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PUBLICATIONS AVAILABLE FROM THE
CENTER FOR CHEMICAL PROCESS SAFETY
of the
AMERICAN 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 INVESTIGATING
PROCESS SAFETY INCIDENTS
THIRD EDITION



CENTER FOR CHEMICAL PROCESS SAFETY
OF THE
AMERICAN INSTITUTE OF CHEMICAL ENGINEERS
New York, NY







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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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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.

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
N2 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
Pfatality Probability of Fatality
Pignition Probability of Ignition
Pperson 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)
T0 starting time
Tn 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