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Reassuring Numbers, Hidden Risk

A case study of the BP Texas City refinery explosion based on the CSB report: why low injury rates misled, and what that means for safety data in sustainability reports.

By M. Reza Huzain, SKM, MKKK 4 min read

The Texas City refinery skyline in the United States, seen from Galveston Bay
Photo: Jumpingmpjopa, Wikimedia Commons, CC BY-SA 4.0
Contents
  1. What Happened
  2. Organisational Findings
  3. Reading the Indicators
  4. Lessons for Reporting
  5. How Nusa Safety Helps

On 30 April 2026, Indonesia's Financial Services Authority (Otoritas Jasa Keuangan, OJK) said that, based on its internal review, only about 40 percent of companies disclose emissions quantitatively, relatively and systematically in their sustainability reports. The obstacles it cited include limited company capacity, inconsistent calculation methods and emissions data not yet integrated into business strategy (Ritonga, 2026). The duty to prepare a sustainability report comes from OJK Regulation No. 51/POJK.03/2017 on sustainable finance for financial institutions, issuers and public companies (Otoritas Jasa Keuangan [OJK], 2017).

Questions about data quality do not stop at emissions. A study of Indonesian listed companies that used the Global Reporting Initiative guidelines as its benchmark found that only about 29 percent voluntarily disclosed occupational health and safety information (Cahaya, 2012). This case study reads one official investigation report that shows how good-looking safety numbers can mislead, and draws lessons for the social pillar of ESG reporting.

What Happened

According to the U.S. Chemical Safety and Hazard Investigation Board (CSB), at 1:20 p.m. on 23 March 2005, BP's refinery in Texas City, United States, suffered explosions and fires that killed 15 people and injured 180, with financial losses exceeding 1.5 billion US dollars. The event occurred during the startup of an isomerization unit, when a raffinate splitter tower was overfilled, pressure relief devices opened and flammable liquid erupted from a blowdown stack that had no flare. All the fatalities occurred in or near office trailers placed close to the blowdown drum, and about 43,000 people were told to shelter indoors (U.S. Chemical Safety and Hazard Investigation Board [CSB], 2007).

Organisational Findings

The CSB stressed that blaming operators and supervisors alone would miss the larger cultural, human factors and organisational causes. One underlying cause was how BP measured safety. A very low personal injury rate at Texas City gave a misleading indicator of process safety performance, while the safety culture and the process safety management programme had serious deficiencies (CSB, 2007).

Other organisational findings included cost-cutting and production pressure, a board with no member responsible for assessing major accident prevention programmes, a check-the-box mentality, a weak reporting culture, and safety campaigns, goals and rewards focused on personal injury metrics and worker behaviour rather than on process safety and management systems (CSB, 2007).

Reading the Indicators

We read this case through the distinctions the CSB itself uses: between personal safety and process safety, and between indicators that measure outcomes (lagging) and indicators that measure the condition of controls (leading). Recordable injury rates mostly count frequent, small-scale events such as slips, trips and falls. Major accidents in process industries are rare, so a low annual rate says little about whether barriers are ready for a scenario like Texas City (CSB, 2007).

This lesson carries straight into sustainability reporting. GRI 403: Occupational Health and Safety 2018 asks not only for work-related injury rates but also for the work-related hazards that pose a risk of high-consequence injury, how they were determined, and the actions taken to eliminate them using the hierarchy of controls (Global Reporting Initiative [GRI], 2018). In our view, this narrative part is often the thinnest, yet it is the part that can show whether major risks are under control. For boards and investors, low injury figures without a description of major hazards can create the same comfort BP felt before 2005.

The lesson has limits. Texas City happened at a United States refinery two decades ago, and the CSB findings apply to that organisation. The Indonesian safety disclosure data we found are also old, and OJK's emissions figure comes from an internal review whose method was not explained in the news coverage (Cahaya, 2012; Ritonga, 2026).

Lessons for Reporting

  • Separate personal safety and process safety indicators in internal and sustainability reports, because they measure different things (CSB, 2007).
  • For each high-consequence hazard, describe how it was identified and which controls are in place under the hierarchy of controls (GRI, 2018).
  • Add leading indicators, such as the status of critical equipment inspections, closure of hazard study recommendations and follow-up of near-miss reports.
  • Do not tie bonuses or incentives only to injury rates, since the CSB found that such focus drew attention away from process safety (CSB, 2007).
  • Make sure the board or its relevant committee regularly receives reports on major accident prevention performance.
  • Use the same data for the sustainability report and for operational decisions, so disclosed figures can be checked again (Ritonga, 2026).

How Nusa Safety Helps

Nusa Safety helps companies test whether major hazard controls work as reported through its process safety management review and SMK3 internal audit services. To build leading and lagging indicators that can be traced back to field data, the Nusa Safety team offers HSE digitalization. To discuss specific reporting needs, please contact the Nusa Safety team.

This article is general information and not legal or professional advice for any specific case.

References

  1. Cahaya, F. R. (2012). Health and safety disclosures in Indonesia: A CSR convergence strategy. JESI (Jurnal Ekonomi Syariah Indonesia), 2(2), 143-154. https://doi.org/10.21927/jesi.2012.2(2).143-154
  2. Global Reporting Initiative. (2018). GRI 403: Occupational health and safety 2018. https://globalreporting.org/publications/documents/english/gri-403-occupational-health-and-safety-2018/
  3. Otoritas Jasa Keuangan. (2017). Peraturan Otoritas Jasa Keuangan Nomor 51/POJK.03/2017 tentang Penerapan Keuangan Berkelanjutan bagi Lembaga Jasa Keuangan, Emiten, dan Perusahaan Publik [Financial Services Authority Regulation No. 51/POJK.03/2017 on sustainable finance for financial institutions, issuers and public companies]. https://www.ojk.go.id/id/regulasi/Pages/Penerapan-Keuangan-Berkelanjutan-bagi-Lembaga-Jasa-Keuangan,-Emiten,-dan-Perusahaan-Publik.aspx
  4. Ritonga, S. Z. P. (2026, April 30). OJK ungkap baru 40% perusahaan laporkan emisi secara kuantitatif [OJK reveals only 40% of companies report emissions quantitatively]. Investortrust.id. https://investortrust.id/esg/101885/ojk-ungkap-baru-40-perusahaan-laporkan-emisi-secara-kuantitatif
  5. U.S. Chemical Safety and Hazard Investigation Board. (2007). Investigation report: Refinery explosion and fire, BP Texas City, Texas, March 23, 2005 (Report No. 2005-04-I-TX). https://www.csb.gov/assets/1/20/csbfinalreportbp.pdf

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