At the request of the U.S. Chemical Safety and Hazard Investigation Board (CSB), we examined some of the possible uses of the process safety event metrics proposed by the American Petroleum Institute and published as ANSI/API Recommended Practice 754. We examined many sources to try to estimate what the likely number of Tier 1 and Tier 2 process safety events would be at refineries. Then we calculated the statistical power that would be available to compare rates, both over time and across facilities and firms. As Tier 1 and Tier 2 are defined, it appears that the event frequencies estimated for U.S. refineries (i.e., 0.12 per 100 employees for Tier 1 and 0.26 for Tier 2) would make it unlikely that even two-fold differences in the rates would be statistically significant, except at large refineries with several thousand workers. (C) 2013 Published by Elsevier Ltd.