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Managing hazards

India has a disappointing health and safety record. Much legislation exists to protect workers’ rights and health, but there is an opportunity to improve in line with the approach taken by developed countries and include process safety elements for the prevention of accidents.

DR. J P GUPTA | New Delhi |

Chemicals are the thread that tieindustries together. From conventional oil/gas/bulk chemicals to pharmaceutical,automobile, agriculture, defense, solar power, building materials, apparels, telecom and mobile phone industries, 96 per cent of manufactured goods require chemicals.

The chemical industry is intended to improve the quality of human life. But if due respect is not given to chemicals, they can lead to loss of life and environmental damage.

This negatively impacts the reputation of the industry. Furthermore, the negative impact becomes greater when members of the public living outside factories are injured or killed. The chemical processes when designed and constructed as per international and national standards are safe to operate if processes are under control.

This requires adequate knowledge in process safety and risk management. The chemical industry is broad-based, consisting of very large industries as well as Medium scale and Small-scale industries. In India, several chemical accidents occur leading to fires, toxic releases and explosions.

These accidents have resulted in environmental damage, loss of life, and property destruction. India has developed several mega chemical regions such as Dahej, Ankleshwar, Vapi and Vadodara.

These regions include large companies, such as Reliance, Indian Oil, HPCL, BPCL, ONGC, etc. They maintain their own disaster response teams and resources. We have seen several accidents in small and medium companies and such companies depend on local response facilities. India has a disappointing health and safety record. Much legislation exists to protect workers’ rights and health, but there is an opportunity to improve in line with the approach taken by developed countries and include process safety elements for the prevention of accidents.

Chemical disaster prevention requires a different strategy. Neither National Disaster Management Authority nor other regulatory bodies can prevent manmade tragedies. There is an urgent necessity to develop the needed eco-systemin process safety and risk management, to minimize accidents. Process Safety Management addresses the barriers of protection required to prevent the loss of control, termed preventive barriers, which are specific to the process and are provided at the site.

There are also mitigative barriers which are generic in nature (e.g. fire-fighting vehicles, ambulances, medical centres, etc.).

These are expensive and lie idle most of the time. Hence MSME industries are not able to afford them. They are like insurance against the remote occurrence of an event. These must be installed and maintained irrespective of the responsible operation of the processes.

India’s economy is moving forward to make considerable progress in GDP.

“For every $1 generated by the chemical industry, a further $4.20 is generated elsewhere in the economy”.

Therefore, it is of utmost importance to focus on prevention of accidents. China has been the frontrunner in learning from accidents in past years and has included prevention aspects in education systems by collaborating with global universities. It is suggested that Industry should pool resources to install their own accident prevention programmes.

This is not philanthropy nor is it CSR, it is purely enlightened self-interest. No company is immune to what goes wrong in the neighborhood, either due to toxicity or due to fires/explosions.

Interdependent Process Safety Culture is the mantra for preventing such disasters by creating an ecosystem in process safety and risk management as the cornerstone of Aatmanirbhar Bharat (Self Reliant India).For this, India needs more than 100,000 scientists.

Therefore, there is need to introduce advanced courses in Process Safety and Risk Management including required infrastructure to carry out advanced research in process safety and risk management. India need to create entities for this purpose.

To meet these needs, every university should introduce advanced courses in Process Safety and Risk Management, with facilities to carry out advanced research on industryprojects. Next, India needs to set up a ‘Centre of Excellence’ offering master’s and Ph.D. programmes in the subject where educational institutions, government and industry should collaborate to promote education and research, and to support industries and regulatory authorities.

Such a COE should support regulatory authorities to keep abreast of evolving international developments; help in developing a national strategy, document and investigate all chemical accidents and allied activities. India does have the National Authority Chemical Weapons Convention (NACWC) under the Prime Minister’s Office and it covers all aspects of large numbers of chemicals. India also has the Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989, the Chemical Accidents (Emergency Planning, Preparedness and Response) Rules, 1996 and the Central Crisis Group Alert System and manuals on emergency preparedness on chemical hazards. But It is suggested we should have an independent agency, responsible for investigating industrial chemical accidents, like the Chemical Safety Board of the USA.

The Chemical Safety Board (CSB) is an independent federal agency charged with investigating industrial chemical accidents. Headquartered in Washington, DC, the agency’s board members are appointed by the President and confirmed by the Senate.

The CSB’s mission is to “drive chemical safety change through independent investigation to protect people and the environment”. Its vision is “a nation safe from chemical disasters”.

The CSB conducts root cause investigations of chemical accidents at fixed industrial facilities. Root causes are usually deficiencies in safety management systems but can be any factor that would have prevented the accident if that factor had not occurred.

Other accidental causes often involve equipment failures, human errors, unforeseen chemical reactions, or other hazards. The agency does not issue fines or citations but does make recommendations to plants, regulatory agencies such as the Occupational Safety and Health Administration (Osha), the Environmental Protection Agency (EPA), industry organisations, and labour groups. Congress designed the CSB to be nonregulatory and independent of other agencies so that its investigations might, where appropriate, review the effectiveness of regulations and regulatory enforcement.

The CSB investigative staff includes chemical and mechanical engineers, industrial safety experts, and other specialists with experience in the private and public sectors. Many investigators have years of chemical industry experience. Both accident investigations and hazard investigations lead to new safety recommendations, which is the board’s principal tool for achieving positive change.

Recommendations are issued to government agencies, companies, trade associations, labour unions, and other groups. The implementation of each safety recommendation is tracked and monitored by CSB staff.

When recommended actions have been completed satisfactorily, the recommendation may be closed by a board vote. Accidents leading to fires, toxic releases, and explosions occur in small and medium companies and immediate professional response is always a challenge.

The proposal is to pool the resources and make the services available within five minutes by centrally locating these.

Channel Industries Mutual Aid (CIMA) in the USA is a nonprofit organization combining the firefighting, rescue, hazardous material handling, and emergency medical capabilities of the refining and petrochemical industry in the Greater Houston Metropolitan area. Since 1955, this organisation has been providing cooperative assistance and expertise for all kinds of emergencies ~ both natural and manmade. CIMA members include industrial companies, municipalities and government agencies, and work cooperatively in four geographic response zones.

These groups maintain a corps of highly trained emergency personnel and a well-maintained pool of more than 200 pieces of specialized equipment, including rescue trucks, high-volume foam pumpers, and fully equipped ambulances. Joint operations are controlled from sophisticated command vehicles that link CIMA members via a radio system with a coverage range of 500 square miles.

The Houston Ship Channel has one of the largest concentrations of refineries and petrochemical plants in the world, and these industries recognise their responsibility to protect neighbours in the surrounding communities. CIMA is there to provide world-class, rapid response assistance whenever emergencies occur. In India, we lack such formal mutual aid arrangements (all large industries do have systems of mutual aid including in Industrial parks).

Such a proposal would involve creation, maintenance and governance of such facilities to achieve the twin objectives of preventing disasters,but when they happen responding to them fullywithin five minutes and bringing the situation under control within 20 minutes. They can be provided with state-of-the-art equipment and on-call expertise.

This will be at ground level, while all others can be at the satellite level and will require no funds from the government. Their efforts will eliminate the duplication of efforts by Mutual Aids Response Group of the Directorate of Industrial Safety and the National Disaster Management Agency and will seek their support when resources are stretched.

These centres will also focus on ensuring and enhancing the competency of chemical industry workers by getting them certified before they are deployed.

Such centres should be created, owned, and effectively governed by industry associations in an area likecommon effluent treatment plans and hazard waste management facilities. They may have participation from regulatory authorities depending on their financial contribution.

They should be led by competent experts in Process Safety Risk management and have wide representation from fire and medical professions. The industry should contribute depending on turnover of the facilities and set off the expense against CSR responsibility. Such facilities should be at central locations to reach the farthest industry within five minutes. The facilities must also have fire-fighting training, first-aid training, and other process safety risk training facilities.

Furthermore, these centres must also have mutual aid agreements with major industries for sharing infrastructure in the hour of need.

The writer is Chairman, Expert Appraisal Committee (Industry-II), Ministry of Environment, Forest and Climate Change, Government of India.