Near miss incidents include those releases and/or fires that do not result in significant employee injury or costs. In many cases there are federal reporting requirements requiring reports to the National Reporting Center (NRC). These initial reporting and the follow up written report could be characterized as a waste of time to industry although the Environmental Protection Agency enforcement section has a history of taking interest in finding and fining sites for ‘late’ reports.
The fact is loss of containment releases are often near misses for catastrophic incidents and provide evidence of process safety program weaknesses. Facilities have an interest in finding root causes, lessons learned and making safety improvements. The State of Delaware Accidental Release Prevention program has found a wide range in the quality of incident investigations. Small sites often do not have the expertise to conduct good investigations while some large sites blame operator error rather than admit management system errors or process design issues.
This paper explains how Delaware has amended the federal requirement to report releases to include flammable gas releases and added to existing written follow up report requirements to explain the ‘facts and circumstances leading to the release and the measures proposed to prevent the future releases and remedy any deficiencies in the prevention program’. This has proved to be a valuable tool for our regulatory program as we work with industry to make continuous improvements to their process safety programs. Having this ‘public’ examination of near miss investigations puts pressure on both industry and our regulatory program to find root causes and make real improvements at site process safety programs – without adding any substantial regulatory burden to industry. This paper will also discuss the pros and cons of how this innovative regulatory initiative has worked out over the last decade including both how it influenced our regulatory program and how it influenced our industry stakeholders.
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