provides a comprehensive treatment of investing chemical processing incidents. It presents on-the-job information, techniques, and examples that support successful investigations. Issues related to identification and classification of incidents (including near misses), notifications and initial response, assignment of an investigation team, preservation and control of an incident scene, collecting and documenting evidence, interviewing witnesses, determining what happened, identifying root causes, developing recommendations, effectively implementing recommendation, communicating investigation findings, and improving the investigation process are addressed in the third edition. While the focus of the book is investigating process safety incidents the methodologies, tools, and techniques described can also be applied when investigating other types of events such as reliability, quality, occupational health, and safety incidents.

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PUBLICATIONS AVAILABLE FROM THECENTER FOR CHEMICAL PROCESS SAFETYof theAMERICAN INSTITUTE OF CHEMICAL ENGINEERS

This book is one in a series of process safety guidelines and concept books published by the Center for Chemical Process Safety (CCPS). Please go to www.wiley.com/go/ccps for a full list of titles in this series.

GUIDELINES FOR INVESTIGATINGPROCESS SAFETY INCIDENTSTHIRD EDITION

CENTER FOR CHEMICAL PROCESS SAFETYOF THEAMERICAN INSTITUTE OF CHEMICAL ENGINEERSNew York, NY

This edition first published 2019© 2019 the American Institute of Chemical Engineers

A Joint Publication of the American Institute of Chemical Engineers and John Wiley & Sons, Inc.

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While the publisher and authors have used their best efforts in preparing this work, they make no representations or warranties with respect to the accuracy or completeness of the contents of this work and specifically disclaim all warranties, including without limitation any implied warranties of merchantability or fitness for a particular purpose. No warranty may be created or extended by sales representatives, written sales materials or promotional statements for this work. The fact that an organization, website, or product is referred to in this work as a citation and/or potential source of further information does not mean that the publisher and authors endorse the information or services the organization, website, or product may provide or recommendations it may make. This work is sold with the understanding that the publisher is not engaged in rendering professional services. The advice and strategies contained herein may not be suitable for your situation. You should consult with a specialist where appropriate. Further, readers should be aware that websites listed in this work may have changed or disappeared between when this work was written and when it is read. Neither the publisher nor authors shall be liable for any loss of profit or any other commercial damages, including but not limited to special, incidental, consequential, or other damages.

Library of Congress Cataloging-in-Publication Data is available.

Hardback ISBN: 9781119529071

Cover Images: Silhouette, oil refinery © manyx31/iStockphoto; Stainless steel © Creativ Studio Heinemann/Getty Images, Inc.; Dow Chemical Operations, Stade, Germany/Courtesy of The Dow Chemical Company

It is sincerely hoped that the information presented in this document will lead to an even more impressive safety record for the entire industry. However, the American Institute of Chemical Engineers, its consultants, the CCPS Technical Steering Committee and Subcommittee members, their employers, their employers’ officers and directors, and Baker Engineering and Risk Consultants, Inc.®, and its employees do not warrant or represent, expressly or by implication, the correctness or accuracy of the content of the information presented in this document. As between (1) American Institute of Chemical Engineers, its consultants, CCPS Technical Steering Committee and Subcommittee members, their employers, their employers’ officers and directors, and Baker Engineering and Risk Consultants, Inc.®, and its employees and (2) the user of this document, the user accepts any legal liability or responsibility whatsoever for the consequences of its use or misuse.

CONTENTS

Cover

PREFACE

ACKNOWLEDGMENTS

ACRONYMS AND ABBREVIATIONS

1 INTRODUCTION

1.1 BUILDING ON THE PAST

1.2 INVESTIGATION BASICS

1.3 WHO SHOULD READ THIS BOOK?

1.4 THE GUIDELINE’S OBJECTIVES

1.5 THE GUIDELINE’S CONTENT AND ORGANIZATION

1.6 THE CONTINUING EVOLUTION OF INCIDENT INVESTIGATION

2 OVERVIEW OF CHEMICAL PROCESS INCIDENT CAUSATION

2.1 STAGES OF A PROCESS-RELATED INCIDENT

2.2 KEY CAUSATION CONCEPTS

2.3 SUMMARY

3 AN OVERVIEW OF INVESTIGATION METHODOLOGIES

3.1 HISTORY OF INVESTIGATION METHODOLOGIES AND TOOLS

3.2 TOOLS FOR USE IN PREPARATION FOR ROOT CAUSE ANALYSIS

3.3 STRUCTURED ROOT CAUSE ANALYSIS METHODOLOGIES

3.4 SELECTING AN APPROPRIATE METHODOLOGY

4 DESIGNING AN INCIDENT INVESTIGATION MANAGEMENT SYSTEM

4.1 SYSTEM CONSIDERATIONS

4.2 TYPICAL MANAGEMENT SYSTEM TOPICS

4.3 MANAGEMENT SYSTEM

5 INITIAL NOTIFICATION, CLASSIFICATION AND INVESTIGATION OF PROCESS SAFETY INCIDENTS

5.1 INTERNAL REPORTING

5.2 INCIDENT CLASSIFICATION

5.3 INCIDENT NOTIFICATION

5.4 TYPE OF INVESTIGATION

5.5 SUMMARY

6 BUILDING AND LEADING AN INCIDENT INVESTIGATION TEAM

6.1 TEAM APPROACH

6.2 ADVANTAGES OF THE TEAM APPROACH

6.3 LEADING A PROCESS SAFETY INCIDENT INVESTIGATION TEAM

6.4 POTENTIAL TEAM COMPOSITION

6.5 BUILDING A TEAM FOR A SPECIFIC INCIDENT

6.6 TEAM ACTIVITIES

6.7 SUMMARY

7 WITNESS MANAGEMENT

7.1 OVERVIEW

7.2 IDENTIFYING WITNESSES

7.3 WITNESS INTERVIEWS

7.4 CONDUCTING FOLLOW-UP ACTIVITIES

7.5 CONDUCTING FOLLOW-UP INTERVIEWS

7.6 RELIABILITY OF WITNESS STATEMENTS

7.7 SUMMARY

8 EVIDENCE IDENTIFICATION, COLLECTION AND MANAGEMENT

8.1 OVERVIEW

8.2 SOURCES OF EVIDENCE

8.3 EVIDENCE GATHERING

8.4 TIMELINES AND SEQUENCE DIAGRAMS

8.5 SUMMARY

9 EVIDENCE ANALYSIS AND CAUSAL FACTOR DETERMINATION

9.1 SCIENTIFIC METHOD

9.2 CONFIRMATION BIAS

9.3 EVIDENCE ANALYSIS

9.4 HYPOTHESIS FORMULATION

9.5 HYPOTHESIS TESTING

9.6 SELECT THE FINAL HYPOTHESIS

9.7 SUMMARY

10 DETERMINING ROOT CAUSES—STRUCTURED APPROACHES

10.1 CONCEPT OF ROOT CAUSE ANALYSIS

10.2 CASE HISTORIES

10.3 METHODOLOGIES FOR ROOT CAUSE ANALYSIS

10.4 ROOT CAUSE DETERMINATION USING LOGIC TREES

10.5 BUILDING A LOGIC TREE

10.6 EXAMPLE APPLICATIONS

10.7 ROOT CAUSE DETERMINATION USING PREDEFINED TREES

10.8 USING PREDEFINED TREES

10.9 CHECKLISTS

10.10 HUMAN FACTORS APPLICATIONS

10.11 SUMMARY

11 THE IMPACT OF HUMAN FACTORS

11.1 HUMAN FACTORS CONCEPTS

11.2 INCORPORATING HUMAN FACTORS INTO THE INCIDENT INVESTIGATION PROCESS

11.3 OTHER REFERENCES

11.4 SUMMARY

12 DEVELOPING EFFECTIVE RECOMMENDATIONS

12.1 KEY CONCEPTS

12.2 DEVELOPING EFFECTIVE RECOMMENDATIONS

12.3 TYPES OF RECOMMENDATIONS

12.4 THE RECOMMENDATION PROCESS

12.5 SUMMARY

13 PREPARING THE FINAL REPORT

13.1 REPORT SCOPE

13.2 INTERIM REPORTS

13.3 WRITING THE REPORT

13.4 SAMPLE REPORT FORMAT

13.5 REPORT REVIEW AND QUALITY ASSURANCE

13.6 INVESTIGATION DOCUMENT AND EVIDENCE RETENTION

13.7 SUMMARY

14 IMPLEMENTING RECOMMENDATIONS

14.1 ACTIVITIES RELATED TO RECOMMENDATION IMPLEMENTATION

14.2 VALIDATION OF EFFECTIVENESS – CASE STUDIES

14.3 PRACTICAL SUGGESTIONS FOR SUCCESSFUL RECOMMENDATION IMPLEMENTATION

15 CONTINUOUS IMPROVEMENT FOR THE INCIDENT INVESTIGATION SYSTEM

15.1 REGULATORY COMPLIANCE REVIEW

15.2 INVESTIGATION QUALITY ASSESSMENT

15.3 CAUSAL CATEGORY ANALYSIS

15.4 REVIEW OF NEAR-MISS EVENTS

15.5 RECOMMENDATIONS REVIEW

15.6 INVESTIGATION FOLLOW-UP REVIEW

15.7 KEY PERFORMANCE INDICATORS

15.8 SUMMARY

16 LESSONS LEARNED

16.1 VARIOUS SOURCES OF LEARNING FROM INCIDENTS

16.2 IDENTIFYING LEARNING OPPORTUNITIES

16.3 SHARING AND INSTITUTIONALIZING LESSONS LEARNED

16.4 SENIOR MANAGEMENT – INCIDENT SHARING AND COMMITMENT

16.5 EXAMPLES OF SHARING LESSONS LEARNED

16.6 SUMMARY

APPENDIX A.PHOTOGRAPHY GUIDELINES FOR MAXIMUM RESULTS

APPENDIX B. EXAMPLE PROTOCOL – CHECKING POSITION OF A CHAIN VALVE

APPENDIX C. PROCESS SAFETY EVENTS LEVELING CRITERIA

APPENDIX D. EXAMPLE CASE STUDY

APPENDIX E. QUICK CHECKLIST FOR INVESTIGATORS

APPENDIX F. EVIDENCE PRESERVATION CHECKLIST – PRIOR TO ARRIVAL OF THE INVESTIGATION TEAM

APPENDIX G. GUIDANCE ON CLASSIFYING POTENTIAL SEVERITY OF A LOSS OF PRIMARY CONTAINMENT

GLOSSARY

REFERENCES

INDEX

WILEY END USER LICENSE AGREEMENT

List of Tables

Chapter 2

Table 2.1

Chapter 3

Table 3.1

Chapter 4

Table 4.1

Chapter 5

Table 5.1

Table 5.2

Table 5.3

Table 5.4

Chapter 6

Table 6.1

Chapter 7

Table 7.1

Chapter 8

Table 8.1

Table 8.2

Table 8.3

Table 8.4

Table 8.5

Chapter 9

Table 9.1

Chapter 10

Table 10.1

Table 10.2

Table 10.3

Chapter 11

Table 11.1

Chapter 13

Table 13.1

Table 13.2

Table 13.3

Chapter 15

Table 15.1

Table 15.2

Table 15.3

Table 15.4

Table 15.5

Chapter 16

Table 16.1

List of Illustrations

Chapter 2

Figure 2.1 Event Tree for a Process-related Incident

Figure 2.2 Swiss Cheese Model

Figure 2.3 Latent (hidden) Failure

Figure 2.4 Incident Prevention Strategies

Figure 2.5 Universal Concept for Controlling Risk (Kletz)

Chapter 3

Figure 3.1 Overview of Investigation Tools

Figure 3.2 Schematic of an MES display (Benner, 2000)

Figure 3.3 Top Portion of the Generic MORT Tree

Figure 3.4 Common Features of Investigation Methodologies

Chapter 4

Figure 4.1 Management System for Process Safety Investigation

Figure 4.2 Checklist for Developing an Incident Investigation Plan

Chapter 5

Figure 5.1 . Logic Tree for Determining Incident Classification

Figure 5.2 Example Risk Matrix for Determining Incident Classification

Chapter 6

Figure 6.1 Investigation Team Collaboration

Chapter 7

Figure 7.1 Iteration between Witness and Physical Evidence Collection and Analysis

Figure 7.2 List of Potential Witnesses

Figure 7.3 . Illustration of Human Observation Limitations

Figure 7.4 Overview of Interview Process

Chapter 8

Figure 8.1 Iteration between Data Analysis and Data Gathering

Figure 8.2. Forms of Data Fragility

Figure 8.3 As-found Position of Valves—Example Photo

Figure 8.4 Initial Site Visit—Example Photo

Figure 8.5 Timeline Example Based on Precise Data

Figure 8.6 Timeline Example Based on Approximate Data

Figure 8.7 Timeline Example Based on a Combination of Precise and Approximate Data

Figure 8.8 Timeline Tips

Figure 8.9 Sequence Diagram for Tank Overflow Example

Chapter 9

Figure 9.1 Scientific Method Process

Figure 9.2 Basic Steps in Failure Analysis

Figure 9.3 Rules for Causal Factor Charting

Figure 9.4 Example of a Causal Factor Chart

Chapter 10

Figure 10.1 Example of 5 Whys Root Cause Analysis

Figure 10.2 Example of Ishikawa Fishbone Diagram

Figure 10.3 Structured Root Cause Methods Described in This Chapter

Figure 10.4 . Flowchart for Root Cause Determination Using Logic Trees

Figure 10.5 Generic Logic Tree Displaying the AND-Gate

Figure 10.6 Generic Logic Tree for a Fire

Figure 10.7 Generic Logic Tree Displaying the OR-Gate

Figure 10.8 Logic Tree using the OR-Gate to establish an Ignition Source

Figure 10.9 Other Symbols Used in Logic Trees

Figure 10.10 Logic Tree Tips

Figure 10.11 Example Top of the Logic Tree, Employee Slip

Figure 10.12 Example Logic Tree Branch Level, Oil Spill

Figure 10.13 Example Logic Tree, Hand-carried Containers

Figure 10.14 Logic Tree, Slip/ Trip/ Fall Incident

Figure 10.15 Logic Tree Top, Employee Burn

Figure 10.16 Logic Tree Branch, Acid Spray

Figure 10.17 Expanded Logic Tree Sample, Employee Burn

Figure 10.18 Operator Fatality Branch

Figure 10.19 Fire Branch

Figure 10.20 Fact/Hypothesis Matrix for the Kettle Exit Piping Failure

Figure 10.21 Exit Piping Crack Branch

Figure 10.22 Flowchart for Root Cause Determination—Predefined Tree/ Checklist

Figure 10.23 Example of Root Causes Arranged Hierarchically within a Section of a Predefined...

Figure 10.24 Incident Sequence

Figure 10.25 Complete Causal Factor Chart for Fish Kill Incident

Figure 10.26 Top of the Predefined Tree

Figure 10.27 First Question of the Human Performance Difficulty Category

Figure 10.28 Human Engineering Branch of the Tree

Figure 10.29 Analysis of the Human Engineering Branch

Chapter 11

Figure 11.1 Common Human Factors Model (CCPS, 2007)

Figure 11.2 Example of Poor Pump and Switch Arrangement

Figure 11.3 Incident Causation Model (EI, 2016)

Chapter 12

Figure 12.1 Incident Investigation Recommendation Flowchart

Figure 12.2 Layers of Safety (Foord, 2004)

Figure 12.3 Bow-Tie Barrier Method

Figure 12.4 Example Recommendations and Assessment Strategies (ABS, 2001)

Chapter 14

Figure 14.1 Flowchart for Implementation and Follow-up

Chapter 16

Figure 16.1 Example Safety Alert

Figure 16.2 CCPS Process Safety Beacon

Figure 16.3 ICI Safety Newsletter No. 96/ 1 & 2

Figure 16.4 ICI Safety Newsletter No. 96/7

Figure 16.5 Learning Event Report Example

Figure 16.6 Process Safety Bulletin Example

Guide

Cover

Table of Contents

INTRODUCTION

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LIST OF FIGURES

Figure 2.1 Event Tree for a Process-related Incident

Figure 2.2 Swiss Cheese Model

Figure 2.3 Latent (hidden) Failure

Figure 2.4 Incident Prevention Strategies

Figure 2.5 Universal Concept for Controlling Risk

Figure 3.1 Overview of Investigation Tools

Figure 3.2 Schematic of an MES display

Figure 3.3 Top Portion of the Generic MORT Tree

Figure 3.4 Common Features of Investigation Methodologies

Figure 4.1 Management System for Process Safety Investigation

Figure 4.2 Checklist for Developing an Incident Investigation Plan

Figure 5.1 Logic Tree for Determining Incident Classification

Figure 5.2 Example Risk Matrix for Determining Incident Classification

Figure 6.1 Investigation Team Collaboration

Figure 7.1 Iteration between Witness and Physical Evidence Collection and Analysis

Figure 7.2 List of Potential Witnesses

Figure 7.3 Illustration of Human Observation Limitations

Figure 7.4 Overview of Interview Process

Figure 8.1 Iteration between Data Analysis and Data Gathering

Figure 8.2 Forms of Data Fragility

Figure 8.3 As-found Position of Valves—Example Photo

Figure 8.4 Initial Site Visit—Example Photo

Figure 8.5 Timeline Example Based on Precise Data

Figure 8.6 Timeline Example Based on Approximate Data

Figure 8.7 Timeline Example Based on a Combination of Precise and Approximate Data

Figure 8.8 Timeline Tips

Figure 8.9 Sequence Diagram for Tank Overflow Example

Figure 9.1 Scientific Method Process

Figure 9.2 Basic Steps in Failure Analysis

Figure 9.3 Rules for Causal Factor Charting

Figure 9.4 Example of a Causal Factor Chart

Figure 10.1 Example of 5 Whys Root Cause Analysis

Figure 10.2 Example of Ishikawa Fishbone Diagram

Figure 10.3 Structured Root Cause Methods Described in This Chapter

Figure 10.4 Flowchart for Root Cause Determination Using Logic Trees

Figure 10.5 Generic Logic Tree Displaying the AND-Gate

Figure 10.6 Generic Logic Tree for a Fire

Figure 10.7 Generic Logic Tree Displaying the OR-Gate

Figure 10.8 Logic Tree using the OR-Gate to establish an Ignition Source

Figure 10.9 Other Symbols Used in Logic Trees

Figure 10.10 Logic Tree Tips

Figure 10.11 Example Top of the Logic Tree, Employee Slip

Figure 10.12 Example Logic Tree Branch Level, Oil Spill

Figure 10.13 Example Logic Tree, Hand-carried Containers

Figure 10.14 Logic Tree, Slip/Trip/Fall Incident

Figure 10.15 Logic Tree Top, Employee Burn

Figure 10.16 Logic Tree Branch, Acid Spray

Figure 10.17 Expanded Logic Tree Sample, Employee Burn

Figure 10.18 Operator Fatality Branch

Figure 10.19 Fire Branch

Figure 10.20 Fact/Hypothesis Matrix for the Kettle Exit Piping Failure

Figure 10.21 Exit Piping Crack Branch

Figure 10.22 Flowchart for Root Cause Determination—Predefined Tree/Checklist

Figure 10.23 Example of Root Causes Arranged Hierarchically within a Section of a Predefined Tree

Figure 10.24 Incident Sequence

Figure 10.25 Complete Causal Factor Chart for Fish Kill Incident

Figure 10.26 Top of the Predefined Tree

Figure 10.27 First Question of the Human Performance Difficulty Category

Figure 10.28 Human Engineering Branch of the Tree

Figure 10.29 Analysis of the Human Engineering Branch

Figure 11.1 Common Human Factors Model

Figure 11.2 Example of Poor Pump and Switch Arrangement

Figure 11.3 Incident Causation Model

Figure 12.1 Incident Investigation Recommendation Flowchart

Figure 12.2 Layers of Safety

Figure 12.3 Bow-Tie Barrier Method

Figure 12.4 Example Recommendations and Assessment Strategies

Figure 14.1 Flowchart for Implementation and Follow-up

Figure 16.1 Example Safety Alert

Figure 16.2 CCPS Process Safety Beacon

Figure 16.3 ICI Safety Newsletter No. 96/1 & 2

Figure 16.4 ICI Safety Newsletter No. 96/7

Figure 16.5 Learning Event Report Example

Figure 16.6 Process Safety Bulletin Example

LIST OF TABLES

Table 2.1 Attributes of a Management System

Table 3.1 Some Characteristics of Selected Public Methodologies

Table 4.1 Suggested Training for Effective Implementation

Table 5.1 Common Classification Schemes

Table 5.2 Tier 1 Process Safety Event Severity Categories

Table 5.3 Example of Likelihood Levels for Determining Incident Classification

Table 5.4 Examples of the Impacts of a 1000-lb Cyclohexane Release

Table 7.1 Example Questions for Witnesses and Emergency Responders

Table 8.1 Scene Activities and Typical Responsibilities

Table 8.2 Examples of Paper Evidence

Table 8.3 Examples of Electronic Data

Table 8.4 Examples of Position Data

Table 8.5 Example Data Collection Form for Recording Physical Evidence

Table 9.1 Example Fact/Hypothesis Matrix – Chemical Reduction Explosion

Table 10.1 Strengths and Weaknesses of the 5 Whys Technique

Table 10.2 Strengths and Weaknesses of Logic Trees

Table 10.3 Strengths and Weaknesses of Predefined Trees

Table 11.1 Human Factors Issues

Table 13.1 Sample Sections of an Incident Investigation Report

Table 13.2 Findings, Causal Factors, Root Causes and Recommendations

Table 13.3 Example Checklist for Written Reports

Table 15.1 Requirement Compliance Checklist

Table 15.2 Investigation Key Element Audit Checklist

Table 15.3 Example Categories for Incident Investigation Findings

Table 15.4 Recommendations Review Checklist

Table 15.5 Example Follow-Up Checklist

Table 16.1 Questions for Identifying Learning Opportunities

PREFACE

The American Institute of Chemical Engineers (AIChE) has helped chemical plants, petrochemical plants, and refineries address the issues of process safety and loss control for over 30 years. Through its ties with process designers, plant constructors, facility operators, safety professionals, and academia, the AIChE has enhanced communication and fostered improvement in the high safety standards of the industry. AIChE’s publications and symposia have become an information resource for the chemical engineering profession on the causes of incidents and the means of prevention.

The Center for Chemical Process Safety (CCPS), a directorate of AIChE, was established in 1985 to develop and disseminate technical information for use in the prevention of major chemical accidents. CCPS is supported by a diverse group of industrial sponsors in the chemical process industry and related industries who provide the necessary funding and professional guidance for its projects. The CCPS Technical Steering Committee and the technical subcommittees oversee individual projects selected by the CCPS. Professional representatives from sponsoring companies staff the subcommittees and a member of the CCPS staff coordinates their activities.

Since its founding, CCPS has published many volumes in its “Guidelines” series and in smaller “Concept” texts. Although most CCPS books are written for engineers in plant design and operations and address scientific techniques and engineering practices, several guidelines cover subjects related to chemical process safety management. A successful process safety program relies upon committed managers at all levels of a company, who view process safety as an integral part of overall business management and act accordingly.

Incident investigation is an essential element of every process safety management program. This book presents underlying principles, management system considerations, investigation tools, and specific methodologies for investigating incidents in a way that will support implementation of a rigorous process safety program at any facility. The principles and suggested practices contained in this expanded third edition are not limited to chemical and petroleum process incidents. The basic concepts and provided examples are equally applicable to mining, pharmaceutical, manufacturing, mail order fulfillment, and numerous other hazardous industries.

A team of incident investigation experts from the petroleum, chemical, and consulting industries, as well as a regulatory agency representative, drafted the chapters for this guideline and provided real-world examples to illustrate some of the tools and methods used in their profession. The subcommittee members reviewed the content extensively and industry peers evaluated this book to help ensure it represents a factual accounting of industry best practices. This third edition of the guideline provides updated information on many facets of the investigative process as well as additional details on important considerations such as human factors, forensics, and legalities surrounding incident investigations.

ACKNOWLEDGMENTS

The American Institute of Chemical Engineers wishes to thank the Center for Chemical Process Safety (CCPS) and those involved in its operation, including its many sponsors whose funding made this project possible; the members of its Technical Steering Committee who conceived of and supported this Guidelines project; and the members of its Incident Investigation Subcommittee. The Incident Investigation Subcommittee of the Center for Chemical Process Safety authored this third edition of the Guidelines for Investigating Process Safety Incidents.

The members of the CCPS Incident Investigation Subcommittee were:

Michael Broadribb, Baker Engineering and Risk Consultants, Inc.

Laurie Brown, Eastman Chemical Company

Chonai Cheung, Contra Costa County

Eddie Dalton, BASF

Carolina Del Din, PSRG

Jerry Forest, Celanese, Subcommittee Chair

Scott Guinn, Chevron Corporation

Christopher Headen, Cargill

Kathleen Kas, Dow Chemical Company

Mark Paradies, System Improvements, Inc.

Nestor Paraliticci, Andeavor

Muddassir Penkar, Evonik Canada Inc.

Morgan Reed, Exponent

Meg Reese, Occidental Chemical Corp.

Marc Rothschild, DuPont

Joy Shah, Reliance Industries Ltd

Dan Sliva, CCPS Staff Advisor

Robert (Bob) Stankovich, Eli Lilly

Lee Vanden Heuvel, ABS Consulting

Terry Waldrop, AIG

Scott Wallace, Olin

Della Wong, Canadian Natural Resources

The third edition was authored by Baker Engineering and Risk Consultants, Inc. The authors at BakerRisk were:

Quentin A. Baker

Michael P. Broadribb

Cheryl A. Grounds

Thomas V. Rodante

Roger C. Stokes

Dan Sliva was the CCPS staff liaison and was responsible for overall administration of the project.

CCPS also gratefully acknowledges the comments and suggestions received from the following peer reviewers:

Amy Breathat, NOVA Chemicals Corporation

Steven D. Emerson, Emerson Analysis

Patrick Fortune, Suncor Energy

Walter L. Frank, Frank Risk Solutions, Inc.

Barry Guillory, Louisiana State University

Jerry L. Jones, CFEISBC Global

Gerald A. King, Armstrong Teasdale LLP

Susan M. Lee, Andeavor

William (Bill) D. Mosier, Syngenta Crop Protection, LLC

Mike Munsil, PSRG

Pamela Nelson, Solvay Group

Katherine Pearson, BP Americas

S. Gill Sigmon, AdvanSix

Their insights, comments, and suggestions helped ensure a balanced perspective to this Guideline.

The efforts of the document editor at BakerRisk are gratefully acknowledged for contributions in editing, layout, and assembly of the book. The document editor was Phyllis Whiteaker.

The members of the CCPS Incident Investigation Subcommittee wish to thank their employers for allowing them to participate in this project and lastly, we wish to thank Anil Gokhale of the CCPS staff for his support and guidance.

ACRONYMS AND ABBREVIATIONS

ACC

American Chemistry Council

AIChE

American Institute of Chemical Engineers

ALARP

As Low as Reasonably Practicable

ANSI

American National Standards Institute

API

American Petroleum Institute

ARIP

Accidental Release Information Program

ARIA

Analysis, Research and Information on Accidents

ASME

American Society of Mechanical Engineers

BARPI

Bureau for Analysis of Industrial Risks and Pollutions

BP

Boiling Point

BI

Business Interruption

BLEVE

Boiling Liquid Expanding Vapor Explosion

BPCS

Basic Process Control System

C

Consequence factor, related to magnitude of severity

CCF

Common Cause Failure

CCPS

Center for Chemical Process Safety,

CE/A

Change Evaluation/Analysis

CEFIC

(European) Chemical Industry Council

CEI

Dow Chemical Exposure Index

CELD

Cause and Effect Logic Diagram

CFD

Computational Fluid Dynamics

CIRC

Chemical Incidents Report Center

CLC

Comprehensive List of Causes

COMAH

Control of Major Accident Hazards

CPQRA

Chemical Process Quantitative Risk Assessment

CSB

Chemical Safety and Hazards Investigation Board (US)

CTM

Causal Tree Method

CW

Cooling Water

D

Number of times a component or system is challenged (hr–1 or year–1)

DCS

Distributed Control System

DIERS

Design Institute for Emergency Relief Systems

DMAIC

Define, Measure, Analyze, Improve, Control

DOT

Department of Transportation

E& CF

Events & Causal Factor Charting

EBV

Emergency Block Valve

EHS

Environmental, Health & Safety

EI

Energy Institute

EPA

United States Environmental Protection Agency

eMARS

European Commission Major Accident Reporting System

EPSC

European Process Safety Centre

ERPG

Emergency Response Planning Guideline

ETA

Event Tree Analysis

F

Failure Rate (hr–1 or year–1)

f

Frequency (hr–1 or year–1)

F& EI

Dow Fire and Explosion Index

F/N

Fatality Frequency versus Cumulative Number

FCE

Final Control Element

FEA

Finite Element Analysis

FMEA

Failure Modes and Effect Analysis

FTA

Fault Tree Analysis

HAZMAT

Hazardous Materials

HAZOP

Hazard and Operability Study

HAZWOPER

Hazardous Waste Operations and Emergency Response

HBTA

Hazard–Barrier–Target Analysis

HE

Hazard Evaluation

HIRA

Hazard Identification and Risk Analysis

HMI

Human Machine Interface

HSE

(UK) Health and Safety Executive

HRA

Human Reliability Analysis

ICCA

International Council of Chemical Associations

IChemE

Institution of Chemical Engineers

IEC

International Electrotechnical Commission

IEEE

Institute of Electrical and Electronic Engineers

IOGP

International Association of Oil & Gas Producers

IPL

Independent Protection Layer

ISA

The Instrumentation, Systems, and Automation Society (formerly, Instrument Society of America)

ISBL

Inside Battery Limits

ISD

Inherently Safer Design

ISO

International Organization for Standardization

JSA

Job Safety Analysis

KPI

Key Performance Indicators

LAH

Level Alarm—High

LAL

Level Alarm—Low

LEL

Lower Explosive Limit

LFL

Lower Flammability Limit

LI

Level Indicator

LIC

Level Indicator—Control

LNG

Liquefied Natural Gas

LOPA

Layer of Protection Analysis

LOPC

Loss of Primary Containment

LOTO

Lockout/Tagout

LSHH

Level Sensor High High

LT

Level Transmitter

MARS

Major Accident Reporting System

MAWP

Maximum Allowable Working Pressure

MCSOII

Multiple-Cause, Systems-Oriented Incident Investigation

MES

Multilinear Event Sequencing

MHIDAS

Major Hazard Incident Data System

MI

Mechanical Integrity

MIC

Methyl isocyanate

MM

Million

MOC

Management of Change

MOM

Singapore's regulatory standard for incident investigation

MORT

Management Oversight Risk Tree

MSDS

Material Safety Data Sheet

NAICS

North American Industry Classification System

NFPA

National Fire Protection Association

N

2

Nitrogen

NOM

Mexico's regulatory standard for incident investigations

NTSB

National Transportation Safety Board

IOGP

International Association of Oil and Gas Producers

OREDA

The Offshore Reliability Data project

ORPS

Occurrence Reporting and Processing System

OSBL

Outside Battery Limits

OSHA

United States Occupational Safety and Health Administration

P

fatality

Probability of Fatality

P

ignition

Probability of Ignition

P

person present

Probability of Person Present

P

Probability

P& ID

Piping and Instrumentation Diagram

PCB

Polychlorinated Biphenyl

PFD

Probability of Failure on Demand

PHA

Process Hazard Analysis

PI

Pressure Indicator

PIF

Performance Influencing Factor

PL

Protection Layer

PLC

Programmable Logic Controller

PM

Preventive Maintenance

PPE

Personal Protective Equipment

PSHH

Pressure Sensor High High

PSI

Process Safety Information

PSID

Process Safety Incident Database

PSM

Process Safety Management

PSM

also Canada's (non-regulatory) standard, individualized by district

PSV

Pressure Safety Valve (Relief Valve)

R

Risk

RCA

Root Cause Analysis

RIDDOR

Reporting of Injuries, Diseases and Dangerous Occurrence Regulations

RMP

Risk Management Program (US)

RQ

Release Quantity

RV

Relief Valve

SAWS

China's regulatory guideline for incident investigations

SCAT

Systematic Cause Analysis Technique

SCE

Safety Critical Equipment

SDS

Safety Data Sheets

SEMS

Safety and Environmental Management System

SHE

Safety Health & Environment

SIF

Safety Instrumented Function

SIS

Safety Instrumented System

SMART

Specific, Measureable, Agreed/Attainable, and Realistic/Relevant, with Timescales

SOL

Safe Operating Limit

SOP

Standard Operating Procedure

SOURCE

Seeking Out the Underlying Root Causes of Events

SRK

Skills, Rules, Knowledge

SSDC

System Safety Development Center

STEP

Sequentially Timed Events Plot

T

Test Interval for the Component or System (hours or years)

T

0

starting time

T

n

ending time

TNO

Nederlandse Organisatie voor Toegepast

Natuurwetenschappelijk Onderzoek (TNO; English:Netherlands Organization for Applied Scientific Research)

UEL

Upper Explosive Limit

UFL

Upper Flammable Limit

VCE

Vapor Cloud Explosion

VLE

Vapor Liquid Equilibrium

XV

Remote Activated/Controlled Valve

1INTRODUCTION

1.1 BUILDING ON THE PAST

Flixborough, Bhopal, Piper Alpha, Deepwater Horizon, Buncefield— all are now synonyms for catastrophe. These names are inextricably linked with images of death, suffering, environmental damage and disastrous loss tied to the production of chemicals, fuels, or oils. An objective review of the world’s industrial history reveals a story punctuated with infrequent yet similarly tragic incidents. Invariably, in the wake of such tragedy, companies, industries, and governments work together to learn the causes. Their ultimate goal is to implement the knowledge acquired through diligent investigation, which in turn can help prevent recurrence or mitigate consequences.

Investigations into catastrophic events have revealed something of major significance—the key to preventing disaster first lies in recognizing leading indicators rather than the lagging indicators. Leading indicators exist, and therefore can be uncovered, in incidents that are much less than catastrophic. They can even be seen in so-called near-misses that may have no discernable impact on routine operation. By examining abnormal/upset operations, near-misses, and lower-consequence higher-frequency occurrences, companies may identify deficiencies that, if left uncorrected, could eventually result in serious or even catastrophic events.

The two most significant roles incident investigations can play in comprehensive process safety programs are:

Preventing disasters by consistently examining and learning from near-misses (inclusive of abnormal operations, minor events, etc.) and;

Preventing disasters by consistently examining and learning from more serious accidents.

The Center for Chemical Process Safety (CCPS) of the American Institute of Chemical Engineers (AIChE) recognized the role of incident investigation when it published the original Guidelines for Investigating Chemical Process Incidents in 1992.

The first edition provided a timely treatment of incident investigation including:

a detailed examination of the role of incident investigation in a process safety management system,

guidance on implementing an incident investigation system, and

in-depth information on conducting incident investigations, including the tools and techniques most useful in understanding the underlying causes.

The second edition, released in 2003, built on the first text’s solid foundation. The goal was to retain the knowledge base provided in the original book while simultaneously updating and expanding upon it to reflect the latest thinking. That edition presented techniques used by the world’s leading practitioners in the science of process safety incident investigation.

This third edition is a further enhancement of the second edition. Specific emphasis has been placed on updating investigation techniques and analytical methodologies, and applying them to example case studies where possible. Expanded topics include scientific validation of hypotheses, rigorous physical evidence documentation and examination, scientific analysis, hypothesis rejection and substantiation, learnings from repeat incidents, and means to institutionalize learnings within an organization.

1.2 INVESTIGATION BASICS

Successful investigations are dependent on preplanning, documented procedures, appropriate investigator training and experience, appropriate support from leadership, and necessary resources (personnel, time, and materials), to conduct a thorough investigation. It is imperative that operating organizations conduct careful and comprehensive investigations that are factual and defensible. Developing and following written procedures allows organizations to consistently respond promptly and effectively, establishes the basis for continuous improvement, and helps preserve a company’s “license to operate”.

1.2.1 The First Step in conducting a successful incident investigation is to recognize when an incident has occurred so that an Incident Management System (Chapter 4) can be activated. Linked with incident recognition are Initial Notification, Classification, and Investigation (Chapter 5).

It is important to use standard terminology when referring to incident investigation so that those investigating an occurrence all share a common language that efficiently and accurately supports their investigation objectives. Some investigators may define the terms presented below slightly differently or use other descriptive terms that have the same meaning. Some organizations may desire to further sub-divide these terms into different levels. Within the scope of this book, the following definitions for key terms will apply throughout:

1.2.1.1 Incident—an unusual, unplanned, or unexpected occurrence that either resulted in, or had the potential to result in harm to people, damage to the environment, or asset/business losses, or loss of public trust or stakeholder confidence in a company’s reputation. Some examples are:

process upset with potential process excursions beyond operating limits,

release of energy or materials,

challenges to a protective barrier,

loss of product quality control,

etc.

1.2.1.1(a) Accident—an incident that results in a significant consequence involving:

human impact,

detrimental impact on the community or environment,

property damage, material loss,

disruption of a company’s ability to continue doing business or achieve its business goals, (e.g. loss of operating license, operational interruption, product contamination, etc.).

1.2.1.1(b) Near-miss—an incident in which an adverse consequence could potentially have resulted if circumstances (weather conditions, process safeguard response, adherence to procedure, etc.) had been slightly different.

For most occurrences, protective barriers prevent a resultant adverse consequence. Such occurrences are often referred to as near-hits, near-misses, or close calls. For every incident labeled a near-miss, more subtle precursors exist that, if investigated and understood, could provide valuable insights into factors that could be applied to mitigating or preventing other incidents.

1.2.2 The Second Step in conducting a thorough investigation is to assemble a qualified team (Chapter 6) that will determine and analyze the facts of the incident. This team’s charter is to apply appropriate investigation tools and methodologies (Chapter 3) that will lead to the identification of the latent causes and application of remedies that could have prevented the incident or mitigated its consequence.

1.2.3 The Third Step in incident investigation is to gather information, separate facts from suppositions, analyze data, and determine what happened. Before conducting a cause analysis, a comprehensive and accurate understanding of what happened must first be completed. Witness management (Chapter 7), evidence management Chapter 8), and evidence analysis and hypothesis testing (Chapter 9) are key concepts to be employed during the investigation process.

1.2.4 The Fourth step in incident investigation is to determine root causes for the failure(s) that initiated or failed to prevent the incident. Note that root cause is being used in this book in the traditional sense, i.e.:

Root Cause - A fundamental, underlying, system-related reason why an incident occurred that identifies a correctable failure(s) in management systems.

By this definition, a root cause is the most fundamental level in the cause determination, and there is no more fundamental level. Recommendations can be developed for root causes that will prevent, lessen the likelihood, and/or consequence, of the same and similar incidents from occurring. Whereas, causal factors are invariably contributory in nature and, for the purposes of this book, are defined as:

Causal Factor - A major unplanned, unintended contributor to an incident (a negative event or undesirable condition), that if eliminated would have either prevented the occurrence of the incident, or reduced its severity or frequency.

This definition implies that, if recommendations are based on causal factors, they would only prevent the same incident but not similar incidents from occurring. Therefore, recommendations should be based on root causes.

Once the most likely hypothesis is validated, determining root causes via a structured approach (Chapter 10) will help the investigation team determine all relevant factors. Understanding the impact of human factors is key to identifying root causes and is discussed in detail in (Chapter 11). Once root causes have been identified, effective recommendations can be developed (Chapter 12).

1.2.5 The Fifth Step in incident investigation is preparing the investigation report (Chapter 13) which details the facts, findings, and recommendations prepared by the investigation team. Typically, recommendations are written to prevent incident recurrence by:

improving the process technology,

upgrading the operating or maintenance procedures or practices,

improving compliance with existing organizational systems (operational discipline); and

upgrading the management systems, (often the most critical area).

1.2.6 The Sixth Step in incident investigation is to implement and communicate the team’s conclusions. After the investigation is completed and the findings and recommendations are issued in the report, a system is needed to implement and audit those recommendations (Chapter 14). This is not part of the investigation itself, but rather the follow-up related to it. Once a technological, procedural, or administrative corrective action is enacted, it is monitored periodically for effectiveness and, where appropriate, modified to meet the intent of the original recommendation. Learnings from an investigation can also be institutionalized and shared throughout the company and industry, particularly with those most affected by the incidents.

These six steps will result in the greatest positive effect when they are performed in an atmosphere of openness and trust. Management demonstrates, by both word and deed, that the primary objective is not to assign blame, but to implement system fixes and share learnings for the sake of preventing future incidents. This book helps organizations define and refine their incident investigation systems to achieve positive results effectively and efficiently.

1.3 WHO SHOULD READ THIS BOOK?

This book assists three target groups:

Incident investigation team leaders

Incident investigation team members

Corporate and site process safety managers and coordinators

This book provides a valuable reference tool for anyone directly involved in leading or participating on incident investigation teams. It presents knowledge, techniques, and examples to support successful investigations. This book offers a model for success in building or upgrading an incident investigation program.

Like previous editions, the book remains focused primarily on investigating process-related incidents. Most organizations find that integrating process safety with other types of investigations provides an opportunity to enhance any investigation. Readers will find that the methodologies, tools, and techniques described in the following chapters may be successfully applied when investigating other types of occurrences such as operational reliability, product quality, and occupational health and safety incidents.

1.4 THE GUIDELINE’S OBJECTIVES

Readers should be able to achieve the following objectives.

Describe the basic principles behind successful incident investigations.

Identify the essential features of a management system designed to foster and support high quality incident investigations.

List detailed steps for planning and conducting incident investigations, including investigative tools, techniques, and methodologies for determining causes.

Use the findings of an investigation to make effective recommendations that can reduce the likelihood of recurrence or mitigate the consequences of similar incidents (or even dissimilar incidents with common root causes).

Plan an effective system for documenting, communicating, and resolving investigation findings and recommendations, including a method to track resolution of incident recommendations.

Effectively share the learnings of investigations and institutionalize learnings to prevent the lessons from being lost over time.

1.5 THE GUIDELINE’S CONTENT AND ORGANIZATION

The summaries below provide an overview of the content and organization of the book chapter-by-chapter to assist in quickly locating a particular area of interest.

Chapter 2—Overview of Chemical Process Incident Causation

This chapter discusses the basics of determining incident causation, general types of incidents, and the linkage between causation theories, root causes, and management systems. Understanding incident sequence models, barrier analysis, and failure modes can greatly assist investigators in dissecting the anatomy of process incidents.

Chapter 3—An Overview of Investigation Methodologies

This chapter provides an overview of investigation methodologies, associated tools, and techniques that come together to form a modern structured investigate approach. An overview of the historical transition is provided along with description of methodologies and tools most commonly used by CCPS members.

Chapter 4—Designing an Incident Investigation Management System

This chapter provides an overview of a management system for investigating process safety incidents. It opens with a review of responsibilities from management through the workforce and presents the important features that a management system can address to be effective. It examines systematic approaches that start with notification, team structure, functional and agency integration, document control, team objectives, etc. The learning objective is to define a management system that supports incident investigation teams, root cause determinations, effective recommendation implementation, follow-up, and continuous improvement.

Chapter 5—Initial Notification, Classification, and Investigation of Process Safety Incidents

Timely reporting of incidents enables management to take prompt preventative or corrective measures to mitigate consequences. Many major process safety incidents were preceded by precursor occurrences (typically referred to as near-misses) that might have gone unrecognized or ignored because “nothing bad” actually happened. The lessons learned from any incident can be extremely valuable. However, this benefit is only realized when incidents are recognized, reported, and investigated. This chapter describes important considerations for internal reporting of incidents, the process of classifying incidents into categories, and means for determining appropriate levels of investigation to be conducted.

Chapter 6—Building and Leading an Incident Investigation Team

Personnel with proper training, skills, and experience are critical to the successful outcome of an incident investigation. This chapter describes team composition as a function of incident type, complexity, and severity, and includes suggested training topics. It also provides team leaders with a high-level overview of the basic team activities typically required in the course of conducting an investigation.

Chapter 7—Witness Management

This chapter discusses techniques for identifying witnesses and effective interviewing techniques designed to obtain reliable information from them. Witnesses often hold the most intimate knowledge of conditions at the time of the incident, actions taken pre-incident and post-incident, process design and operations, etc. Effective management of witnesses is a crucial element of the investigation process. Issues related to witness interactions and interviewing techniques are covered in detail.

Chapter 8—Evidence Identification, Collection, and Management

Facts are the fuel that an investigation needs to reach a successful conclusion. This chapter addresses the methods and practical considerations of data-gathering and archiving activities. It describes plan development; priority establishment; different types and sources of data; data-gathering tools, techniques, and preservation; documentation requirements; photography and video techniques; suggested supplies; etc.

Chapter 9—Evidence Analysis and Causal Factor Determination

This chapter provides practical guidelines for analyzing evidence, proving/disproving hypotheses, and developing causal factors. The use of a scientific methodology to sort out facts from collected data is explained, and techniques are offered for use during this iterative and overlapping process. Identifying causal factors is an intermediate step towards determining root causes, and implementing recommendations based on root causes should inherently address the causal factors as well.

Chapter 10—Determining Root Causes—Structured Approaches

This chapter addresses methods and tools used successfully to identify multiple root causes. Process safety incidents are almost always the result of more than one root cause. This chapter provides a structured approach for determining root causes. It details some powerful, widely used and proven tools and techniques available to incident investigation teams, including timelines, fault trees, logic trees, predefined trees, checklists, and application of human factors. Examples are included to demonstrate how they apply to the types of incidents readers are likely to encounter.

Chapter 11—The Impact of Human Factors

This chapter describes human factor considerations in incident investigation. It provides insight and tools to identify and address applicable human factor issues throughout an investigation. Practical models are presented along with examples.

Chapter 12—Developing Effective Recommendations

Once the likely causes of an incident have been identified, investigation teams evaluate what can be done to help prevent recurrence or mitigate consequences. The incident investigation recommendations are the product of this evaluation. This chapter addresses types of recommendations, attributes of high quality recommendations, methods to document and present recommendations, and related management responsibilities.

Chapter 13—Preparing the Final Report

In the case of incident investigation, a major milestone is completed when the final incident investigation report is submitted. The incident report documents the investigation team’s findings, conclusions, and recommendations. This chapter describes practical considerations for writing formal incident reports, and discusses the attributes of quality reports and differences among incident notifications, interim reports, and a final report. Considerations and associated practical techniques are provided for stating report scope, preparing preliminary notices, documenting the investigation process and results, developing a report format, and performing a quality assurance check that includes management review and approval.

Chapter 14—Implementing Recommendations

The recommendations generated from an incident investigation when implemented in a timely and effective fashion, decrease the probability of recurrence, and/or reduce the potential consequences of an event. This chapter begins with case examples that underscore key concepts, and then focuses on the critical aspects of effectively implementing recommendations. It addresses initial resolution of the recommendations, their full implementation, effectiveness of follow-up, and tracking.

Chapter 15—Continuous Improvement for the Incident Investigation System

The adage “if it ain’t broke, don’t fix it” does not apply to process safety management systems. A continuous improvement pillar is an integral part of the process safety management system. This chapter describes techniques that can help the incident investigation element of process safety remain strong and viable in an ever-changing technical, business, and regulatory environment. It includes considerations for assessing existing incident investigation programs as well as approaches for implementing continuous improvement.

Chapter 16—Institutional Knowledge

Sharing lessons learned, not only across the organization but also across industry and related agencies, is an extremely effective way to learn from the occurrences of others. This chapter focuses on how to obtain and critically analyze incident information and share core learnings, and provides examples.

Appendices

The appendices provide a wealth of supplemental information on the subject of incident investigation. Topics include:

A. Photography Guidelines for Maximum Results

B. Example Protocol – Checking Position of a Chain Valve

C. Process Safety Events Leveling Criteria

D. Example Case Study

E. Quick Checklist for Investigators

F. Evidence Preservation Checklist– Prior to Arrival of the Investigation Team

G. Guidance on Classifying Potential Severity of a Loss of Primary Containment

Glossary

The glossary provides definitions of terms used throughout the book. To the greatest extent possible, definitions are consistent with the CCPS Process Safety Glossary.

(https://www.aiche.org/ccps/resources/glossary).

References

An extensive list of references is assembled to allow the reader to obtain the source reference papers and reports for investigation methodologies.

1.6 THE CONTINUING EVOLUTION OF INCIDENT INVESTIGATION

Like all the elements of process safety management, the incident investigation element continues to evolve. The AIChE Center for Chemical Process Safety assists this evolution by providing information to help companies safely operate process facilities. To this purpose, CCPS and the contributing authors offer this third edition of this guidebook on investigating process safety incidents.

2OVERVIEW OF CHEMICAL PROCESS INCIDENT CAUSATION

For an investigation of a chemical process incident to be effective, the investigation team should apply a systematic approach that identifies the root causes of the incident, as defined in Chapter 1. As a rule, the benefits of this systematic approach result from:

Applying a consistent and effective investigative effort, and

Implementing sound process safety management principles.

The investigation team should apply an approach based on basic incident causation concepts. When a system or process fails, it may be difficult to trace the reasons for its failure. Based on available historic incident data, the makeup of a major incident is rarely simple and rarely results from a single root cause. Serious process safety incidents typically involve a complex sequence of occurrences and conditions that can include, but are not limited to:

equipment faults or faulty design,

latent unsafe conditions,

environmental circumstances, and

human errors.

Understanding the concepts of incident causation is essential to comprehensively investigate incidents and prevent their recurrence or mitigate their consequences through implementation of effective recommendations.

Numerous theories and models of incident causation have been developed over the years (Heinrich, 1936; Gibson, 1961; Recht, 1965; Haddon, 1980; Peterson, 1984, etc.). These theories and models may appear at first to be diverse and disparate, but they do contain a number of common themes and concepts. As a result of this research, industry best practices in incident investigation have evolved significantly over the last few decades, based upon a number of key incident causation theories.

This chapter discusses models that illustrate how a process safety incident can develop in a staged manner, often as a result of weaknesses in the management system. It also provides a brief overview of key causation concepts such as loss of primary containment, linkage between root causes and the management system, involvement of human factors, and multiple root causes.

2.1 STAGES OF A PROCESS-RELATED INCIDENT

Experience from systematic analyses of past process safety incidents has allowed researchers to develop incident models that display the makeup of a process-related incident using a conceptual framework.

2.1.1 Three Phase Model of Process-Related Incidents

The progression of any process-related incident could be described as occurring in three different phases or stages (DoE, 1985):

Change from normal operating state into a state of abnormal (or disturbed) operation, i.e. a deviation from intended safe operation.

Loss of control of the abnormal operating phase, which may involve a breakdown of a barrier function. A barrier function is a safety feature such as a shutdown valve or containment system, a procedure, or the communication system. When safety systems fail, the incident can evolve from an undesirable occurrence to a near-miss and, if enough barriers fail, the incident could progress to an operational interruption or accident, depending upon the consequences or circumstances.

The severity of subsequent consequences is influenced by [the impact of] loss of control of energy accumulations. Process safety incidents can involve different hazardous energies, such as chemical, mechanical, electrical, thermal and pressure.

This model introduces the general concept that there is typically a sequence of events leading to a process safety incident. Understanding the sequence of events, and the barriers that have failed can help investigators to understand the progression of an incident.

2.1.2 Event Tree

An event tree model is an example of a more structured conceptual framework encompassing the three phases of a process-related incident. Figure 2.1 illustrates an example of an event tree of incident causation.

Figure 2.1Event Tree for a Process-related Incident

In the Figure 2.1 example, there is:

Deviation from normal operation into abnormal operation. An example is the tank level deviation, which could be caused by various events or conditions, such as: operator error, faulty instrumentation, etc.

Breakdown of control of the abnormal operation. An example is the distributed control system (DCS) not compensating properly. Another example is the operator not detecting the deviation.

Loss of control of energy. An example is the operator not responding, which allows the tank to overflow.

This example has three contributors to incident causation in each of the three phases: equipment, process systems, and human. Under different circumstances, the organization, the environment and/or external factors may also contribute. There are two detection systems and two intervention opportunities. Depending on the success or failure of each, there are three potential paths that result in no adverse consequences and four potential paths that lead to failure, with overflow as the immediate consequence. Note that sometimes there are more opportunities for things to go wrong than to go right and the event tree clearly depicts the specific paths that can lead to an undesired event.

This example illustrates that event trees can be useful models of an incident sequence because they provide a graphical, logic-based depiction of the various potential consequences that could occur, depending on the pathway of an event. This is a more structured sequence model than the three-phase model, but it does not fully address the weaknesses in barriers and the management systems behind them.

2.1.3 Swiss Cheese Model

Another way to represent the staged events and conditions that result in an incident is by using the Swiss Cheese model (Reason, 1990). This model takes one of the failure paths defined in the event tree that leads to a consequence of concern. The protective barriers (safety systems) are represented by parallel slices of Swiss cheese. These barriers represent the equipment, procedures/practices, and people that comprise elements of the management system for the facility.

Ideally each barrier should be robust, but like the holes in Swiss cheese, all barriers have weaknesses (Figure 2.2) resulting from:

Active failures (e.g., equipment failures, unsafe acts, human errors, procedural violations, etc.).

Latent failures (e.g., design/equipment deficiencies, inadequate/ impractical procedures, time pressure, unsafe conditions, fatigue, etc.) – see

Section 2.1.4

below.

Figure 2.2Swiss Cheese Model

These weaknesses can lead to management system failures resulting in a process safety incident (see Section 2.2.2 below).

In reality, the holes or weaknesses are not static; they are dynamic and continually open and close. For example, one personnel shift may be more experienced and diligent than another, so that some barriers begin to degrade further at shift change. Each barrier may not work when needed, and is fully dependent on management system implementation to ensure a reasonable probability of working on demand.

If a weakness occurs in one barrier, there may be one or more other barriers that can provide sufficient protection and, while the weakness may have an undesirable outcome, it is unlikely that a significant incident will occur. However, most process safety incidents involve a combination of multiple active and latent failures. Therefore, investigators should understand that no layer of protection is perfect, and look for weaknesses in all barriers.

2.1.4 Importance of Latent Failures

The Swiss Cheese model introduced the concept of latent failures (also known as latent conditions). Historic incident data show that latent failures have played an important role in incident causation (Reason, 1990). The term latent failure implies the condition is dormant or hidden. Normally the latent failure can be revealed before an incident occurs, through testing or auditing during typical operations within the process, as shown in Figure 2.3.

Figure 2.3Latent (hidden) Failure

There is always a possibility, however, that a latent failure may remain hidden during testing. There are several reasons a latent failure may not be detected, including, but not limited to:

It was not activated by the test used.

The test was deficient, gave wrong results, or did not test the system properly.

The test activity itself activates failure upon the next use of the process.

It is important that investigators understand the concept that latent failures can contribute to an incident, in addition to more obvious active factors, such as unsafe acts and spontaneous equipment failure. Latent failures may involve organizational influences, inadequate supervision, human error and equipment/system preconditions that were hidden from, or unknown to, personnel responsible for the process.

2.2 KEY CAUSATION CONCEPTS

Some of the common concepts from incident causation theories that are relevant to the investigation of process safety incidents are:

There is potential or actual loss of containment or energy,

There is a direct linkage between root causes and the management system,

Most incidents involve human factors,

Each incident will likely have multiple root causes,

Events are not root causes, and

Risk is not reduced until effective remedies are implemented.

Each of these causation concepts and a number of avoidable pitfalls that incident investigators should be aware of are discussed below.

2.2.1 Loss of Containment or Energy