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National Safety Council, India

NSCI’s Virtual Classroom Training Program

NSCI INTERNAL OCCUPATIONAL SAFETY & HEALTH (OSH) AUDITOR’S COURSE

(28- 30 July, 2020)

OH & S MANAGEMENT
A Y Sundkar
Director
National Safety Council, India
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National Safety Council, India

“Safety is not an intellectual exercise to keep us in

work. It is a matter of life and death. It is the sum of our
contributions to safety management that determines
whether the people we work with live or die.”
Sir Brian Appleton

Piper Alpha worst offshore disaster in history of UK (6 July 1988) wherein 167 people died

As for us safety professionals, we take to heart the words of Sir Brian Appleton

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OH & S Management System

ILO A set of interrelated or interacting elements to establish OSH

2001 policy and objectives, and to achieve those objectives

Definition
ISO – 45001 Management system (or part of a management system) used to
2018 achieve the OH&S policy

The organizational structure, responsibilities, procedures,

IS – 14489 processes and resources specified by top management of an
2018 organization as required for implementing OHS objectives

The intended outcomes of the OH&S management system are to prevent

injury and ill health to workers and to provide safe & healthy workplaces

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OH & S Management System Elements

Elements as per IS 14489: 2018 – Occupational Health & Safety Audit - Code of Practice
Basic Elements (8) Sub elements (76)

1 OH & S Management 18 Planning

2 Physical Hazard 8

3 Chemical Hazard 8

4 Fire & Explosion Hazard 13

5 Industrial Hygiene & Occupational Health 6 Operational

6 Accident/ Incident Reporting, Investigation and 5

Analysis
7 Emergency Preparedness (On-site and Off-site) 13

8 Safety Inspection 5

14489: 1998 – Occupational Safety & Health Audit - Code of Practice (34 elements altogether)*
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OH & S Management Elements

OH & S Policy 1 2 OH & S organizational set-up

Safety Manual 3 4 Safer Operating

Standard Procedures
Operating (SOP)
Procedures (SOP)

Plant Modification Procedure 5 6 Work Permit System

Contractor’s Safety System 7 8 Plant Design & Layout

Medical Management of Accidents 9 10 Management of Emergencies (natural/ man-made)

Employee selection and placement 11 12 Safety Culture

Statutory licences, approvals & records 13 14 Motivational and promotional measures

Hazard identification and JSA 15 16 Product safety

Safety Training 17 18 Change Management

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1. OH&S Policy (contd…)

• Does the organization have policy? If yes, whether it is appropriate

to the organization?
• Who has signed policy?
• Whether policy is as per guidelines of the statutory provisions?
• When was policy declared and adopted?
• Whether policy reviewed periodically?
• What was the last date of updation?
• Whether policy is available in local language and made known to
all? Prominently displayed in the workplaces
• Does policy find a place in the annual report?

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1. OH&S Policy (contd…)

Factories Act and State Factories Rules
Sec Gen. Duties of Occupier - Occupier to prepare, periodically
7A(3)* revise and communicate statement of policy w.r.t. health and
safety of the workers and arrangements for carrying out that
policy.
Sec 41B(2)* Compulsory disclosure of Info by Occupier - Factory
involving hazardous process to prepare detailed policy and
intimate Chief Inspector at the time registration
State Rules Detailed coverage provided:
MFR – 73 L • intention and commitment of the top management including
: Health & Safety compliance of relevant statutory requirements
Policy • organisational set-up to carry out the declared Policy
• arrangements for making the policy effective.
• Communicate in a language understood by majority of workers
• Made available to the concerned inspector of factories.
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1. OH&S Policy (contd…)

BOCW (RE&CS) Act, 1996 and Central Rules, 1998

Rule 39: Establishment employing 50 or more building workers to
Health & prepare Policy in Hindi and local language understood by the
Safety Policy majority of building workers.

CEA (Safety Requirements for Construction, Operation, Maintenance of

Electrical Plants and Electric Lines) Regs , 2011

Reg. Owner is required to formulate a written statement of policy in

4(4-a) respect of safety and health of employees.

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2. OH&S Organisational setup

Intent – Establish commitment, involvement, accountability and responsibility at executive
levels for OHS risk management

Employer responsible for the protection of workers safety & health and provide
leadership for OHS activities.
Employer and Sr. Mgt should allocate responsibility, accountability and authority for
development & implement OHS mgt system
• Establish and implement OHS Policy
• Ensure that OHS is a line management responsibility which is known and accepted at all
level
• Define and communicate the responsibility, accountability and authority
• Provide effective supervision to ensure protection of worker
• Establish accident prevention and health promotion programmes
• Ensure participation of all in the fulfillment of OHS Policy
How is the organization structured, where are responsibilities and accountabilities defined, who
reports to whom and who is responsible for what?

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2. OH&S Organisational setup

Board of
Directors Plant Head
(OSH Responsible Person)

Fire
In-charge
Departmental Heads
Safety Safety
Committee In-charge
Line
Managers/Supervisors Covid
Medical Coord
Responsible to
In-charge inator

Accountable to Workers Safety

Representatives
Advice and support to

Represent Support
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2. OH&S Organisational setup

2.1 Leadership – Top Management, Middle Management and Jr. Management

1. Top Management
• Taking overall responsibility and accountability
• Ensuring OHS Policy and related OHS targets are established
• Ensuring the integration of OHS management system requirements into
organisations business process
• Ensuring resources needed to establish, implement, maintain and improves
OHS management system.
2. Middle Management
• Implement policy and ensure the system achieves its intended outcomes.
• Supporting their role in demonstrating their leadership to their area of
responsibility
• Directing and supporting the persons to contribute to the effectiveness.
• Developing, leading and promoting an organizational culture that supports the
OH&S management system
• Supporting to establish and function of Safety Committees
• Ensuring and promoting continual improvement
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2. OH&S Organisational setup (Contd..)

2.1 Leadership – Top Management, Middle Management and Jr. Management

3. Junior Management
• Implement policy and ensure the system achieves its intended outcomes
• Supporting their role in demonstrating their leadership to their area of
responsibility.
• Explain hazards, SOPs etc. to workers
• Protecting workers from reprisals when reporting incidents, hazard/risk
4. Worker
• Nominate their representatives on Safety Committees
• Support the management to implement OHS Policy
• Follow Rules and regulations of the organisatiuon
• Report any hazards/risk to the supervisor, manager, or representative of Safety
Committee Member (FA Sec. 41H – Right of Workers to warn about imminent danger)
• Participate in training programmes, campaigns, etc. for promoting safety

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2. OH&S Organisational setup (Contd..)

Legal Requirements
Factories Act
• Sec.7A(2)(a) - General Duties of Occupier - Occupier to ensure provision and maintenance of
plant and systems of work that are safe and without risk to health
• Sec 41 C (b) – Hazardous Processes : Appoint a person possessing qualifications and
experience in handling haz substances and competence to supervise

BOCW Act and Rules

• Sec 44 : Responsibility of employer - Employer to provide constant and adequate supervision
of work as to ensure compliance of the provisions of the Act relating to safety and take practical
steps necessary to prevent accidents
• Rule 39(1)(b)(iii) : H&S Policy - Organizational arrangements specifying responsibility at
different levels of hierarchy

CEA (Safety Requirements for Construction, Operation, Maintenance of Electrical

Plants and Electric Lines) Reg 2011
• Reg. 4 (4-b) - Owner has to set up a sound and scientific safety management system including
defining and documenting responsibilities for all levels of functionaries to carry out safety related
activities including responsibilities of the contractors.
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2. OH&S Organisational setup (Contd..)

2.2 (i) Safety Department

Intent – To advice the management on OHS matters

• Does the factory have a safety department and what is strength of safety
department?
• Whether the strength and qualifications of Safety Officers are as per the
statutes?
• Does the head of safety department report to the Chief Executive?
• How often are the safety officers retrained in the latest techniques of total safety
management? What is the frequency of retraining?
• What additional duties the safety officer is required to do?
• What is the power of safety officer vis-a-vis unsafe condition or unsafe act?

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2. OH&S Organisational setup (Contd..)

2.2 Safety Department – Legal requirements

Factories Act and State Factories Rules

• Sec 40 (b) - Employ safety officer if
(i) 1000 or more workers employed or
(ii) Mfg process or operation involves any risk to health. (The state government to
Notify)
• State Rules -Notified Safety Officers Rules with qualification and duties

BOCW Act and Central Rules

• Sec 38 - Safety Officers Rule 209 Sch VI
i) 500 to 1000 workers - 1 no. ii) 1001 to 2000 workers - 2 nos.
iii) 2001 to 5000 workers - 3 nos. iv) 5001 to 10000 workers - 4 nos.
v) For every addl 5000 or part thereof - additional 1 no.

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2. OH&S Organisational setup (Contd..)

2.2 Safety Department – Legal requirements

CEA (measures related to safety & electric Supply) Reg 2010

Reg 5 : (1) Electricity generating, transmission & distribution
Electrical companies to designate Electrical Safety Officer
SO (2) His qualification – BE with 5 years or Diploma with 10 years of
experience in operation & maintenance of electrical installation
(amended 2018)
(4) Every electrical installation including factories, mines or oil
field to designate Electrical Safety Officer where
connected electrical load more than 250 kW
Reg 5A Chartered Electrical Safety Engineer (CESE) –
• Govt. shall authorise CESE as per specified qual. & exp. to assist
the installation for self-certification
• Govt. to upload name of CESE on the portal
(amended 2018)

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2. OH&S Organisational setup (Contd..)

2.2 (ii) Fire Department

• How assessment of fire safety Factories Act – Sec 38 obligations of the occupier to take
practicable measures to prevent fire, which include-
measures are done? • To provide & maintain the firefighting equipment properly and
• train workers in steps to be taken in a fire accident.
• As per the assessment they The State Factories Rules, framed under the Factories Act, have
are in place prescribed in detailed requirement. MFR 79-B(9) states a
trained officer for maintenance of the equipment
• Responsible person for OISD standards STD 114 (Safe handling of hazardous chemicals); OISD
Inspection and maintenance STD 116 (Fire Protection Facilities for Petroleum Refineries and Oil/Gas
Processing Plants); OISD STD 117 (Fire Protection Facilities for Petroleum
• Training Depots, Terminals, Pipeline installations & Lube oil installations).

NBC 2016 (Part-4 : Fire & Life Safety)

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2. OH&S Organisational setup (Contd..)

2.2 (iii) Occupational Health Department

• Are First-aid Facilities and trained first aiders available? Factories Act and State
Rules
• Whether occupational health center is provided?
• Does OHC conform to the provisions of the existing statutes? BOCW Act and Rules
• Are the Medical Attendants/Doctors available in each shift? CEA Reg 2011 – Clause -4
(medical check up)
• What facilities are available for transportation of the injured Clause 10 – Medical facilities
to hospital?
• Has organization designated a COVID-19 co-Ordinator?
• What is mechanism for reporting any COVID patient to local
authority?

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2. OH&S Organisational setup (Contd..)

2.3 Safety Committee
Intent – Ensure employee participation in, and create participation forum to discuss
OHS related issues and solutions
• Does organization have a safety committee(s)? What are the types, structures and terms of
reference of the committees?
• Is the constitution of the safety committee as per the statute?
• How are the members of safety committee selected? (elected/ nominated)
• How often are the meetings of safety committee held?
• Are the recommendations of the committees implemented?
• Are the minutes of the safety committee meetings circulated among the members?
• Are the minutes forwarded to the trade union and chief executive and occupier?
• Whether the management and trade union play their active roles in supporting and
accepting the committee recommendations?
• How are the safety committee members apprised of the latest development in safety, health
and environment?
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2. OH&S Organisational setup (Contd..)

2.3 Safety Committee – legal requirements

Factories Act and Rules

• Sec 41-G : Workers participation in Safety Management - Haz. Process, set up
safety committee with equal representation of mgt & workers
• Rule 73-J : Safety Committee - Employing 250 or more workers
- Dangerous operations or hazardous process and more than 50 workers
- Equal representation (mgt. & workers)
- Composition, tenure (2 year) and functions are provided
- Meeting once in 3 months
BOCW Act and Rules
• Sec 38 Safety Committee and Rule 208B - Form a safety committee
- Employing 500 or more workers
- Composition and functions of committee provided

CEA Reg 2011 – Reg 6 (2-a) : Safety committee exceeds 250 workers

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2. OH&S Organisational setup (Contd..)

2.2 Safety Budget

• What is the annual safety budget?

• How much percentage is this budget of the total turnover of the
company?
• How much budget has been utilized till date?
• Is the safety budget adequate?
• How is the safety budget arrived at?
• What is the pattern of expenditure for the last five years?
• What are the approved sanctions for the expenditure in this budget?
• Does this budget get reflected in the Annual Report of the company?

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3. Safety Training
To develop OSH competence of employees to carry out safety
and health aspects of their duties and responsibilities and to
implement OSH mgt system training programme should:

• Cover all employees

• Be conducted by competent persons
• Provide effectively and timely and refresher training at
appropriate intervals
• Include participants’ evaluation of their training
• Be documented

Training should be provided to all participants at no cost and should

take place during working hours, if possible.

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3. Safety Training (Contd…)

Intent – Enhance skill/competence and motivate employees
• Whether training needs have been identified?
• Is there any programme of induction training, its duration and topics covered?
• What are the infra-structural facilities available for training?
• Whether training is conducted by qualified person?
• Whether trainers are being re-trained from time to time?
• Whether proper records of training program conducted are maintained?
• Whether schedule for training on OHS is available and maintained?
• Whether the training programmes are reviewed?
• Whether the assessment of the trainees has been carried out?
• Whether system is established to monitor suitability and effectiveness of training
programme, including that of outside agency?

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3. Safety Training (Contd…)

• Are all employees periodically trained/retrained and what is the frequency of such
training?
• Are the retraining needs identified, whenever a new process / products and change
in existing process introduced?
• Whether training covers top management?
• How many hours of safety training is given to different employees?
• Supervisors adequately experienced to provide on-the-job training.

• Have Supervisors been adequately trained on Covid-19?

• Whether all employees have been provided training on Covid-19?

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3. Safety Training (Contd…)

Factories Act and State Factories Rules
Sec.7A(2)(c) Occupier to provide information, instruction, training
General Duties of Occupier and supervision necessary to ensure the health and
safety of workers
Sec 41B Provide information regarding dangers,
Disclosure of info health hazards and measures to overcome such
(Haz Process) hazards to workers and general public in the vicinity

Sec 111 A Every worker has a right to get trained either within
Right of Workers the factory, or, at approved training centre/ institute

State Factories Rules Specific Rules to train operators of dangerous

machines or processes (wood working m/c, power
presses, oven & driers, chemical process, etc.) and
persons handling fire fighting equipment, first-aiders,
etc
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3. Safety Training (Contd…)

BOCW Act and Rules

Rule 39 Management should make arrangements for training of

building workers, trainers, supervisors or other persons
engaged in the construction work

Rule 39 b(v) Health & Safety Policy – training to workers, trainers,

supervisors or other persons engaged in construction work

Rule 64 Operation of lifting appliances – crane driver or lifting

operator possess skill and trained in operation

Rule 88 Earth Moving Equipment and vehicles – These to be

operated by well trained persons

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3. Safety Training (Contd…)

CEA (measures related to safety & electric supply) Reg 2010
Reg 6 : Safety Measures Engineers, supervisors and Technicians engaged
for O&M of electric Plant for operation and maintenance of electric plants
should have successfully undergone the type of
training as specified
Reg 7 : Safety Owner of every transmission or distribution system
Measures for O&M of should arrange for training of personnel engaged
transmission & in operation and maintenance either in-house or at
distribution system any recognized institute.

CEA ((Safety Requirements for Const., O&M of Electrical Plants

and Electric Lines) Reg 2011
Reg. 11(3): Safety Training and Awareness – Regular Safety training prg
to be conducted on awareness, PPE, first-aid, emergency,
etc. - 10 hrs trg per year to each

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3. Safety Training (Contd…)

Insecticides Act
Insecticides Rules, The manufacturers, distributors of insecticides and
1971 operators should arrange for suitable training in
Rule 42- Trg to observing safety precautions and handling safety
workers equipment provided to workers

CMV Act, 1988 and Rules, 1989

Sec 14 2(a) Renewal of license subject to 1-day refresher training for
drivers carrying hazardous goods (as per amendment
2019, initially for 3 years and for renewal Central Govt to
notify)

Rule 9 Successfully completion of 3-day training course

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3. Safety Training (Contd…)

Environment (Protection) Act, 1986

MSIHC Rules Occupier should provide to the persons working
Rule 4 (Responsibility of on the site with the information, training and
Occupier) equipment including antidotes necessary to
ensure their safety

Haz & Other Wastes The occupier of the facility should provide
(Mgt & Transboundry persons working in the site with appropriate
Movement) Rules training, equipment and the information necessary
2016 – Rule 6(b) to ensure their safety

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4. Safety Manual
Intent – To guide and direct all employees regarding organization's rules, procedures, and
communicates hazards & control measures. It is as supporting tool to training

▪ Is there a safety manual? Disseminate/disclose

information about
▪ What is the periodicity of updation/ review of safety
Safety – Sec. 7A , 41-B
manual?
& 111A –right of
▪ Does the safety manual adequately address all the hazards workers of FA
in the plant?
CEA Reg - 2011
▪ Are the employee made aware of safety rules/ instruction
Reg 4 (4C) – Requirement
mentioned in the safety manual?
Reg 5 – Content provided
in Schedule
▪ Are covered about any pandemic situation like Covid-19 Do’s
and Don’ts ?

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5. Standard Operating Procedures (SOP)

Intent – Manage high risk task effectively through formal written procedure

▪ Are written SOPs are available for all operations and FA – Sec 7 A(2) (a) (b) (c)
processes, particularly high risk task identified through risk
assessment or JSA? BOCW – Rule 2 (zzg) and Rule 5 –
▪ SOPs include sequence, tools, equipment and PPEs General Duties of employer
(Standard Operating Practices)
▪ Whether the written SOPs are displayed or made available
and explained in the local language to the workers? CEA Reg 2011 – 4 – content of
▪ Whether concerned section and safety department prepares Safety Manual
SOPs jointly?
▪ Are SOPs reviewed and updated? SMPV Rules 2016
▪ Have the workers been informed of the consequences of
failure to observe SOPs?
▪ Have you modified/reviewed SOPs taking into COVIOD-19
pandemic?

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Some Observations during audit

SOP display blocked SOP display blocked

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6. Plant Modification Procedures

Modification due to aging of the plant/machinery, augmentation of plant, regulatory
requirements, etc

▪ What is the system for effecting any change in the FA – Sec 7(a)
existing plant, equipment or process?
▪ Whether hazard assessment done before Sate Rules – 4 (d): Permission
in writing should be obtained
implementation of modification?
from Factory Inspector in case
of any changes

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7. Work Permit System

Intent –Control over execution of potentially dangerous tasks

• Work Permit written procedure available and updated? Sate Factories Rules – 73 C : Safety
measures in factories where
• Training to supervisors on compliance, monitoring and control equipment or pipeline containing
of permit flammable material
• What types of work permits exist in the factory? The system of work permit shall be
• Are the necessary forms detailing required safety introduced and Safety Officer or
authorized officer to check randomly on
precautions have been prepared and used for each type the work permit issued.
of work-permit? 73F – Fragile roof
• Is the responsibility assigned to authorized person for
issuing of safety work permit? Petroleum Rules, 2002
98- Maintenance or repair works by
• Is the copy of safe work permit sent to safety officer issuing a written permit - precautions
before execution of the job? to be observed and the procedure for
• Is validity period specified in the safety work permit? work.

• Are the records of work permit available and maintained

in proper order?
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7. Work Permit System (Contd…)

Types of work permit For what?

Cold Work An activity which does not produces sufficient heat to cause fire in
an inflammable air-vapour mixture
Hot work An activity which produces sufficient heat to cause fire in a
inflammable air-vapour mixture
Confine space It is an enclosure with known or potential hazards and restricted
means of entrance and exit, is not normally occupied by people,
and is usually not well ventilated
Work at height While working at a height of more than 3 meters, permit should be
issued by competent person before commencement of the job
Electrical isolation and Before issuing any work permit, it is essential that the equipment /
energisation permit facility to be worked on is electrically safe and electrical power is
isolated to the extent necessary for the safe conduct of the
authorized work.
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7. Work Permit System (Contd…)

Control Measures for Work at Height
❖ Is adequate safe access provided to all places where workers need to work?
❖ Are all such access in good condition?
❖ Are all scaffolds are properly designed and erected?
❖ Are scaffolds inspected every day before work begins?
❖ Are ladders securely clamped or lashed in place? Are planks in good condition?
❖ Are scaffold walkaways, platforms, runs or stairs free of debris, grease, any unnecessary obstruction
and projecting nails?
❖ Are the scaffolds higher than 20 m.? If yes, is a netting or intermediate railing provided between toe-
boards and hand railings?
❖ Are folding stepladders properly used?
❖ Are ladders set up at the proper slope of about 1:4?
❖ Are proper ladders used around electrical hazards?
❖ On sloping roofs, are crawling boards, lifelines, safety belts and edge protection provided where
needed?
❖ Whether the weak spots, skylights, or deteriorated asbestos-cement boards through which a worker
might fall while working in the roof has been identified and safety net provided appropriately?
❖ Are the workers being medically examined for their fitness to work at height?
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7. Work Permit System (Contd…)

Work in Confined Space

Intent – Create and ensure safe operation for work

❖ Is work permit system followed for working in confined space?

❖ Whether monitoring of the atmosphere inside the confined space is carried out
and ensured that there is no flammable or toxic gas in the area?
❖ Whether the person entering the confined space is using suitable PPE ?
❖ Is rescue team available in case of any emergency?

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8. Contractors’ Safety System

Intent – OHS risk and impact associated with contractors and contracts managed
• Is there any system for selection of contractors? MFR Rule 73-L (5c) –
• Are there any guidelines on contractor’s safety and training? Health and Safety Policy -
Fixing the responsibility of
• Whether contract document includes necessary safety and the contractor, sub-
welfare clauses as per statutes? contractors, transporters
• Is there any programme to ensure use of PPE by contractors and other agencies entering
personnel? the premises to compliance
the provision related to
• Do the contractors have their own safety organization? safety policy
• Are the contractors reporting all accidents and injuries?
The Contract Labour
• Are contractor workers trained to observe safety at workplace? (Regulation and Abolition)
• Whether contractor workers are engaged in process/ operations? Act, 1970 - Provide better
If yes, are they aware of safe operating procedures? conditions of work

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9. Plant Design and Layout

Intent – Right things in right place

• Whether hazardous operations in the plant are segregated? Sec 6 and state Rule – Approval of
Plan and stability certificate from
• Whether occupational health & safety aspects are Competent Person and revalidate
considered during the design? every 5 years or any modification,
• Are all the equipment provided with adequate space for changes etc.
working, maintenance, etc.?
• Are the storage tanks provided with enough space/
clearance between them?
• Whether the plant layout has taken care of the movement of
firefighting equipment and emergency exits?
• Illumination levels
• Fresh Air requirements

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10. Medical Management of Accidents

Intent – To provide immediate medical assistance to employees and maintain
optimum health status of workforce through the provision of a holistic occupational
health service.
• Are medical facilities available with trained first aid Factories Act
staff and equipment in round the clock shift for all Sec.45: (First Aid Appliances)
including contractors? MFR 73W – OHC requirement pf
hazrad process industry
• Is the ambulance van available for round the clock
basis with the dedicated driver? BOCW Act and Rules
Sec 36
• Is there any mutual aid scheme available with the Rule – 226 – ambulance room
nearest hospitals to manage and treat injured one
during emergency? CEA Reg 2010 – Reg 27 on first
Aid
• Are the workers/ contractor workers aware of
emergency medical facilities?

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11. Management of Emergencies (Natural / Man-made)

Intent – Severity and impact of emergencies minimized

• Does the system exist to detect and control these Factories Act
Emergencies? Sec, 41 B-4
• Has the organisation established, implemented and maintained BOCW ACT and Rules – 36
procedure for management of emergency scenarios. The (Emergency Action Plan
procedure should define requirements for:
– identification of potential emergency scenarios CEA Reg, 2011 – Reg 9 :
– development of emergency plans Emergency Management Plan
– Communicate emergency plan to all
– Testing of emergency plan MSIHC Rules – Rule 12
– Review of emergency plan
• All employees are aware of the measures to be taken during
emergencies?

• Is there a Covid-19 Crisis Management Committee at workplace?

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12. Employees Selection and Placement

Intent – Right person at right job

• Whether norms are available for selection Factories Act and Rules
of different category of employees? Sec 41 C (b) – Hazardous Processes : Appoint a
person possessing qualifications and experience
• Whether pre-employment medical
in handling haz substances and competent to
examination is being conducted for
supervise.
employees?
MFR 73H- Special Safety Precautions for highly
• Job rotation, particularly hazardous hazardous chemical process – Work of operator
process areas be supervised by competent person having
Graduate in Chemical Engineering/Technology
• Is there any procedure to evaluate safety
with knowledge of process.
performance/ and record of the
employees during their promotion (KPI)?
For Factory Medical Officers of Hazardous
Process Industries – AFIH Course

Appointing Safety Officers – As per SO Rules

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13. Safety Culture

Safety culture of an organisation is the product of individual and group values, attitudes,
perceptions, competencies, and patterns of behaviour that determine the commitment to,
and the style and proficiency of, an organisation’s health and safety management.

Attitudes of Managers
• Do the managers follow the plant safety Rules at all times?
• What are their attitudes towards safety reviews and audits?
• What is the response of management to safety violation?
• Whether safety related decisions are taken in consultation with the workers?
• What is the attitude of the managers towards nonuse of personal protective equipment?
• Any safety perception survey conducted? What is result of perception survey?

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13. Safety Culture (Contd…)

Attitudes of Workers
• Whether workers are aware of the consequences of their wrong actions?

• Are laid down safe working procedures followed strictly?

• What is the attitude of the workers towards their own mistake, which can prejudice safety?

• Do the workers report near miss incidents and suggest safety improvements?

• Are the workers aware of the system of rewards and sanctions relating to safety matters?

• What is the attitude of workers towards use of personal protective equipment?

• Any safety perception survey conducted? What is result of perception survey?

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14. Statutory Licenses, Approvals and Records

Intent –Facilitate compliance to legal requirements
IS 15793 : 2007 : Managing
• Whether all the safety related Acts / Rules (with latest environment, occupational health
amendments) applicable to your organization identified, and safety legal compliance —
informed to all employees and complied? Requirements of good practices

• Whether the licences have been validated?

• Specific legal requirements within applicable legislations

requirement

• Whether responsibuility has been fixed for keeping track

on regal compliance?

• Custodian of all legal documents.

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15. Motivational and Promotional Measures for OHS

Intent – To promote workers involvement in Safety & Health Management programme

• Does the factory have occupational health and safety suggestion scheme?
• Are occupational health and safety contests organized in the factory?
• Does the factory participate in any National Awards scheme?
• Has the factory been awarded during last five years?
• Does the organization publish safety bulletin/ newsletters?
• Whether the safety bulletins are widely distributed?
• How is the occupational health and safety information including accident
statistics disseminated in the factory? (Bulletin boards, Newsletter etc.)
• What are the activities conducted during National Safety day / week?
• What is the percentage of Workers participating in the various safety
promotional activities?
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15. Motivational and Promotional Measures for OHS ….. Contd..

Factories Act and State Factories Rules

Sec 41 (B) Disclosure of Information to workers - Hazardous process industry to
provide information regarding dangers and action taken in the form of
leaflet, booklet

SO Rule - Duties of Safety officer to organize safety campaigns, competitions, contests

SO and other activities

Safety Comm One of the function to undertake training and promotional activities

Sec7A(3),41B-2 Safety performance of individuals at different level while considering

Rule - Safety their career advancement (a motivational factor for Safety)
Policy

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15. Motivational and Promotional Measures for OHS

BOCW Act and Rules

Rule 208: Safety One of the functions of SC to stimulate the interests of employer and
Committee (SC) building workers by organising safety weeks, safety competition, talks
and film shows on safety, and taking similar other measures.
Rule 209 One of the functions is to organize campaigns, competitions,
contests and other activities to develop and maintain the interests
Safety Officer

CEA Reg, 2011

Reg. 11 Safety promotional activities be organized periodically to create
awareness and enthusiasm among employees like organizing
safety week , fire safety week, safety competition, posters, slogans,
safety calendars and display possible consequence of unsafe act
and condition in the conspicuous locations in plant.

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16. Change Management

1. Management of Change
• Are there written procedures for managing change to process chemicals, technology,
equipment and procedures and changes to facilities that affect the plant process/ system
operation?
• Do the procedures assure that the impact of the change on safety and health addressed
prior to any change?
• Do the procedures assure that modifications to operating procedures are addressed prior to
any change?
• Do the procedures assure that the necessary time period for the change is addressed prior
to any change?
• Do the procedures assure that the authorization requirements for the proposed change are
addressed prior to any change?
• Are employees involved in operating a process, and maintenance and contract employees
whose job tasks will be affected by change informed of, and trained in, the change prior to
the start-up of process or affected part of process / operations?
• Is the safety information is reviewed and updated on changes?
• Are the operating procedures or practices updated? 50

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16. Change Management

2. Mechanical Integrity
• Does the mechanical integrity program include for all mechanical equipment including
pressure vessels and storage tanks, piping and components, relief devices and vent
systems, emergency shutdown systems, pumps, control systems?
• Are there written procedures to maintain the ongoing integrity of process equipment?
• Whether training been provided to each employee involved in maintaining the on-going
integrity of process equipment?
• Are inspections and tests performed on each item of process equipment included in the
program?
• Does the inspection and test frequencies meet the manufacturer’s recommendation and
good engineering practice?
• Are inspections and tests performed more frequently if determined necessary by operating
experience?
• Are deficiencies in equipment that are outside limits corrected before further use so as to
assure safe operation?

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16 Change Management
2. Mechanical Integrity Contd..
• In the construction of new plants and equipment, whether quality assurance programme is
implemented to ensure that equipment fabricated is suitable for the process?
• Are appropriate checks and inspections made during equipment installation stage?
• Whether the process(s) and equipment that generate and accumulate static charge have
been identified?
• Are the suitability of maintenance materials, spare parts and equipment ensured during
maintenance?

Legal Requirements

• MFR 65 - pressure vessels tested by competent person before taking into use

• SMPV Rules 2016 - Rule 33: Certificate of safety to provide the authority

• MSIHC Rule – 11: Safety report before 90 days of modification/ alternation

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17. Product Safety

Intent –
• Whether hazards arising from use of The Factories Act,1948
the products are identified? Sec.7B ( c) -Manufacture to provide instruction about

• Whether MSDS prepared for the product’s use, tested condition for its usage
The MSIHC Rule,1989
products? Rule 17 schedule 9 - Collection, development and
• Are all the products labeled and packed dissemination of information
The Explosives Rules, 2008
appropriately?
• Whether safety instructions are given
Rule 14 & Rule 15 - Packages of explosives & Labelling

along with IS 1260-1 : Pictorial marking for handling and labelling of

• products?
goods, Part 1: Dangerous goods

• Whether policy exists for recall of

The Insecticides Rules 1971
Rule 19 - Labelling
products? The Gas Cylinder Rules,2018
Rule Identification colours
IS:4379 for industrial cylinders and IS:3933 for medical
cylinders

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If you want to improve the performance

of your organisation, you must not only
focus your people to work on the right
things, but also improve the way your
people work.

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THANK YOU

National Safety Council

…..Your safety is our passion…..

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