Process safety management in india

10/9/2018
PANNALAL SONI (DGM - HSE), RAJASHREE POLYFIL (A DIV OF
CENTURY ENKA LTD., UNIT OF B.K. BIRLA GROUP), e-mail ID :
pannalal.soni@birlacentury.com, Mob. No. 7285092192
1

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Initiation
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Accident includes Event and Effect but event is very important. Effect
may be or may not be but event, if not assessed before happening, will
be resulted in consequences as Major Disaster, Minor Disaster,
Occupational Illness, Injury, Disability, Death, Property Damage,
Environment Damage, Resources Consumption, Time & Production
Delay & Loss / Loss of Skilled Man Power and other Direct & Indirect
Losses to the Company, Victim & His Family, Society and Nation.

To be discussed
•Current trends in Process Safety management in India
•Emergency Reponses Planning and Off site
Emergencies : Limitations and Problem faced
• Learning from Incidents : What are the minor details
that we tend to overlook
•Process Safety Training : How much do we really Focus
on it in our Company
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Objective of the whole discussion is -
Managing
Releases of
Toxic
Substances
Explosives
Substances
Flammable
Substances
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To Prevent
Exposure, Injuries &
Loss of Lives
Property damage and
conserve Resources
Environmental damage and
its effect on future
generation

Current trends in Process
Safety management in India
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Matter is of Discussion :
for both Law enforcing agencies and Industrialists
 Are we really able to Prevent Another disaster in India like Bhopal?
 Are after Bhopal Law capable enough to prevent such incidents?
 Are Law enforcers capable of ensuring Compliance?
 Are Occupiers aware about their Duties and Responsibilities (Sec-7A and
Sec 41A to 41H of Factories act and Rule 4, 10 & 13 of MSIHC Rules 1989)
 Are Occupiers witnessing their duties by heart?
 Are such incidents investigated thoroughly and Report in circulated to the
industries for learning purpose?
 Are ensured that Competent Persons are appointed in Process Operation
 Are ensured that Compulsory Information are disclosed to the concerned
persons (Sec 41B of Factories Act and Rule 15 of MSIHC Rules)
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Matter is of Discussion :
for both Law enforcing agencies and Industrialists
Is it ensured that Emergency Response Plan is adequate?
Are ensured that employees are well aware about simple Do
and Do not while they are at work?
• If Yes, What are the reason of such Incidents?????
• If not, Why? And -
• Who is responsible?????
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Current trends in Process Safety management in India
PSM Elements
Legal Perspective
Operational
Control (Industrial
Perspective)
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Legal
Perspective of
PSM
Pre-Bhopal Post Bhopal
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Pre-Bhopal
1. Explosive Act 1884
2. Petroleum Act 1934
3. Founded DGFASLI - 1945
4. Factories Act 1948
5. Insecticide Act 1968
6. SMPV Rule 1981
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None of these
Law say even a
single word
about Major
Accident
Prevention and
Control

Post-Bhopal
1. Env. Protection Act 1986
2. Amended in Factories Act (1987)
2. CMV Act 1988
3. PLI Act 1991
4. Amended CMVA – 1993
5. Rule made under EPA :
- MSIHC Rule – 1989
- CA (EPP&R) Rule – 1996
6. Amendments in State Factories Rule
7. Formation of other Organization :
- Formation of OISD – 1986
- Formation of PESO - 1998
8. MAH Control Guide, DGFASLI – 1998
9. Disaster Management Act – 2005 and
Formation of DMA – 2005
10. EIA Notification 2006
11. National Chemical Disaster
Management Guidelines for Chemical
disasters – 2007
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Areas of Discussion
Our Legal framework for Disaster Management System is Excellent. It
covers all areas and all aspects. Authorities are also ensuring the
implementations of the Plan. As per our plans, we are also fully
prepared for mitigating any emergency in the Country.
Even after such preparedness and enforcements of actions,
we are fail to manage (Prevent and Protect) many Natural as
well as Manmade disasters. Why?????
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If we consider it only for Process Industries, some of
the Practical Scenario of Legal Compliance in India is :
• Majority of the Companies want to Satisfy only to the Licensing
Authorities (Why????? ---- .. ---- Matter is of Discussion)
• Occupiers are Not aware about economic benefits of PSM
(Why not aware, who will make them aware? - Point of Discussion)
• Incompetent HSE professionals appointed for compliance
• Experts are Costly (Mostly business Oriented)
• Dependency on mediator (Consultants – Advocacy) and their
monopoly
• Compliance on Paper to justify Authorities rather than
implementation
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Conti………………………………………………………………..
• Lack of Monitoring of the system adequacy by Govt. Agencies/
Enforcing Authorities
• Lack of Specialized skill on Process Safety for the law enforcers
• Third Party Audit by External Agencies other than Govt. Authority
• Not sharing Incidents Root Cause to the Companies – as case study for
awareness even after portal is available - Chemical Accident
Information and Reporting System (CAIRS), under MoEF
• Not involvement of Govt. Authorities in Onsite ERP preparation and
during Checking of its adequacy (Mock Drill)
• Formal Offsite Disaster Mock-drill. Not mandate to attend all
concerned Industries under Local Crisis Group & DDMA
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1. Appointment of Strong technical Team to Assess Process industries
for Process Safety arrangement and its adequacy. (In Bhopal,
Chilling System & Scrubber was not in operation. It was assumed
that Gauges are indicating wrong reading etc.)
After Bhopal LAW : There is a provision of Periodical examination of
the system by Competent Person certified/accredited by
PESO/CCE/DISH etc. but if we talk about actual practices, few of them
are dedicated to checks whether the system is practically adequate or
not. Occupier never ask whether the system is being checked for its
adequacy or only certificates are being issued with extended dates for
next examination. Authorities also trust on Report.
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For Compliance of Section 41-B & 41-C of Factories Act, the occupiers
of industrial activities or isolated storage shall arrange to carry out
safety audit by a competent person to be accredited by an
Accreditation Board to be constituted by the Ministry of Labour,
Government of India in this behalf.
IS 14489 is used as readymade checklist to Audit the Industrial
Activities. There are some other elements related to Process
Management which are out of IS 14489.
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Compliance of the Auditors Recommendations is Sent to
the Authorities but no one visit the plant to see whether
compliance is there at shop-floor or it is only on Paper

Conti…………………………………………………………..
2. Compulsory disclosure of information to the Public in vicinity of
Company is Specific Responsibility of Occupier under Section – 41-B &
41-C of Factory Act. This must contain the detail of the Emergency may
be arising due to Companies operation including Do and Do not during
Emergency. In Practical, even a single Industry, not giving any such
information to the public in vicinity. Legal Authorities ask a copy of the
same and enforce to make it available to workman only. Who will ensure
– whether public which may be affected is informed about emergency
communication including Do & Do not?????
Rule 15 of MSIHC Rule also Demand the Same Obligation : Information to be
given to the person to be affected by a Major Accident.
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3. Direct dealing with Occupiers by law enforcers
Occupiers/Owners/Factory Managers of the maximum Companies
having Hazardous Process are not aware about obligation applicable
to their Company under Applicable Laws. This resulted in – hiring a
Consultant – as an Expert.
Consultants – Comply law on paper and help in grant of License. As
for as implementation of law at ground is Concern, it is untouched.
No doubt, expert consultants are also available but they are either
very costly or they are limited up to Submission of Assessment
Report. Then, Compliance ………………………………..?????
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4. System to share even a minor incidents
investigation for learning lesson.
Except some major cases, Incidents investigation Report are
not made available to the industries. As we know, Case study
is more effective to understand gap in our process rather than
its Audit. Govt. should make a enforced strong system to share
Process incidents, even if minor, with Root cause. We always
talks about Near-miss Reporting, here Incidents are not
reported.
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5. System to ensure readiness for chemical disasters Management
On-site emergency Management falls under the responsibilities of
Occupier. Authorities ask only to submit a Copy of Emergency
Response Plan. How Authorities ensures that all potential risks are
covered in the plan?, Authorities Ask to submit Mock drill report
once in six month but how they ensure that Mock-drill are
conducted on Every Emergency Scenarios and Report is Authentic?
In MAH Industries, Authorities must involve in Preparing Onsite
ERP and its Mock-drill. They must ensure that Onsite
arrangements including awareness is strong and company is
capable of handling emergency.
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Off-Site emergency Management falls under the
responsibilities of Govt. Authorities. Companies are liable only
to provide information to the Authorities for Offsite Response
Plan. No doubt, Offsite Emergency Response Plan Contains
Complete information about Major Accident Hazard including
Facilities available in those Companies for mitigation of
Emergencies. But copy of OFF SITE ERP is not made available
to the Companies. Every Company is not get involved in
Offsite Drill. Report of the drill is also not made available to
the Companies, While such communication can make our
Emergency Management system more strong.
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6. Under Section 40-B of Factories Act, it is compulsory
to appoint safety officer. Criteria for Nos of Safety
officers to be appointed is also laid-down in law but
how Got. Authorities ensure that Safety Officers
appointed are Competent and skilled enough to
meet Process Safety needs of the organization.
There should be some control on it by Govt.
Authorities so that it can be ensured that there
would not be any incidents in the company if
Section 40-B is complied.
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PSM
Legal
Perspective
Operational
Perspective
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Operational
Perspective of
PSM
Implementation
of 14 elements
of PSM
Leadership,
Commitment &
Culture change
Accepting
Challenges
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OSHA CFR 1910.119 (Occupational Safety and Health
Administration) of US prescribes 14 PSM elements:
1. Employee Participation
2. Process safety information
3. Process hazard analysis
4. Operating procedures
5. Incident investigation
6. Management of change
7. Pre start up safety review
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8. Contractor control
9. Hot work
10. Mechanical integrity
11. Training
12. Emergency Preparedness
13. Trade secrets
14. Compliance audits

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In India, we do not have any such Action based Approach for
PSM. Consolidated short enforcing guide in checklist form can
be introduced by Govt. which can be easily understood by
Occupiers and other person engaged in Compliance.
Our Law are very lengthy and of repetitive nature hence
majority of the person do not take interest in its reading.
Legal language is also quite different and citations are very
lengthy.

Current PMS trend in India – Operational Perspective
• Except major Petrochemicals, Oil and Chemical Industries, 14
elements of PSM, as enforced by US, Department of Labour, CFR
1910-119 dated 18th June 1998, not fully observed by Indian
Industries.
• Though, Chemical plants generally know how to complete a process
hazard analysis (PHA), Mechanical Integrity, management of change
(MOC), Managing Hot work & incident investigation, etc. They also
know that the Failures can result in an incidents, which may lead to
injuries, Fatalities, financial losses and public disgrace.
• They have to inculcate such a work culture to know What is
inadequate in their work practices and what to do to make it
adequate.
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Current PMS trend in India – Operational Perspective
• Following are the Actual Trend of PSM in India:
1. Leadership of Safety integrated Process Operation is quite poor
2. Poor credibility of the Chemical Industry with the Public
3. Very limited risk based approach to process safety
4. Industries/Employees do not want to share incidents
5. Technical competency for safe operation of a process is quite
poor
6. Skill development Plans for Safe Operation of the Process is also
poor
7. Industrialists are reactive rather than proactive
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Leadership, Commitment & Culture
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• Fashioning policies and hanging posters is not enough. Rising a healthy
safety culture requires leadership of top management to victor safety as a
key organizational value.It is true : When management leads in safety, the
organization will follow.
• Management must involve in workplace safety.
• They must address to the workers and
• They must take accountability for creating a safe work environment
• Emphasis should be given on Near miss Reporting, Investigation and
actions to mitigate root cause
• Participation and involvement of all cadre of employees in Risk
Assessment, Incident Investigating, Safety Suggestion, Safety Contests etc.

Major area to be considered as challenges by Industrialists and
Safety Professional handling PSM
• Reducing Risk applying hierarchy of control starting from Safe design of
plant, Process and equipment
• Always Preferring Safer technology
• Analysing, Monitoring and Maintaining effectiveness of the Safeguards
• Considering Process Hazard Analysis and HAZOP Study as a tool for Process
• Strong maintenance of Equipment and Safety Systems to ensure its
reliability
• Strong and Effective Emergency Response Plan
• Adequate Education, Training and Awareness including display of Placard,
Cautionary notices etc.
• No cost cutting in Contractor’s Safety and Management of Change.
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Any Question?????
Please
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Emergency Reponses Planning
and Off site Emergencies :
Limitations and Problem faced
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Classification based on Severity of Harm
Emergency
Related to
Process Industries
Onsite
Emergency
Offsite
Emergency
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Legal Requirements
Emergency Related to
Process Industries
Onsite Emergency :
Sec 41A, 41B (4) of Factories
Act 1948 (1987) and Rule 13
of MSIHC Rule 1989
Offsite Emergency :
Rule 14 of MSIHC Rule 1989
And CA(EPPR) Rule 1996
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On-site Emergency Plan:
If an accident takes place in a factory, its effects are confined to the factory
premises, involving only the persons working in the factory and the property inside
the factory it is called as On-site Emergency.
Or
any situation, which presents a threat to safety of person or/and property within
the organization. It may require outside help also. Hence :
The on-site emergency plan deals with measures to prevent and control
emergencies within the factory premises and not affecting outside public or
environment. Mostly the emergency is controlled by the infrastructure of the plant
i.e. people, equipment, vehicles etc. belonging to the plant itself.
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• After Bhopal MIC disaster, the Factories Act has been amended in
1987 and Chapter IV-A introduced. This chapter deals with
HAZARDOUS PROCESSES. There are total Seven Section viz. visions sec
41A, 41B, 41C, 41D, 41E, 41G & 41H covering all hazardous process
industries. MSIHC Rule came in Existance
• Under Sec 41B(4) of FA and Rule 13 of MSIHCR it is Duty of Occupier
of the facility operating Hazardous Process to Prepare On-site
Emergency which shall be approved by Chief inspector of Factories
and make known to the employees and to the public in the vicinity of
the factory along with safety measures required to be taken in the
event of any major accident.
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Under Sec 41B(4) of FA and R-13 of MSIHCR
1. Involvement of Authorities in its
Preparation
2. approved by Chief inspector of Factories,
3. make known to the employees
4. Make known to the public in the vicinity
of the factory
5. Make known safety measures required to
be taken in the event of any major
accident.
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Problems & Limitations :
Authorities ask only to submit a Copy of
Emergency Response Plan. How Authorities
ensures that all potential risks are covered in
the plan?, Authorities Ask to submit Mock
drill report once in six month but how they
ensure that Mock-drill are conducted on
Every Emergency Scenarios and Report is
Authentic? May be the shortage of
executing officers under Authorities

Off-site Emergency
It is related to the Major Accident.
Rule 2(f) of CA(EPPR) Rule 1996 and Rule 2(J) of MSIHC Rule 1989 :
"major chemical accident" means, - an occurrence including any
particular major emission, fire or explosion involving one or more
hazardous chemicals and resulting from uncontrolled developments in
the course of industrial activity or transportation or due to natural
events leading to serious effects both immediate or delayed, inside or
outside the installation likely to cause substantial loss of life and
property including adverse effects on the environment;
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• A major emergency is one that may affect several departments
within organization and/or may cause serious injuries, loss of life,
extensive damage to property or serious disruption outside the
works. It will require the use of outside resources to handle it
effectively.
• Disaster is a catastrophic situation in which the day-to-day patterns
of life are, in many instances, suddenly disrupted and people are
plunged into helplessness and suffering and as a result need
protection, clothing, shelter, medical and social care and other
necessities of life.
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Rule-14 of MSIHC Rule 1989 : OFF-SITE EMERGENCY PLAN
(1) It shall be the duty of the concerned authority as identified in Column 2
of Schedule 5 to prepare and keep up-to-date an adequate off-site
emergency plan containing particulars specified in Schedule 12 and
detailing how emergencies relating to a possible major accident on that
site will be dealt with and in preparing that plan the concerned authority
shall consult the occupier, and such other persons as it may deem
necessary.
(2) For the purpose of enabling the concerned authority to prepare the
emergency plan, the occupier shall provide the concerned authority with
such information relating to the industrial activity under his control as
the concerned authority may require, including the nature, extent and
likely effects off-site of possible major accidents
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1. There are so many Industries Handling Hazardous Chemical in any
District but only One Offsite Drill on any one Scenario is Conducted by
the Authorities every year. How it is ensured/assumed that the Action &
Resources for Handling Emergencies within District or Within Industrial
Pocket is adequate.
2. Drill is Conducted only during Day time not during any odd hours as night
3. In case, any two or more emergencies are there in any Area, then
what?????, No moc-kdrill on such conditions.
4. Copy of OFF SITE ERP is not made available to the Companies.
5. Every Company is not get involved in Offsite Drill.
6. Report of the drill is also not made available to the Companies, While
such communication can make our Emergency Management system
more strong.
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What we learned from Bhopal ?????
If a Strong, Efficient, Effective, Capable and Readily available Onsite and
Offsite Emergency Response plan was there and if the requirement as
mentioned under Section 41-B(4) of FA & Rule 13 & 14 of MSIHC Rule
was fulfilled we could have save the lives of innocent People of Bhopal
This was the Reason for the Amendments in Safety Law after Bhopal.
Law are being continually improved.
But – Execution of the compliance of obligations by the Authorities
need to be improved in terms of proactive rather than reactive.
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What to do?????
• Bothe Industrialist and Authorities have to take Concrete proactive
and Preventive action for Accident Prevention.
• Both Industrialist and Authorities have to Ensure that Onsite & Offsite
Emergency Response Plan is Appropriate, Adequate and Readily
Available to use
• HSE Professional/Safety officers to take full Responsibilities to Ensure
that there is no gap in Paper and Ground
• They have to inform to both Occupier and Concerned Authorities
about gaps, if any, and the Action to bridge it.
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Any Question?????
Please

Learning from Incidents :
What are the minor details that we
tend to overlook
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FINDING ROOT CAUSES
When we determines the contributing factors, we must dig
bottomless! E.g. :
• If operative error, what caused that behavior?
• If machine failure, why wasn’t it identified & fixed?
• If poor illumination, why wasn’t it identified and corrected?
• If Unskilled employment/Lack of training, why so?
• If SOPs deficiency, why not reviewed and made user-friendly?
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The trend often seen in the Industries is :
• Starting from PPE :
e.g. : Splashed Caustic lye in to eye,
After discussion with Plant head, See Reply : –
Even after issuance of good quality of Safety google employees are not
using it during work.
No thought :
1. What was the reason of coming out liquid - is there any leakage?
2. What is the reason of Leakage – Old corroded pipe, quality of flange gasket etc.
3. Why condition of pipe not assessed (Failure of Mechanical Integrity Quality Assessment)
4. If assessed, why problem was not fixed
5. Was the employee made aware about use of specific PPEs for specific work?, Is Someone
ensuring that he is using such PPEs
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Must focus on Root Cause :
• We have readymade 14 Elements of Process Safety
Management.
• These can be used as Checklist to identify – Which
element of the PSM failed.
• What was the reason of Failure?
• What preventive action could have been taken to
Prevent the Incident?
• what PROACTIVE Action is required to prevent
Accidents in future?
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Technique mostly Popular are :
• Fishbone Analysis
• Why why analysis
• Accident Anatomy
• Event Tree and Fault Tree Analysis
Why Why (also
known as 5 – why) is
most Popular and
very easy method
Expert Advise is essential : Team should be
competent enough in PSM
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Any Question?????
Please

Process Safety Training :
How much do we really Focus on it in our Company
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• Average In-house education and training - Ned movement toward
Excellent :
Creating in-house education and training platforms can help build a
steady channel of talent required to Cultivate Process Safety Culture.
As outdoor trainers are costly and not possible to allow 100%
employees to attend outdoor programmes.
• Not involvement of Government Agencies:
The Government could look into building a framework to recognize
process industries. This will encourage or enforce industry players to
invest in training and time to develop talent for Process Safety
management. Only Section 111A of FA is there in Existence
Process Training in India : Area of Concern
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• Minimum Evolvement of technology in Training:
Today’s employees are technology inhabitants, hence, we need to
engage with them in a manner which they relate to – means use of
technology in the delivery of training will create interest and make it
effective.
• Negligible Outreach programmes:
There is a need to introduce outreach programs (Site Visits) to share
ideas and learn practical experience and best practices being followed
in similar industries.
Process Training in India : Area of Concern
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Awareness Available are not implemented:
Responsibility of Safety Professionals
Online knowledge is available in Google. Many HSE professional
whatsapp groups are created, knowledge are shared, problems are
discussed, ideas are exchanged and finally it is concluded that we are
somewhere failed to implement shared best practices. Reason of
failure may be economy of best safer practice, May be management is
not taking interest or may be other reason. But as Mr. R.K. Sharma
shared in whatsapp discussion, as safety professional – we have to sale
our safety as salesman because we know better the consequences of
Safety Failure.
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Reactive Approach rather than Proactive one :
Need Practical Awareness
• The major operational challenge in Process Safety Management is –
“Mechanical Integrity and its Quality Assurance”. Todays trend in this
regards is to wait till any failure is observed. Reason may be cost cutting.
• I have Audited so many MAH industries and it is found that :
- No one has History of Equipment, Pipe and supporting structure,
- Self life of MOC is not recorded,
- Replacement Plan is not there,
- Periodical Integrity Examination Plan is not there,
- Preventive Maintenance is not strong enough and Lack of Proactive
Maintenance Practices,
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Failure of following Accident Prevention Hierarchy :
Root Cause – “Lack of Training and Awareness”
• During discussion on any accident, Occupier or factory manager or
manager responsible for site management Start with Personal Protective
Equipment.
• I am sharing one a live Example of a Company :
One of the worker’s eye exposed with dilute Caustic lye solution resulted in
irritation and medical attention. Without discussion with safety peoples, a
circular about compulsion on Use of Goggle by all employees while they are
at work is served by topmost management. Major thing was : Violation may
attract Penalty as deduction of one day salary. While goggles are already
being used by those who are involved in such operation. No doubt, Safety
goggles must be used by everyone while moving at any area where such
chemicals are being handled but hierarchy of control must be kept in mind
while deciding control.
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Failure of following Accident Prevention Hierarchy :
Root Cause – “Lack of Training and Awareness”
No one has asked :
- What exactly happen
- What was the reason of exposure
- What is the root cause and
- What to do to prevent Leakage/Spillage/splash of Caustic solution
so that such incidents can be prevented?????
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PSM Training : Major Concern/Leading Challenge
• Costly Expert Trainer – as DoPont etc.
• Prioritization and understanding the importance of PSM training
• Lack of Training Effectiveness Evaluation
• Lack of Refresher Training and Training Consistency
• Availability of Trainers and Training Resources in Regional Languages
• Risk Taking behavior of the Industrialists
• Contractor Management - Major key focus Arwa for Training
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HSE Leadership : Basic Tool of PSM
Role Of Chemical Industries In Indian Economy :
1. It contributes approximately 3% of the GDP.
2. It is the 3rd largest in Asia and occupies the 12th place in the world.
3. It compromises both large and small scale manufacturing units.
4. Rapid growth has been recorded in both inorganic and organic sector.
5. Organic chemicals include petrochemicals which are used
for manufacturing of synthetic fibers, rubber, plastics, and dye stuffs.
6. Inorganic chemicals include sulphuric acid, fertilizers, synthetic
fibers, plastics, adhesives, paints, etc.
7. The chemical industry is its own largest consumer.
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Process safety is a deep topic and requires the involvement of nearly all staff,
workman and contractors at a company. But, how do you make sure your
staff are up to the task? And how do you judge the competency of
subcontractors or third party experts? This paper describes the basics of
building competencies in one of the process safety activities that require
expert levels of competency: PHA/HAZOP LEADERSHIP. The paper shows
how many companies, beginning with Olin Chemicals and others in the
1970s through hundreds of companies today have planned for the
progression to full competency of PHA/HAZOP Leaders and Scribes. The
paper describes step by step what is required for each level of competency.
One focus of the paper is that competency cannot be measured by exams
and case studies (at least not completely); competency must instead be
judged through hands-on observation, by those who are already expert in
PHA Leadership.
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Process safety is a deep topic and requires the involvement of nearly all
staff, workman and contractors at a company. But, how do we make
sure that our staff are up to the task? And how do we judge the
competency of subcontractors or third party experts is up to mark
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So many Questions are there but Leadership can
make it possible to manage Accident Free India

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Process safety management in india

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Process safety management in india