Course Material

NSCI Internal Occupational Safety and Health

(OSH) Auditor’s Course

NATIONAL SAFETY COUNCIL

Plot No. 98-A, Institutional Area,
Sector 15, CBD Belapur,
Navi Mumbai – 400 614

Phones: 022 - 2757 9924-26 E-mail :[email protected]

Fax : 022 - 2757 6411 Website: www.nsc.org.in
 INDEX
1 INTRODUCTION 1
2 DEFINITIONS-TERMINOLOGY 4
3 STATUTORY REQUIREMENTS FOR 5
OCCUPATIONAL SAFETY AND HEALTH AUDIT
4 OVER VIEW TO REVISED IS 14489(2018)- 7
OCCUPATIONAL HEALTH AND SAFETY AUDIT —
CODE OF PRACTICE (First Revision)
5 ELEMENTS OF OCCUPATIONAL HEALTH AND 13
SAFETY (OH & S) SYSTEMS

A-1 OH & S MANAGEMENT 15

a) OH & S Policy 15
b) OH & S organizational set-up 17
c) Safety manual 20
d) Standard Operating Procedures (SOP 24
e) Plant modification procedure 26
f) Work permit system 27
g) Contractors’ safety system 29
h) Plant design and layout 34
i) Medical management of accidents 39
j) Management of emergencies (natural / man-made) 44
k) Employee selection and placement 51
l) Safety culture 53
m) Statutory licenses, approvals and records 60
n) Motivational and promotional measures for OH & 64
o) Hazard identification and job safety analysis 69
p) Product safety 73
q) Safety training 76
r) Change management 79

A-2 PHYSICAL HAZARD 82

a) Housekeeping 83
b) Machine and general area guarding 86
c) Material handling 88
d) Electrical safeguarding 93
e) Safety in storage and warehousing 97
f) Hazard assessment of new equipment 100
g) Hazards from radiation sources 101
h) Control measures for specialized industrial hazards 105
like work at height and work in confined space

A-3 CHEMICAL HAZARD 111

a) Transportation of hazardous substances 112
b) Handling of hazardous substances 123
 c) Storage of hazardous substances 123
d) Spill control measures 129
e) Material Safety Data Sheet (MSDS) 130
f) Gas cylinders 132
g) Labelling and colour coding 133
h) Hazardous waste management 135

A-4 FIRE AND EXPLOSION HAZARD 140

a) Organizational setup for fire fighting 141
b) Built in safety in civil design and construction 142
c) Built in Safety in Electric Circuits and Equipment 146
d) Explosive substances 148
e) Fire safety in handling flammable and explosive 151
materials
f) Fire detection and alarm system 153
g) Passive and active fire protection system 155
h) Fixed fire extinguishing system 158
i) Portable Fire Extinguishing System 161
j) Fire fighting equipment and facilities 163
k) Fire drill 164
l) Fire fighting training 164
m) Static electricity and lightning 165

A-5 INDUSTRIAL HYGIENE / OCCUPATIONAL HEALTH 168

a) Vibration, heat stress, Non-ionizing radiations, 169
ventilation, illumination and noise
b) Work place monitoring for hazardous chemicals 184
c) First aid facilities and occupational health centre 187
(OHC)
d) Periodic medical examination 189
e) Personal protective equipment and emergency 198
equipment
f) Occupational disease 204

A-6 ACCIDENT / INCIDENT REPORTING, 206

INVESTIGATION AND ANALYSIS
a) Accident reporting, 207
b) Accident investigation 215
c) Analysis of accidents 222
d) Implementation of recommendations 226
e) Reporting and investigation of near -miss incidents 228

A-7 EMERGENCY PREPAREDNESS (ON-SITE / OFF 230

SITE)
a) Site specific details 231
 b) Duties and responsibilities of key personnel 231
c) Identification of emergencies and accident scenario 232
d) Declaration and termination of emergency 233
e) Resources-evacuation / transport 233
f) Communication facilities 234
g) Medical care 235
h) Updating of emergency plan 235
j) Periodic drills / exercises 236
k) Training of plant personnel 238
m) Public awareness programmes 239
n) Mutual-aid programme 239
p) Emergency control centre 240

A-8 SAFETY INSPECTION 241

a) Inspection programme 242
b) Safety Related Deficiency (SRD) Report 243
c) Safety inspection records 243
d) Methodology and inspection team 244
e) Compliance of recommendations 246

A-9 OTHER RELEVANT TOPICS 247

a)Techniques of collecting information 248
b) Report writing 249
c) Examination of Documents 251
 1. INTRODUCTION

BACKGROUND:

IS code 14489 "Occupational Health & Safety Audit –code of Practice Code of Practice” was first
published in the year 1998, NSC had played a major role in developing this Standard. To address
the growing need of the Industry this standard was taken up for revision and the revised version
of standard was published recently. Revised standard IS code 14489 of 2018 has many new
elements, In the old version there were 31 elements, in new revision, the elements are
categorized as 8 major elements and 76 sub-elements.

The responsibility for safe operation of industrial plants is clearly placed on the top executives of
companies under provisions of the Factories Act, 1948 as well as the Environment Protection Act,
1986. To effectively discharge this responsibility, there is a need for laying down the broad safety
policy as well as a comprehensive programme to ensure its implementation. Thereafter, it is
important for management to review the performance of the safety activity and programme of a
company on periodical basis.

Occupational Safety and Health (OSH) Audit is a useful technique to undertake a systematic
critical appraisal of the effectiveness of a company’s safety programme. Such a periodic review
provides an independent assessment on the correctness of the basic direction as well as
identifies specific areas for action to improve the programme. OSH Audit is a tool for ensuring
that the plant operation and maintenance procedures match the design intent and standards. It
keeps operation personnel alert to the process hazards; reviews operating procedures for
necessary revision; seeks to identity equipment or process changes that could have introduces
new hazards; and review adequacy of maintenance and safety inspections.

ABOUT THE COURSE

NSC has specially designed this internal OSH Auditor’s course, to bring out awareness and to
train the internal auditors to carry out internal Occupational Safety and Health audits as per
revised IS code 14489 of 2018. This course will be very useful for enhancing the internal auditing
skills in line with new developments.

This standard can be used as a guideline for self-demonstration of conformance to major

elements of IS / ISO 45001 to others and compliance to IS 15793 i.e. Managing environment,
occupational health and safety legal compliance Requirements of good practices”

This training course will give and appreciation of the role techniques involved in company safety
audits. The internal OSH Auditor’s course will highlight the methodology to be adopted, the
elements of management and technical systems, statutory requirements as well as the standards
against which they will be audited, and use of checklist, strategies for effective action on audit
reports. It is normal part of good business practice to initiate and carry out systems of inspection
and checking to ensure the operations are performed in an efficient and profitable way. No
management would consider that its financial statement to be true unless the accounts had been
audited. The stores controller would be working in the dark were it not for periodic stocktaking.
Engineers are rightly concerned that equipment is regularly inspected and checked. Control of
laboratory techniques ensure that specifications are adhered to.

Accident prevention is just as much an aspect of efficient operation as in any other industrial
activity. Yet many manager still tend to look at suggestions that their company’s safety and loss
prevention measures should be subjected to regular scrutiny and where necessary with
constructive criticism. In fact, internal safety audit is an important tool for identifying falling
standards, areas of risks or vulnerability, hazards and potential accidents in existing plants and

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processes; for determining the action necessary to remove hazards before personal injuries or
damage occur; and for ensuring that the whole safety effort is effective.

Before the managements of companies question at the prospect of a possibly expensive and
time-consuming addition to their activities, it should be made clear that internal OSH audit
schemes can be tailored to the needs of each locations. A simple but often very effective method
in some factories is a purposeful, frequent walk-round by a works manager, provided it is properly
organised to cover a whole plant within a reasonable time and the objective is to see that proper
regard is being given to safe working. Other sites, because of size highly sophisticated processed
or potentially hazardous chemical may require a more formal and complex auditing system,
carried out by people with specialist knowledge and training.

Various indices for attempting to assess the results of a company’s safety activities are well
known. They include injury rate, frequency and duration, estimating financial loss due to fire and
other damage and recording the number and types of injuries. All these methods have certain
things in common; they are qualitative, and because they measure results only are not always
strictly related to the quality of a company’s safety effort.

What is needed, therefore, is a method which will give a reasonable indication of how well a
company’s safety programme is working in all its aspects, how hazards are being recognized
and controlled, how unsafe acts are being eliminated, how accidents are being avoided.

Top management of the US chemical companies noted for profitability as well as good safety
records, effective safety and loss prevention programmes were essential for a company’s
prosperity and accepted as part of good business practice. The report suggested that one
requirement of such programmes was that their efficiency should be checked by the introduction
of safety audits to ensure that a company’s assets were effectively safeguarded. A system of
independent auditing should use the best people available for either inside or outside the
company.

The loss potential in the chemical and allied industries is high and is not restricted to large-scale
incidents related to accidents, fire, explosions. For example, failure or damage to cable and
instrumentation equipment as the result of a minor incident has led to lengthy down-time of plant,
resulting in heavy financial loss. Loss potential also is not confined to activities concerned with
the production of chemicals.

OBJECTIVE OF THE COURSE

On completion of this course, participants will be able to:

• Perform an internal OSH audit in accordance with revised IS code and regulatory
guidelines, hence it will beneficial to the industry.
• Identify significant hazards and risks in the work areas.

Whatever the objective may be, it is of paramount importance that be clearly defined after
preliminary discussions within the plant or company and then be effectively communicated to all
concerned. They must also be subject to periodic review, as indeed must be technique as a
whole

In general, the objectives should cover the examination and qualitative assessment of all facets of
safety of every activity. The activities should include research and development, design,
occupational health and hygiene, environmental control, product and public safety (including
storage, packaging labelling and transportation) as well as those associated directly with
production, technical operation, maintenance, clearance certificates, emergency procedures, job
description and operating instruction, training, housekeeping and personal attitudes. The

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formalised systematic critical approach of the audit technique can be applied with very real
advantage at various stages in the development of a new process or plant or in a major alteration
to an existing one.

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 2. DEFINITIONS-TERMINOLOGY
Safety audit, the title chosen for this course is increasing by being used as a general term to
describe any of a wide range of level of surveillance. However, the terms Safety Audit, Safety
Survey etc. have specific connotations. It is hoped that the following definitions will only assist the
reader and help to standardize more precise use of the various terms.

Occupational Health and Safety Audit (Audit) — A systematic, objective, documented and
independent evaluation to determine whether, the activities conform to the requirements of the
occupational health and safety systems and procedures monitored.

Audit Team — A team of persons designated as auditors who are suitably qualified and have
experience to perform these audits.

Nonconformity — The non-fulfilment of specified requirement.

Safety Survey

A safety survey is a detailed examination in depth of a narrower field of activity revealed by safety
audits e.g. major key areas, individual plants, procedures or specific problems common to a work
as a whole. These too are followed by a formal report, action plan and subsequent monitoring.

Safety Inspection

A routine scheduled inspection of a unit or department which may be carried out by personnel
within the unit, possibly accompanied by someone from outside. The inspection would check
maintenance standards, employee involvement, working practices and that work is carried out in
accordance with procedure etc. rather than the wide-reaching or in-depth approach taken in
audits or surveys.

Safety Tour

An unscheduled examination of a work area, carried out by any personnel from works managers
to safety committee members to ensure that e.g. standards of housekeeping are at an acceptable
level, obvious hazards and in general that safety standards are observed.

Safety Sampling

A specific application of Safety Inspection/Tour designed to measure by random sampling the

accident potential by counting safety defects. Trained observers record the number of safety
defects seen while touring specifications by a prescribed route. Typically, tours last only 15
minutes and are conducted at weekly intervals. The un-weighted count of defects is used to
potray trends in the safety situation.
***

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3. STATUTORY REQUIREMENTS FOR OCCUPATIONAL SAFETY
AND HEALTH AUDIT
The process of conducting periodic safety audits has been gradually institutionalized in India
aftermath of the Bhopal disaster in 1984. Till 1994 there was no direct statutory obligation for
conducting safety audit. In 1994 for the first time the requirement for carrying out an independent
safety audit was introduced in the Manufacture, Storage and Import of Hazardous Chemicals
Rules, 1989 notified under the Environment (Protection) Act, 1986. The ‘Control of Industrial
Major Accident Hazards Rules’ (CIMAH Rules,) 1999 subsequently notified by various states
under the Factories Act includes similar provision.

The Government of Maharashtra notified ‘The Maharashtra Factories (Safety Audit) Rules, 2014’
wherein the requirements regarding frequency, audit standard, qualification, experience and
recognition/approval of the safety auditors and the scope of the audit are explicitly mentioned

Legal Requirements:

Sr. Statute Section/sub- Provisions

No. section /
rule/sub-rule
i The Factories Act Sec. 7A(1) Every occupier shall ensure, so far as is
1948 reasonably practicable, the health, safety and
welfare of all workers while they are at work in
the factory.
ii The Factories Act Sec. 41B(1) The occupier of every factory involving a
1948 hazardous process shall disclose in the manner
prescribed all information regarding dangers,
including health hazards and the measures to
overcome such hazards arising from the
exposure to or handling of the materials or
substances in the manufacture, transportation,
storage and other processes, to the workers
employed in the factory, the Chief Inspector, the
local authority within whose jurisdiction the
factory is situated and the general public in the
vicinity
iii The Manufacture, Rule 10(4) After the commencement of the Manufacture,
storage and import Storage and Import of Hazardous Chemicals
of (Amendment) Rules, 1994, the occupier of both
hazardous the new and the existing industrial activities
chemical Rules, shall carry out an independent safety audit of
1989 the respective industrial activities with the help
of an expert, not associated with such industrial
activities.(this is adopted by all state factory
rules )
iv The Maharashtra Rule 73-L(5 e) In particular, the Policy should specify the
Factories Rules. following:-
1963 Relevant techniques and methods, such as
safety audits and risk assessment for periodical
assessment of the status on health, safety and
environment and taking all the remedial
measures;

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Sr. Statute Section/sub- Provisions
No. section /
rule/sub-rule
v The Maharashtra Rule 9(2) The occupier of any new and the existing industrial
Factories (Control activities shall arrange to carry out safety audit as
of Industrial Major under:-
Accident Hazards) Internally once in a year by a team of suitable plan
Rules,2003 personnel
Externally once in two years by competent person
approved in this behalf.
Note: In the year when an external audit is carried
out, it would not be necessary to carry out internal
audit.
vi The Maharashtra Rule 1(2) They shall apply to the factories,-
Factories (Safety (i) in which manufacturing processes, which
Audit) Rules, 2014 involves use, storage, handling or processing of
toxic or highly inflammable or explosive or
hazardous chemicals or wherein such toxic or
highly inflammable or explosive substances are
likely to be generated or given out, are carried out,
or
(ii) in which the hazardous processes as listed in
First Schedule appended to clause (b) of section 2
of the Factories Act, 1948 (LXIII of 1948)is carried
out; or
(iii) Employing more than 250 workers.
vii The Maharashtra Rule 2(vii) “Safety audit” means a systematic, objective and
Factories (Safety document
Audit) Rules, 2014 evaluation of the occupational safety and health
systems and procedures in a factory,
viii The Maharashtra Rule 2(viii) “Safety Auditor” means a person recognized by a
Factories (Safety committee
Audit) Rules, 2014 constituted by State Government as per rule 5 to
carry out safety audit in accordance with these
rules and include the safety auditors mentioned in
sub rule(3) of rule 5;
ix The Maharashtra Rule 3 a measure for securing the safety of persons
Factories (Safety employed therein, the following manner, namely:-
Audit) Rules, 2014 (a) internally, once in a year by a team of Plant
personnel;
(b) externally, once in two years by the Safety
Auditor:
Provided that, in the year, when an external audit is
carried out, it shall not be necessary to carry out an
internal audit
Provided further that, in case of any changes, total
or partial, in the manufacturing process, the
occupier shall, within one month prior to such
change, carry out the safety audit externally by the
Safety Auditor
x The Maharashtra Rule 4 The Safety Audit shall be carried out as per the
Factories (Safety standards laid down as IS14489: 1998 in the Indian
Audit) Rules, 2014 Standard Code of Practice on Occupational Safety
and Health Audit

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4. OVER VIEW TO REVISED IS 14489 (2018)- OCCUPATIONAL
HEALTH AND SAFETY AUDIT — CODE OF PRACTICE (First
Revision)
This standard was first published in 1998. With the passage of time, it was felt to revise the
standard with a view to incorporate new elements which are relevant to the industry in the present
context including the safe behavior of workers at work place.

This Indian Standard (First Revision) was adopted by the Bureau of Indian Standards, after the
draft finalized by the Occupational Safety and Health Sectional Committee, had been approved
by the Chemical Division Council.

This standard focuses on general Occupational Health and Safety Audit to be carried out in
various industries including Major Accident Hazard industries. Specific audits can be carried out
in areas identified based on the general Occupational Health and Safety Audit or in the high risks
operations or when there is a high frequency of accidents. Based on the identified elements, type
of hazards and nature of the work carried out, a detailed safety audit checklist for conducting the
audit should be developed.

This standard can be used as a guideline for self-demonstration of conformance to IS / ISO

45001 to others and for compliance to IS 15793.

The clause 3 of the standard gives terminology various terms.

Occupational Health and Safety Audit (Audit) is defined as — A systematic, objective,

documented and independent evaluation to determine whether, the activities conform to the
requirements of the occupational health and safety systems and procedures. Occupational Safety
and Health Audit is defined as a systematic, objective and documented evaluation of the
occupational safety and health systems and procedures.
There are two types of audits, external and internal. External audits are those carried out by
agencies external to the auditee organization. Internal audit are those carried out by the
employees designated by the management for this purpose. Such employees may be selected
preferably from amongst those not having direct responsibility in the areas being audited and
having no responsibility for implementation of recommendations.
These audits may be periodic, or may be prompted by significant changes in the organization’s
OH & S system, process, product or service or by a need to follow up legal requirements.

4.1 Audit goals (as stated in IS)

Audits are normally designed to achieve one or more of the following goals:

a) To provide the auditee with an opportunity to assess its own OH & S system against a OH &
S system standard and identify areas for improvement;
b) To determine the conformity of the implemented OH & S system with specified requirements
and identify areas for improvement;
c) To meet regulatory requirements.

4.2 Audit Objectives

OH & S audits are to be conducted with the following objectives:

a) To carry out a systematic, critical appraisal of all potential hazards involving personnel, plant,
services and operation method; and

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b) To ensure that OH & S system fully satisfies the legal requirements and those of the
company’s written safety policies, objectives and program.

4.3 Roles and Responsibilities ;

The standard specifies the responsibilities of various persons/organizations

a) Audit team

It is desirable to have the OH & S audit team comprising of two or more auditors; with different
specialized backgrounds, which are complementary. One of the auditors should be designated as
the lead auditor and should have overall charge and responsibility. Auditors should be qualified,
trained and experienced in the related areas.

b) The lead auditor

Lead auditor is ultimately responsible for all phases of the OH & S audit. The lead auditor should
have management capabilities and experience and should be given authority to make final
decisions regarding the conduct of the audit and any audit observations. The lead auditor’s
responsibilities also cover:

• Selecting the audit team members;

• Preparing the audit plan;
• Planning the field visit;
• Defining the requirements of each audit assignment;
• Communicating with client, auditee and other auditors regarding audit requirements;
• Briefing the audit team and guide the auditors to prepare the working document;
• Reporting critical nonconformities resulting in imminent danger to the auditee
immediately;
• Interacting with the client and auditee’s management;
• Reporting any major obstacles encountered in performing the audit;
• Maintaining agreed time schedule.
• Preparing audit report with the help of auditors;
• Reporting the audit results objectively, clearly, conclusively and without delay.

c) Auditors’ responsibilities

Auditors are responsible for:

• Complying with the applicable audit requirements;

• Scheduling and carrying out assigned responsibilities effectively and efficiently;
• Preparing additional checklist if required;
• Documenting the observations;
• Reporting the audit findings;
• Verifying the effectiveness of corrective actions taken as a result of the earlier audits;
• Retaining and safeguarding documents pertaining to the audit ensuring such documents
remain confidential, and treating privileged information with discretion.

d) Auditors’ duties

Auditors should be free from bias and influences, which could affect objectivity. Auditors should
not be indecisive and aggressive. Auditor should:

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 • Remain within the audit scope;
• Exercise objectivity;
• Collect and analyse evidence that is relevant and sufficient to permit the drawing of
conclusions regarding the audited OH & S safety system;
• Remain alert to any indications of evidence that can influence the audit results and
possibly require more extensive auditing;
• Be able to answer such questions as presented by the auditee with respect to the
relevance of the auditor’s queries;
• Should be able to convince the auditee about any apprehension, if any, regarding audit
findings;
• Ensure that the procedures, documents and other information specifying requirements of
the H & S system are known, available, understood and used by the auditee’s personnel;
• Ensure that all the documents and other information used to describe the safety system
are adequate to achieve the required OH & S objectives;
• Act in an ethical manner at all times.

e) Attributes of auditors

Trust, integrity, confidentiality and discretion are essential to auditing. Auditors should possess
the following personal attributes to enable them to act in accordance with the purposes of auditing
described

• Ethical, that is, fair, truthful, sincere, honest and discreet;

• Open-minded, that is, willing to consider alternative ideas or points of view;
• Diplomatic, that is, tactful in dealing with people;
• Observant, that is, actively aware of physical surroundings and activities;
• Perceptive, that is, instinctively aware of and able to understand situations;
• Versatile, that is, adjusts readily to different situations;
• Tenacious, that is, persistent, focused on achieving objectives;
• Decisive, that is, reaches timely conclusions based on logical reasoning and analysis
• Self-reliant, that is, acts and functions independently while interacting effectively with
others.

f) Client or Head of organization;

Client should:

• Determine the need for and the purpose of the OH & S audit and initiate the process;
• Select the auditing organization;
• Agree in consultation with the lead auditor the general scope of the audit such as what
OH & S system standard or document is to be selected as reference and the time
schedule;
• Define the audit reporting requirements;
• State specific confidentiality requirements, if any;
• Receive the audit report;
• Determine follow-up action to be taken in consultation with the auditee.

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 g) Auditee (Safety Department)

Auditee should :

• Inform relevant officials and staff about the objectives and scope of the audit;
• Appoint one or two officials to coordinate / liaise with audit team;
• Provide all resources needed for the audit team in order to ensure an effective and
efficient audit process;
• Provide access to the facilities and evidential material as requested by the auditors;
• Co-operate with the auditors to facilitate achievements of audit objectives;
• Review of the audit results
• Ensure implementation of corrective actions based on the audit report

4.4. AUDIT METHODOLOGY

a) Scope
The client in consultation with lead auditor and auditee organization make the final decisions on
which OH & S system elements, physical locations and organizational activities are to be audited
within a specified time frame. The scope and depth of the audit should be designed to meet the
client’s specific information needs. Generally the audit is carried out to cover the following aspects:

• Identification of areas of OH & S system, which require improvement;

• Assessment of effectiveness of measures taken for controlling the hazards
• Recommendation of measures to strengthen the OH & S system
• Implementation of these measures;
• Monitoring of the changes. Actions with respect to serial number

b) Audit Frequency
The need to perform an audit is determined by the client, taking into account specified or regulatory
requirements and any other pertinent factors. Significant changes in management, organization,
policy, techniques or technologies, and products that could affect the OH & S system, or changes to
the system itself and the results of recent previous audits, are typical of the circumstances to be
considered when deciding audit frequency.

It is desirable that organizations have a combination of external and internal OH & S audit system.
While the external audit in respect of organizations may be conducted once in two years, or as
specified by any statute, the frequency of internal audit may be set once in every year. Records of
accidents and dangerous occurrences should be examined and used to identify high-risk areas and
activities and consequently the frequency of internal audit may be increased.

c) Preliminary Review of Auditee’s Requirements of OH & S System

Client shall send the auditee’s specified requirements and description of OH & S system including
manufacturing processes, organization structure etc. to the lead auditor. As a basis for planning the
OH & S audit, the lead auditor should review adequacy of the auditee’s specified requirements and
recorded description of the methods for meeting the OH & S system requirements (such as the
safety manual or equivalent). on the audit until such concerns are resolved to the satisfaction of the
client, the lead auditor and, where applicable, the auditee. While it is desirable to have a well-
defined set of specified requirements and recorded description, in their absence, audit may be
conducted with reference to legal requirements and concerned standards.

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 d) Audit Plan
The audit plan should be finalized by the lead auditor after consultation with the client and
communicated to the auditors and auditee. The audit plan should be flexible in order to permit
changes in emphasis based on information gathered during the audit, and to permit effective use of
resources. The plan should include:

• Audit objectives and scope;

• Schedule of audit activities;
• Identification of reference documents (such as the applicable OH & S system standard and
the auditee’s description and specified requirements of their safety system);
• Composition of the audit team
• Identification of the organizational units to be audited;
• Schedule of meetings to be held with auditee management;
• List of documents to be perused by the audit team;
• Audit report distribution and the expected date of issue.

e) Audit Team Assignments:

Each auditor should be assigned specific OH & S system elements or functional departments to
audit. Such assignments should be made in consultation with the auditors concerned. The lead
auditor should hold a briefing session for his team prior to the audit at which he will ensure that
preparations are complete and that all members are aware of their roles.

f) Working Documents of the Audit Team

The documents required to facilitate the audit may include:

• Check-lists used for evaluating OH & S system elements (normally prepared by the auditor
assigned to audit that specific element),
• Forms for documenting observations and supporting evidence. Working documents should
be so designed that they do not restrict additional audit activities, which may become
necessary as a result of information gathered during the audit. Working documents
involving confidential or proprietary information shall be suitably safeguarded by the
auditing organization.

g) Questionnaire of Preliminary Information

The lead auditor would send to the auditee management a questionnaire seeking information
about various elements of OH & S system as given in Annex A. This would be filled in by the
auditee and returned for study by the audit team before the field visit.

h) Opening Meeting

The purpose of an opening meeting is to:

• Introduce the members of the audit team to the auditee’s senior management;
• Explain the scope and objectives of the audit;
• Provide a short summary of the methods and procedures to be used to conduct the audit;
• Establish the official communication links between the audit team and the auditee;
• Confirm that the resources and facilities needed by the audit team are available
• Fix a schedule of visits to individual plants / departments;

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 • Discuss with the auditee’s senior management the areas of concern and areas of focus
suggested by the audit team;
• Confirm the time and date for the closing meeting and any interim meetings of the audit
team and the auditee’s senior management;
• Clarify ambiguities if any, in the audit plan.
• Auditee should make a presentation on organization, structure, manufacturing processes
and the OH & S system

i) Field visit, Observations and Document check.

• Examination of Records Information should be collected through examination of

documents and records. A sample list of documents and records to be examined is given
in Annex B. Nonconformities should be noted.
• Field Visit Audit team should carry out field visit along with the concerned officials of the
auditee.
• The auditor is expected to interact with various levels of employees including the top
management to gather information on the OH & S system and its implementation.
Information collected through interviews should be verified from other sources such as
physical observation and scrutiny of records.
• All audit observations should be documented. After all activities have been audited, the
audit team should review all of their observations to determine which are to be reported
as nonconformities

j) Closing Meeting with Auditee

• At the end of the OH & S audit, prior to preparing the audit report, the audit team should
hold a meeting with the auditee’s senior management and those responsible for the
functions concerned. The main purpose of this meeting is to present audit observations
and recommendations to the senior management in such a manner as to ensure that
they clearly understand the results of the audit.
• The lead auditor should present observations and recommendations, taking into account
their perceived significance. The lead auditor should also present the non-conformities in
a summarized manner. The audit team’s conclusions regarding the OH & S system’s
effectiveness should be presented. The deliberations of the closing meeting should be
recorded. Initiating the audit:

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5. ELEMENTS OF OCCUPATIONAL HEALTH AND SAFETY
(OH & S) SYSTEMS

A-1 OH & S MANAGEMENT

a) OH & S Policy b) OH & S organizational set-up
c) Safety manual d) Standard Operating Procedures (SOP)
e) Plant modification procedure f) Work permit system
g) Contractors’ safety system h) Plant design and layout
j) Medical management of accidents k) Management of emergencies (natural / man-
made)
m) Employee selection and placement n) Safety culture
p) Statutory licenses, approvals and records q) Motivational and promotional measures for OH
&S
r) Hazard identification and job safety s) Product safety
analysis
t) Safety training u) Change management

A-2 PHYSICAL HAZARD

a) Housekeeping b) Machine and general area guarding
c) Material handling d) Electrical safeguarding
e) Safety in storage and warehousing f) Hazard assessment of new equipment
g) Hazards from radiation sources h) Control measures for specialized industrial
hazards like work at height and work in
confined space

A-3 CHEMICAL HAZARD

a) Transportation of hazardous substances b) Handling of hazardous substances
c) Storage of hazardous substances d) Spill control measures
e) Material Safety Data Sheet (MSDS) f) Gas cylinders
g) Labeling and colour coding h) Hazardous waste management

A-4 FIRE AND EXPLOSION HAZARD

a) Organizational setup for fire fighting b) Built in safety in civil design and construction
c) Built in Safety in Electric Circuits and d) Explosive substances
Equipment
e) Fire safety in handling flammable and f) Fire detection and alarm system
explosive materials
g) Passive and active fire protection system h) Fixed fire extinguishing system
j) Portable Fire Extinguishing System k) Fire fighting equipment and facilities
m) Fire drill n) Fire fighting training
p) Static electricity and lightning

13
A-5 INDUSTRIAL HYGIENE / OCCUPATIONAL HEALTH
a) Vibration, heat stress, Non-ionizing b) Work place monitoring for hazardous
radiations, ventilation, illumination and noise chemicals
c) First aid facilities and occupational health d) Periodic medical examination
centre (OHC)
e) Personal protective equipment and f) Occupational disease
emergency equipment

A-6 ACCIDENT / INCIDENT REPORTING, INVESTIGATION AND ANALYSIS

a) Accident reporting, b) Accident investigation
c) Analysis of accidents d) Implementation of recommendations
e) Reporting and investigation of near -miss
incidents

A-7 EMERGENCY PREPAREDNESS (ON-SITE / OFF SITE)

a) Site specific details b) Duties and responsibilities of key personnel
c) Identification of emergencies and accident d) Declaration and termination of emergency
scenario
e) Resources-evacuation / transport f) Communication facilities
g) Medical care h) Updating of emergency plan
j) Periodic drills / exercises k) Training of plant personnel
m) Public awareness programmes n) Mutual-aid programme
p) Emergency control center

A-8 SAFETY INSPECTION

a) Inspection programme b) Safety Related Deficiency (SRD) Report
c) Safety inspection records d) Methodology and inspection team
e) Compliance of recommendations

14
A-1. OH & S MANAGEMENT
a) OH & S Policy
b) OH & S organizational set-up
c) Safety manual
d) Standard Operating Procedures (SOP)
e) Plant modification procedure
f) Work permit system
g) Contractors’ safety system
h) Plant design and layout
i) Medical management of accidents
j) Management of emergencies (natural / man-made)
k) Employee selection and placement
l) Safety culture
m) Statutory licenses, approvals and records
n) Motivational and promotional measures for OH & S
o) Hazard identification and job safety analysis
p) Product safety
q) Safety training
r) Change management

a) OCCUPATIONAL HEALTH & SAFETY POLICY

Introduction

The Occupational Health & Safety (OHS) policy is a statement signed by the top management
declaring its commitment and intent to manage its OHS responsibilities. In publishing the Policy,
the organization is sending a clear message that it has a vision for OHS management within the
whole organization. It is the responsibility of the owner or employer to secure the health and
safety of persons working in organization. The OSH Policy plays an important role in providing
direction, taking actions, allocating resources towards achievement of policy objectives.

Legal obligations

It is the legal obligations on the management to prepare the Policy under various
statues listed below:

• The Factories Act, 1948 and the State Rules made there under;
• The Building and Other Construction Workers (Regulation of Employment and Conditions
of Service ) Central Rules,1998 and the State Rules
• The Central Electricity Authority (Safety Requirements for Construction, Operation,
Maintenance of Electrical Plants and Electric Lines) Regulations, 2011

Content of the Policy

While preparing the policy senior management and workers representatives must be involved. It
should be relevant and appropriate to the nature, scale and OHS hazards and risk associated
with the workplaces’ needs and not adopted from another workplace or copied. The content of the
Policy has been provided in the State Factories Rules which include specific requirements on
preparation, implementation and communication by an Occupier of a Factory. The requirement is
more or less same in all the State Factories Rules and same reference shall be sought. By and
large the Policy should:

15
 • includes a commitment to provide safe and healthy working conditions for the prevention
of work-related injury and ill health and is appropriate to the purpose, size and context of
the organization and to the specific nature of its OH&S risks and OH&S opportunities;
• provides a framework for setting the OH&S objectives;
• includes a commitment to fulfil legal requirements and other requirements;
• includes a commitment to eliminate hazards and reduce OH&S risks;
• includes a commitment to continual improvement of the OH&S management system;
• includes a commitment to consultation and participation of workers, and, where they
exist, workers’ representatives.

Communication of Policy

• A copy of the declared OHS Policy signed by the occupier shall be made available to the
Inspector having jurisdiction over the factory and to the Chief Inspector;
• The Policy shall be made widely known by, making copies available to all workers
including contract workers, apprentices, transport workers suppliers, displaying copies of
the policy at conspicuous places; and any other means of communication; in a language
understood by majority of workers.
• It should be made available to interested parties viz. shareholders, nearby community
and government authorities.

Revision of Policy

• The occupier shall revise the Policy as often as may be appropriate,

• The policy shall necessarily be revised whenever any expansion or modification having
implications on safety and health of persons at work is made; or
• Whenever new substance(s) or articles are introduced in the manufacturing process
having implications on health and safety of persons supposed to such substances.
• The policy shall be signed by the occupier with date

Guidance to check compliance

1) Does the organization have OHS Policy? Is it reviewed periodically and updated?
2) Who has signed the OHS policy?
3) Whether OHS Policy is prepared as per guidelines of the statutory provisions?
4) Whether it expresses a commitment to health and safety? Are obligations towards
employees are made clear?
5) Whether OHS Policy has been communicated to all the workers especially to contract
workers? If yes, what means. Is it displayed at conspicuous places, notice boards or
distributed in the form of pocket leaflet?
6) Is the Policy included in the company annual report?
7) Interview employees including and workers to find out their understanding of the OHS
policy and how they are implementing it in practice.

16
b) OHS ORGANIZATIONAL SET-UP

Introduction

Top management shall ensure that the responsibilities and authorities for relevant roles within the
OH&S management system are assigned and communicated at all levels within the organization
and maintained as documented information. Employees at each level of the organization shall
assume responsibility for those aspects of the OH&S management system over which they have
control.

Top management shall assign the responsibility and authority for ensuring that the OH&S
management system conforms to the requirements of organisation and reporting on the
performance of the OH&S management system to top management.

OHS is a business function like any other function of management such as operations,
maintenance, finance, and HR. The OHS needs to be managed as a part of day to day business
activity. Further, compliance with OHS related requirements is mandatory. Therefore,
organizational set up in the form of a formal structure with clearly defined roles, responsibilities
and authorities at various levels is an essential component of Occupational Safety & Health
Management System (OSHMS) in any organization.

Legal Obligations

The Factories Act,1948; The Building and Other Construction Workers (Regulation of
employment and conditions of service) Act,1996 and The Central Electricity Authority (Measures
relating to Safety and Electric Supply) Regulations, 2010 specify statutory requirements with
regard to organizational set up for OSH management. Some of these requirements relate to (i)
responsibilities and duties of occupier, workers, contractors, etc (ii) designating manager
responsible for compliance with statutory provisions; (iii) constitution of safety committee for
participation of workers; (iv) appointment of safety officer for advising on matters of OSH and
monitoring & reporting of OSH performance; (v) appointment of Factory Medical Officer; vi)
Setting up of fire department, etc.

As per Factories Act, 1948 the occupier is responsible for making OHS policy and ensuring its
implementation through organizational setup, appropriate processes and resources. The occupier
is also required to appoint the Manager for the purpose of ensuring compliance with the relevant
requirements.

As per The Building and Other Construction Workers (Regulation of employment and conditions
of service) Central Rules1998 the establishment employing 50 or more building workers is
required to prepare safety policy. It also requires to specify the arrangements for making the
policy effective.

The Central Electricity Authority (Measures relating to Safety and Electric Supply) Regulations
2010 the occupier is required to designate one person as Electrical Safety Officer.

Organization – responsibility and accountability

Having well written OHS policy is not enough. It should be put into practice in right spirit. For this
requires an organization. This involves establishing responsibilities and relationships which
promote a positive safety and health culture throughout the organization from top to bottom. It
must be emphasized that, it is the employers who have overall responsibility for the protection of
workers’ safety and health. Following full consultation and agreement with all employees, it is top
management’s responsibility to allocate responsibility, accountability and authority for the

17
implementation the policy. This ranges from ensuring that safety and health is a line management
responsibility which is known and accepted at all levels, to establishing effective arrangements to
identify, measure (if possible) and control work related hazards and risks and to promote health at
work. It is also require to ensure that arrangements are made for the full participation of workers
and their representatives in the successful implementation of the policy. The appropriate
resources (time, money, training etc.) have to be provided so that those workers and supervisors
given responsibility for safety and health in the organisation can carry out their duties properly.
Other organizational arrangements include:

• assisting with the formation safety committees;

• allocating the various responsibilities on occupational safety and health to designated
personnel, including identifying who will be responsible for what such as fire drills, first
aid, training and reporting investigations and recording accidents;
• ensuring that the designated people have the relevant competencies to perform their
duties on safety and health;
• ensuring that the requisite safety and health training is carried out throughout the factory
at no cost to the workers;
• making sure that all workers understand the policy and can identify who is responsible for
which areas so that any problems can be reported;
• keeping full records of inspections, accidents, ill health etc;
• obtaining from suppliers full details of products used (e.g. Safety Data Sheets on all
chemicals used);
• providing a two‐way communication system so that senior management can report safety
and health issues to the workforce and vice versa;
• ensuring that safety and health in the organisation is a dynamic, on‐going activity in the
factory and not just introduced at the time of a visit by a Labour Inspector.

Planning and implementation

Having developed the policy and made the organizational arrangements, it is now time to
implement the policy – this requires careful planning and co‐ordination to be successful. This
involves an initial inspection of organization using a checklist to identify, for example:

• how the current national regulations, standards and agreements are being applied;
• what hazards and risks to safety and health may be present in the organisation;
• any control measures that may be available and assess their effectiveness;
• how well documents and records of safety activities are kept e.g. training and inspection
records;
• the extent of emergency prevention, preparedness and response times, as for example,
in the case of a fire in the factory;
• data analysis from accident/sickness register, etc;
• the arrangements for the provision of first aid;
• what arrangements are in place or need to be introduced to ensure workers’ consultation,
co-operation and, most importantly, their active participation;
• any special arrangements required for the procurement of goods and services; and
• any special arrangements for sub-contractors, contractors on site or visitors to the
factory.

Once this initial inspection has taken place (it may take several days to audit the organisation in
detail), it is important to draw up plans, develop programmes and procedures, and establish
priorities based upon relative risks. It is also important to set goals and performance standards for
management action and establish a realistic timetable. This will help to minimize risks to safety
and health and give you a baseline against which all future standards can be measured.

18
Evaluation
It is essential to monitor safety and health performance on a regular It is up to top management to
establish procedures to monitor, measure and record safety and health performance in the
organisation. Such procedures could involve regular inspections by members of the safety
committee, seeking external audits and advice from the factory inspectorate, and analyzing data
such as sickness or accident records. Organisation that have good safety and health records
measure their performance on a regular basis against pre‐determined plans and agreed
standards and are continually “fine‐tuning” so as to improve performance.

Summary
It is important to note that the introduction of a good safety and health management system not
only improves working conditions for the workers but it also has a positive impact on the balance
sheet through increased productivity, fewer accidents and ill health, high staff morale, less staff
turnover, and a positive image to the buyers. A successful safety and health management
system is made up of:

• policy development;
• organization – responsibility and accountability;
• planning and implementation; and
• evaluation.

This requires consultation, co‐operation and commitment from all employees. Workers’
participation is seen as a vital part of the process.

Guidance to check:
1) Whether management has defined and/or specified the organizational structure for
implementation of OHS Policy and OHS management system? (Check existence of Safety
Department, Safety Committee, and Safety stewards/safety captains for particular
section/department/work area.)
2) Are responsibilities for safety at various levels clearly defined, communicated and understood
by concerned employees?
3) Are safety officers, safety committee members, safety stewards trained in related statutory
safety requirements and latest development in safety management?
4) Do the safety officer, safety committee members, safety stewards have power to point out
and initiate action to stop any unsafe work?
5) Is safety committee constituted as per statutory requirements?
6) How are the members of the Safety Committee selected? (elected/nominated)
7) How often are the meetings of the safety committee held? Are the minutes of the committee
meeting circulated among members?
8) Are the recommendations of the committee implemented?
9) Whether the management and workers play their active roles in supporting and accepting the
committee recommendations?
10) Whether architect, project engineer, designer have given due consideration to the safety and
health aspects of the building workers, at designing and planning stage of a project.
11) In building and other construction work, whether constant and adequate supervision is
provided? What specific measures have taken to prevent accidents?
12) Whether “Tool box talks” are conducting for advising workers on how to prevent injuries on
day to day basis?
13) Is safety officer carrying out safety inspections?
14) Does management provide adequate budget for OHS? How much percentage is this budget
of the total turnover of an organization?
15) How is the safety budget arrived at?
16) Is the budget provided for OSH utilized for improvements in OHS system?
17) Whats the medical management at the organization?

19
c) SAFETY MANUAL AND RULES
Safety Manual is a document detailing the various safety aspects / instructions and requirements
relating to a particular practice or application. The purpose of any Safety Manual is to identify the
hazards in the plant/ unit and have a proper management system to control the hazards and
reduce the accidents. Safety manual is prepared to communicate the hazards and safety
management system of the unit to the workers and contractors. Based on these principles, safety
manual should contain:

• Safety Policy
• Accident reporting and investigation
• Safety Work Permit requirement
• Hazards and their control measures
• General Safety Rules
• Duties and Responsibilities
• Standing Fire Order
• First Aid and Occupational Health

There are requirements under various statutes requiring the occupiers, employers to maintain
safe system of work. This system may relate to safe operation and maintenance of plant and
machinery, handling of certain type of material or substances, undertaking certain types of
hazardous activities, working at hazardous places or precautions to be taken in certain types of
work or places. Some statutes also require framing of specific safety rules where as certain
statutes require preparation of safety manual. The safety manual serves very useful purpose of
standardization and reference for following correct procedures. It is also useful for educating and
training of workers and supervisors in controlling accidents.

Safety Manual gives details about the safe work practices inside the plant. While preparation of
Safety Manual of the organization, some of the points are to be taken in consideration like
Hazards, preventive controls to minimize risk, accident prevention methods, safe operating
procedures and its records. The contents of Safety Manual shall be as per given in annexure 2.

Legal Requirements :
The appropriate sections and rules with provisions of the particular legislation, those have
requirements for Safety Manual, are listed below:

Sr. Legislation Section/sub- Provisions

No. section / Rule /
sub-rule /
Regulation
1 The Factories Section 7A (2)(c) Occupier has to ensure the provisions of
Act, 1948 information, instruction, training and supervision
necessary for ensuring health and safety of all
workers at work
Sec. 41 B The occupier of every factory involving a
hazardous process shall disclose all information
regarding dangers, to the workers employed in
the factory, the Chief Inspector, the local
authority and the general public in the vicinity.
Sec. 111 (A) Every worker shall have the right to obtain
information relating to their health and safety at
work

20
Sr. Legislation Section/sub- Provisions
No. section / Rule /
sub-rule /
Regulation
The Maharashtra Rule 73 J Safety Committee shall have the right to ask for
Factories Rules, necessary information and seek any relevant
1963 information concerning health and safety of the
workers to the occupier
Rule 73 M The occupier of every factory carrying on a
'hazardous process' shall arrange to obtain or
develop information in the form of Material
Safety Data Sheet in respect of every hazardous
substance. It shall be accessible upon request
to a worker for reference
Rule 73 N The occupier of a factory carrying on a
'Hazardous process' shall supply information to
all workers.
2 Central Regulation 4 The owner shall set up a sound and scientific
Electricity (4 c) safety management system which shall include
Authority preparing detailed safety manual complying with
Regulations the statutory requirements and manufacture’s
2011 recommendation
Regulation 5 Safety Manual shall be site specific but for
similar installation, common safety manual may
be prepared. The matters identified for
preparation of safety manual has also
mentioned in Schedule 1 & 2 of regulation.

3 The Explosives Rule 26 (3c) The safety management plan shall include the
Rules, 2008 provision of information, education and training
to the work force, contractors and visitors
regarding manufactures of explosives.
4 The Hazardous Rule 4 (6b) The occupier shall take all the steps while
and Other managing hazardous and other wastes to
Wastes provide persons working in the site with
(Management & appropriate information necessary to ensure
Transboundary their safety
Movement)
Rules, 2016
5 The Building and Section 40 Power The appropriate governments may make rules
Other of appropriate regarding the measures to be taken for safety
Construction Governments to and health of building workers. In particular the
Workers (RECS) make rules rules may provide for such matters as relating to
Act, 1986 precautions in certain work/operation/processes;
safe methods/procedures; working in certain
conditions; working with certain
equipment/machines/machinery etc.
6 The Building and The Building and Every establishment employing 50 or more
Other Other Construction building workers should frame a safety and
Construction Workers (RECS) health policy. The safety policy should contain
Workers (RECS) Central Rules (other) elements for making policy effective.
Act, 1986 1998
Rule 39 Safety
and Health Policy

21
 Sr. Legislation Section/sub- Provisions
No. section / Rule /
sub-rule /
Regulation
7 The Building and The Building and Every establishment employing 500 or more
Other Other Construction building workers should appoint a safety
Construction Workers (RECS) officer. The functions of the safety officer
Workers (RECS) Central Rules include (i) framing of safety rules and safe
Act, 1986 1998 working practices (ii) supervise and guide safety
Rule 209 Safety precautions to be followed.
Officer

Guidance to check the compliance

While checking the compliance regarding Safety Manual in line with the statutory requirement
and best safe practices, an auditor should check the following points

1) Whether safety manual has been prepared in organization?

2) Who has made the safety manual? (safety officer and/or others involvement)
3) Whether the contents of the manual are as per the company’s requirement?
4) Whether it has been made available in control room, safety department/officer and other
critical places? Are the operating procedures updated regularly as per the change in
procedure (if any)?
5) Whether it has been made in the language understood by most of the workers?
6) Whether it has been made with reference to statutes and Indian Standards?
7) Is safety manual reviewed periodically (in case of maintenance/ modification/ change in
substance)?
8) Does the safety manual adequately address all the hazards in the plant?
9) Are the employees made aware of safety rules/ instruction mentioned in the safety
manual?

22
 Annexure 1

CONTENT FOR SAFETY MANUAL PREPARATION

• Plant Safety Rules & Procedures

• Brief Description of the plant
• Safety Organization
• Salient Statutory Requirements regarding Safety & Health as per IS15793:2007
• Responsibilities (Management, Safety Officer, Supervisor, Employee, Supplier,
Contractor, Transporter etc.)
• Hazard Identification (Various Hazard Identification Techniques)
• Safety Education &Training
• Work Environment (Noise, Ventilation, Illumination)
• Occupational Health and Medical Facilities
• Emergency Management Plan
• Plant layout & Housekeeping
• Safety in Material Handling (Manual & Mechanical)
• Safety in Lifting Machines and lifting tools & tackles
• Safety in Handling, Storage & Transportation of Compressed Gas Cylinder
• Welding and cutting operation
• Compressed Air
• Electrical hazard
• Lockout & tag out
• Safe Operating Procedure
• New Equipment Review and Inspection
• Do’s & Don’ts
• Fire Prevention and Protection
• Work permit system (Hot Work, Cold Work, Work at Height, Electrical etc.)
• Portable power tool
• Working at height
• Other Safety Aspects
- Traffic Safety Management
- Office Safety
- Handling, Storage & Disposal of Hazardous waste & non-hazardous waste
• Safety in various engineering operations
• Storage of Material
• Maintenance Work
• Reference of Statutes, IS Standards, Best Safe Practice Methods for other standards,
etc.

Addition of Contents in safety manual can be made as per the safety requirement of industries
and its processes.

23
d) SAFE OPERATING PROCEDURE

Every operational activity, be it working with machines, handling chemicals etc. needs to be done
in a safe way at work place. Safety procedures help decrease the number of workplace
incidents. Many companies use an employee manual or guidebook to inform and educate
employees on safety procedures.

Operating procedures are written instructions (including procedures that are stored electronically
and printed on demand) that (i) list the steps for a given task and (ii) describe the manner in
which the steps are to be performed.

Good procedures also describe the process, associated hazards, required tools, necessary
protective equipment and controls in sufficient detail; so that operators understand the hazards,
can verify that controls are in place and can confirm that the process responds in an expected
manner. Procedures also provide instructions for start-up, for troubleshooting when the system
does not respond as expected. Procedures should specify when an emergency shutdown should
be executed and should also address special situations, such as temporary operation with a
specific equipment item out of service. Operating procedures are normally used to control
activities such as transitions between products, periodic cleaning of process equipment,
preparing equipment for certain maintenance activities, and other activities routinely performed by
operators. The operating procedures are normally formulated during the plant design and are
modified as and when necessary during the plant commissioning and operation. Operators
should have sufficient information to accomplish their task in normal, as well as emergency
situations.

Legal Requirements:

Sr. Statutes Section/sub-section / Provisions

No. rule/sub-rule
1. The Building and Preliminary Chapter I Safe operating procedures to be followed in
Other (2) building and other construction activities for
Construction the safety and health of workers and safe
Workers‘ operation of machineries and equipment.
(Regulation of
Employment and Chapter IX (Work on Proper measures should be taken to provide
Conditions of or adjacent to water) for safe transportation and vessels.
Service) Central
Rules, 1998 Chapter XI (Concrete The employer should give technical details
work) regarding use of concrete.

Chapter XIII Project Engineer shall exercise overall

(Excavation and control of the operations and be responsible
Tunnelling Works) for carrying out the activities safely.

Chapter XVII The employer shall ensure adequate

(Structural Frame and measures to be taken to guard against
Formwork) hazards arising from any temporary state of
weakness or unsuitability of a structure.

Chapter XXIII (Piling ) The employer shall ensure all practicable

measures like displaying of warning notices,
barricading the area and other similar
measures are taken to protect the area
while pile testing are carried out.

24
Sr. Statutes Section/sub-section / Provisions
No. rule/sub-rule
The Building and Rule 5 (5) The duty of very employer not to permit an
Other employee to do anything not in accordance
Construction with principles of standard safe operating
Workers‘ practices connected with building and other
(Regulation of construction work.
Employment and
Conditions of Rule 27 The procedures for Loading and Unloading
Service) Central facilities for pumps, compressors, transfer
Rules, 1998 systems, hoses, tank trucks clearly states
Continued about the material suitability and safe
precautions of various installations.
2. The Factories Section 7A (2) Provision should be made to share
Act,1948 (a),(b),(c) information, instruction, training and
supervisions as are necessary to ensure the
health and safety of all workers at work;
3. The Static and (Rule 29) Schedule II Different procedures have to be followed
Mobile Pressure (Rule 21) Schedule IV during filling, operation, maintenance, and
Vessels Rules, transferring of gases.
2016
4. The Gas cylinder (Rule 35) Schedule IV The procedures and testing shall ensure
Rules, 2016 that cylinders, which fail to meet the
requirements and intent of these rules, are
not returned into normal service.
5. The Maharashtra Rule 73 - M The occupier responsibility to develop and
State Factories disseminate information of hazardous
Rules, 1963 substances and their procedures for clean-
up of spills and leaks.
6. Central Electricity Rule 4 The owner shall prepare detailed safety
Authority (Safety manual complying with the statutory
Requirements for requirements and manufacturer’s
Construction, recommendations.
Operation and
Maintenance of The Owner shall establish a sound and
Electric plants and scientific management system to establish
Electric lines) procedures to identify hazards that could
Regulations, 2011 give rise to the potential of injury, health
impairment or death and measures to
control impact of such hazards.
7 Central Electricity Rule 3 Designated persons shall operate and carry
Authority out the work on electrical lines and
Regulations 2010 apparatus.

Guidance to check compliance:

1) Are written safe operating procedures available for all operations?
2) Whether the written safe operating procedures are displayed or made available and
explained in the local language to the workers at the work place?
3) Are safe operating procedures reviewed and updated in case of change in operating
procedure / parameter / addition / alteration?
4) Have the workers been informed of the consequences of failure to observe the Safe
operating procedures?
5) Is there any procedure to train operators on the SOP?
6) SOP shall be checked to comply the hazards and risks associated with the intended task.

25
e) PLANT MODIFICATION PROCEDURE
Incidents and accidents especially the well known major accidents like Flixborough (UK),
Serveso (Italy) and Bhopal (India) have shown that the effects of process / plant malfunction
may not only be hazardous to operators but also catastrophic to human life, environment and
property. The need for modification may arise from the physical ageing of plant systems,
structures and components or past incidents or accidents within the plant or change in regulatory
requirements, or changes in expected performance of the plant.

The timing of a plant modification must be integrated into the operational schedule of the plant.
Some modifications can stretch over several years, where parts of the modification project are
implemented during extension or expansion of the current plant. Some minor modifications may
be implemented during plant operation, but such cases should be scrutinized even more
carefully, because they may increase the likelihood for disturbances. In spite of careful planning
of plant modifications, changes to the plans are often required. Good industry practice requires
that process and plant modifications should not be undertaken without having undertaken a
safety, engineering and technical review.

Process or Plant modification is an integral part of Occupational Health and Safety Management.
An organization’s OH&S management system can translate its intentions to prevent incidents into
a systematic and ongoing set of change in processes and can reinforce the organization’s
commitment to proactively improving its OH&S performance. One of the most infamous process
industry accidents of the 20th Century, the Flixborough disaster, that was caused by an
insufficiently analysed modification to the existing plant . Most companies usually adopt internally
developed plant modification procedures that have been developed through,(i) Corporate history
and experience;(ii) Good industry practice; (iii)Input from Safety, Health and Environmental
department; (iv)Input from Operations department;(v)Input from Technical department; (vi)Input
from engineering department.

Legal Requirements:

Sr. Statute Section/sub- Provisions

No. section /
rule/sub-rule
1 The Factories Sec 7A (2) The provision, maintenance or monitoring of such
Act, 1948 (e) working environment in the factory for the workers that
is safe, without risks to health and providing information
to workers which are necessary to ensure health and
safety of all workers at work.
The manufacturer should ensure, so far as is
Sec 7B (1) reasonably practicable, that the article is so
designed and constructed as to be safe and without
risks to the health of the workers when properly used.
2. Model Rules Rule 4 Permission in writing should be obtained from
under The the State Government or the Chief Inspector in case of
Factories Act, plant modification.
1948.
3. The Rule 3 An application for obtaining previous permission for
Maharashtra factory extension shall be made to the CIF as made in
Factories Rules. Form I.
1963 Rule 73 (L) The OH&S Policy should cover the modification /
expansion of the plant.

26
Sr. Statute Section/sub- Provisions
No. section /
rule/sub-rule
4. Central Electricity Rule 4 The Owner shall establish a sound and scientific
Authority management system to establish procedures to
Regulations, 2011 identify hazards that could give rise to the
(Construction, potential of injury, health impairment or death and
Operation and measures to control impact of such hazards.
Maintenance of
electric plants &
electrical lines)
5. The Petroleum Rule 162 The design and layout approval of facilities /
Rules, 2002 process units in new crude oil refineries shall be
as approved by Chief Controller of Explosives.
6. The Static Mobile Rule 33 A certificate of safety in the proforma prescribed
Pressure Vessels by the Chief Controller and signed by a
(Unfired) Rules competent person shall be furnished to the
2016 licensing authority before any vessel is used for
the storage of any compressed gas or whenever
any addition or alteration to the installations or
foundations for the vessel is carried out.
6 The Manufacture, Rule 4 , The occupier who has control of industrial activity
Storage and shall provide evidence that he has identified and
Import of taken adequate steps to prevent major accident
Hazardous hazards (release of toxic
Chemicals, 1989 chemicals/explosion/fire).
Rule 11 All the plant modifications should be taken into
account in the Safety Report.

Guidance to check compliance:

During the Audit of a plant/site, as an Internal Auditor the following points needs to be checked for
Process / Plant Modification:

1) Whether there is a system of change management and written procedure for effecting
any change in the existing plant, equipment or process?
2) Whether safety aspects are also the part of plant modification procedure?
3) Whether the P&I diagrams and other related documents are updated accordingly?
4) Whether the system of change of management is documented and information is
shared?
5) Whether there is a system of training of employees in case of change in the existing
plant/ equipment or process?

f) WORK PERMIT SYSTEM

Introduction :

The standard operating procedures, safety operating procedure, work instructions are made for
day to day routine works. However, there may be requirement of non- routine jobs involving
hazards and risks such as confined space entry, flammable or explosive situations, exposure to
harmful substances or high voltage electrical equipment, and the transfer of hazardous work from
one work shift to the next. Work permit system is designed for such jobs/activities. The objective
of the Work Permit System is to exercise control over the maintenance, repair and construction
activities by assigning responsibilities, ensuring clear communication between interested
functionaries and safety considerations to the job, its hazards & the precautions to be taken.

27
Work Permit System is an important element of safety management system and implementation
of this in true spirit shall help in ensuring a safe working environment, thereby reducing possibility
of injury to personnel, protect property, avoid fire, explosion & adverse effect on environment.

Workers engaged in maintenance work may be at risk if the machinery they are working on, starts
unexpectedly. Such machinery and equipment needs to be isolated by blanking, blinding, or a
power lockout system.

Background :
A work permit is a written form used to authorize jobs that expose workers to serious hazards. It
identifies the work to be done, the hazards involved, and the necessary preparation and
precautions for the job. The permit is an agreement between the issuer and the receiver that
documents the conditions, preparations, precautions, and limitations that need to be clearly
understood before work begins. The permit records the steps to be taken to prepare the
equipment, building, or area for the work, and the safety precautions, safety equipment, or
specific procedures that must be followed to enable the worker(s) to safely complete the work.

Under the Factories Act, 1948, the occupier of the factory should ensure health, safety and
welfare of all workers while they are at work in the factory and also maintain a safe system of
work.

Legal requirements :

Sr. Statute Section/sub-section / Provisions

No. rule/sub-rule
1. The Factories Sec 7 A : General provision and maintenance of plant and
Act, 1948 Duties of the occupier systems of work in the factory that are safe
and without risks to health;
2. The Rule 73-C : Safety Safety measures in factories where
Maharashtra measures in factories equipment or pipeline containing
Factories Rules, where equipment or inflammable materials are operated : The
1963 pipeline containing system of work permit shall be introduced.
inflammable materials
are operated Fragile Roofs – Provision of crawling
Rule 73-F : Fragile Boards etc. lays down the issue of work
Roofs, Provision of permit each time when a worker is
Crawling Boards etc.
required to work on the fragile roof.
3. The Petroleum Rule 98 (i) : Repair Maintenance or repair works shall be
rules 2002 and maintenance of carried out by issuing a written permit
pipeline. specifying therein the precautions to be
observed and the procedure to be followed
for carrying out the work.
Permits to carry out maintenance and
repair work. – (1) No maintenance or
Rule 171 : Permits to repair work and no entry into confined
carry out maintenance spaces including a closed drain or
and repair work. manhole shall be permitted except under
and in accordance with the conditions of a
written permit as per OISD standard 105
issued by a competent person authorized
by the occupier of the refinery.

28
 Sr. Statute Section/sub-section / Provisions
No. rule/sub-rule
4 Central Rule – 29. Precautions No electrical installation work, including
Electricity to be adopted by additions, alterations, repairs and
Authority consumers, owners, adjustments to existing installations,
Regulations occupiers, electrical except such replacement of lamps; fans,
2010 contractors, electrical fuses, switches, domestic appliances of
workmen and suppliers: voltage not exceeding 250V and fittings as
in no way alters its capacity or character,
shall be carried out upon the premises of
or on behalf of any consumer, supplier,
owner or occupier for the purpose of
supply to such consumer, supplier, owner
or occupier except by an electrical
contractor licensed in this behalf by the
State Government and under the direct
supervision of a person holding a
certificate of competency and by a person
holding a permit issued or recognised by
the State Government.
5 Central Rule 3 : Designated Designated persons shall operate and
Electricity person (s) to operate carry out the work on electrical lines and
Authority and carry out the work apparatus.
Regulations
on electrical lines &
2010
apparatus

Guidance for Check Compliance :

1) What are the different type of work permits exist in the factory ? Does the work permit is
available for all non-routine activities involving hazards/risk.
2) Are the keys kept for individual locks which are used for electrical lock outs with the
supervisor concerned ?
3) Are the necessary forms detailing required safety precautions prepared and used for
each type of work-permit including LOTO system?
4) Is the responsibility assigned to authorized person for issuing of safety work permit?
5) Is the copy of safe work permit sent to safety officer before execution of the job?
6) Is validity period (Permit Closing element) specified in the safety work permit?
7) Are the records of safety work permit available & maintained in proper order?
8) Whether safety officer inspects for proper implementation of permit during execution
9) Whether is a written procedure for work permit and its implementation is available?

g) CONTRACTOR SAFETY SYSTEMS

In various sectors of the economy there is a growing trend for outsourcing of certain non-core as
well as not-so-core activities of the business due to variety of factors. These activities are carried
out many times outside the premises of the outsourcing organization. However in some cases
outsourced activities are carried out by the contractors within the premises of the owner. In such
cases the owner or the occupier becomes liable for ensuring protection of all workers and their
safety health and welfare on site.

Suppliers of raw material, parts, equipment and providers of other services are also important
part of the complete value chain of the business. The sustainability of supply chain is very critical
for business. There are instances where the accidents at vendor of the critical parts have
completely paralyzed the production of manufacturer. In many cases the noncompliance with
safety provisions on the part of the construction contractors has delayed projects of the principal

29
clients. Therefore it is necessary for the occupiers to select vendors and contractors not only on
the basis of cost competitiveness but safety and health parameters also.
The Contract Labour (Regulation and Abolition) Act, 1970 aims to prevent exploitation of contract
labour and also introduce better conditions of work. The Act applies to the Principal Employer of
an Establishment and the Contractor where in 20 or more workmen are employed or were
employed even for one day during preceding 12 months as Contract Labour.

The Contract labour & workmen are defined under Sec.2 of the Contract Labour (Regulation and
Abolition) Act, 1970. It states that "workman" means any person employed in or in connection
with the work of any establishment to do any skilled, semiskilled or un-skilled manual,
supervisory, or clerical work for hire or reward, whether the terms of employment be express or
implied. The worker shall be deemed to be employed as "contract labour" in or in connection with
the work of an establishment when he is hired in or in connection with such work by or through a
contractor, with or without the knowledge of the principal employer.”

Legal Requirements :

Sr. Statute Section/sub- Provisions

No. section / rule /
sub-rule
1 The Factories Sec. 7A (1) Every occupier should ensure the health, safety and
Act, 1948 welfare of all workers while they are at work in the
factory (including contract worker).
Sec. 41B All information regarding dangers, including health
Compulsory hazards and the measures to overcome such
disclosure of hazards arising from the exposure to or handling of
information by the materials or substances in the manufacture,
the occupier transportation, storage and other processes, to the
workers employed in the factory ( including contract
worker)
Sec. 41C Specific responsibility of the occupier in relation to
hazardous processes is to provide for medical
examination of every worker including contract
worker.
Sec. 41G Workers' participation in safety management by
deployment of equal number of representatives of
workers including contract worker and management
in safety committee.

1. The Factories Sec. 41H Right of workers including contract worker to warn
Act, 1948 about imminent danger to their lives or health due to
continued any accident, they may bring the same to the notice
of the occupier, agent, manager or through their
representatives in the Safety Committee and
simultaneously bring the same to the notice of the
Inspector.
Sec. 111A (i) obtain from the occupier, information relating to
Right of workers workers' health and safety at work, (ii) get trained
(including within the factory wherever possible or, to get
contract worker, himself sponsored by the occupier for getting trained
etc) at a training centre or institute on health and safety
work, (iii) represent to the Inspector directly or
through his representative in the matter of
inadequate provision for protection of his health or
safety in the factory.

30
Sr. Statute Section/sub- Provisions
No. section / rule /
sub-rule
2. The Maharashtra Rule 73-L(5 c) The Occupier should fix the responsibility of the
Factories Rules. contractor, sub-contractors, transporters and other
1963 agencies entering the premises to compliance the
provision related to safety policy.
Rule 73-L(7a) The Occupier should make Policy available to all
workers including contract workers, apprentices,
transport, workers, suppliers, etc.
Rule 73-L(7a) The Occupier should make Publication of health and
safety performance of the factory including contract
worker in Annual Report.
Rule 73-L(5g) The Occupier should make Arrangements for
informing, educating, training and retraining to
contract worker wherever required.
Rule 73-M & The Occupier should make copies of MSDSs made
73-N available to all workers including contract worker.
Rule 73-N(k) The Occupier should make Fixing role &
responsibility of workers including contract workers
in the emergency plan
Rule 73-N(3) The booklets, leaflets and the cautionary notices
displayed in the factory in the language understood
by the majority of the workers including contract
workers, and also explained to them by training by
the occupier.
Rule 73-N(g) Information to worker about Personal Protective
Equipment required to be used by workers including
contract worker employed in 'hazardous process 'or
dangerous operation by the Occupier.
Rule 73-N(d) Information to worker including contract worker
about physical and health hazards arising out of the
exposure to or handling of substances by the
Occupier.
Rule 73-V(1) Worker including contract worker should undergone
pre & periodical medical examination.
3. Factory Act,1948 Sect. 45 1 first aid box: per 150 employees.
The Maharashtra Rule 76 The first aid boxes or cupboards marked with a
Factories Rules. redcross on a white background and available in
1963 adequate quantity.
4. The Maharashtra Rule 8 Inspection of work site where workers including
Safety Officer contract workers are working.
Rules,1982
5. The Building and Sec. 36 Employer should provide First aid facilities to all
other places where building or other construction work is
Construction carried on.
Workers‘ Sec. 38 The employer should constitute a Safety Committee
(Regulation of consisting representatives of the employer and the
Employment building worker where more than 500 building
and Conditions worker employed.
of Service) Act, Sec. 44 An employer shall be responsible for providing
1996 constant and adequate supervision of any building
or other construction work relating to safety and for
taking all practical steps necessary to prevent
accidents.

31
Sr. Statute Section/sub Provisions
No. -section /
rule / sub-
rule
6. The Sec .2 The Act is applicable to non-seasonal factories employing
Employees’ 10 or more persons. The existing wage limit for coverage
State under the Act is Rs. 21,000/- per month (
Insurance w.e.f.01/01/2017).
Act,1948 Sec.38 All the employees in the factories or establishments to
which the Act applies shall be insured in a manner
provided by the Act.
7 The Central Clause 4 Provision relating to responsibility of owner:
Electricity 1. The owner shall make safety an integral part of
Authority work processes to ensure safety for employees including
(Safety employees of contractor, sub-contractor as well as visitors.
Requirements 2. The owner shall set up a sound and scientific safety
for management system which shall include:
Construction, o formulation of a written statement of policy in respect of
Operation and safety and health of employees
Maintenance o define and documentation responsibility for all levels of
of Electrical functionaries to carry out safety related activities
Plants and including responsibility of the contractors
Electric Lines) o Preparing detailed safety manual complying with the
Regulations, statutory requirements and manufactures
2011 recommendations
o establishing procedure to identify hazards that could
give rise to the potential of injury, health impairment or
death and measures to control impact of such hazards
o providing adequate human, physical and financial
resources to implement the safety management system
o providing safe working environment and evolving
framework for OSH
o providing and maintaining medical facilities
o providing adequate training to all employees to keep
them aware of safety related issues
o establishing system for accident reporting, analysis,
investigation and implementation of recommendations
o establishing system for proper communication,
documentation and record management in relation to
OSH
o formulating emergency management plan
o establishing methodology for internal and external audit
of safety management system
o establishing system for periodic monitoring and review
of the safety by the management
(n) overseeing the safety performance of contractor
Clause 5 Preparation of Safety Manual
Clause 6 Details of recruitment of Safety Officer by Owner, duty of
Safety Officer &formation of Safety Committee by Owner
Clause 7 Safety provisions relating to Contractors
Clause 9 Emergency Management Plan
Clause 10 Medical facilities to be provided by Owner
Clause 11 Safety training & awareness by Owner

32
Guidance to check compliance
1) Whether Safety clause included in contract document containing responsibility of HSE?
Documents to be checked :Contract document containing safety clause
Field visit: interaction with worker about responsibility

2) Whether copies Health and Safety Policy made available in the language understood by the
majority of the workers?
Documents to be checked :Health and Safety Policy
Field visit: Display, distribution, discussion in meeting & training, interaction with worker

3) Whether a resume on health and safety performance of the factory containing contract
employees published in Annual Report?
Documents to be checked :Annual Report

4) Arrangements for informing, educating and training and retraining to contract workers
wherever required.
Documents to be checked : Internal & external HSE training records
Field visit: interaction with worker

5) Whether copies of MSDSs made available to all workers including contract workers?
Documents to be checked : MSDS as per chemical handled
Field visit: Availability at field office and display of extract of MSDS

6) Whether role of workers vis-a-vis the emergency plan of the factory, in particular the
evacuation procedures made available to all workers including contract workers?
Documents to be checked : Emergency plan
Field visit: Availability at field office and display of assembly point

7) Whether The booklets, leaflets and the cautionary notices displayed in the factory in the
language understood by the majority of the workers including contract workers, and also
explained to them by training
Documents to be checked : booklets, leaflets and the cautionary notices about hazards
Field visit: Availability at field office & training details

8) Whether worker including contract workers informed about Personal Protective Equipment
required to be used by workers employed in 'hazardous process' or dangerous operation;
Documents to be checked : Training records about PPE
Field visit: Availability at field office

9) Whether worker including contract workers informed about physical and health hazards
arising out of the exposure to or handling of substances
Documents to be checked : Training records about PPE
Field visit: Display of physical and health hazards

10) Whether worker including contract workers undergone pre & periodical medical examination
Documents to be checked : Health record of worker

11) Whether the first aid boxes or cupboards marked with a red cross on a white background
and available in adequate quantity (1 first aid box: per 150 employees) and display of first
aider list
Documents to be checked : list of First aid box and first aider
Field visit: availability of First aid box

12) Whether worker including contract workers participated in safety committee

Documents to be checked : constitution order, Agenda & Minute of safety committee

33
 Field visit: Implementation of safety committee suggestion at plant

13) Whether work site supervised & inspection by Contractor supervisor or company safety
officer
Documents to be checked : Inspection record

14) Whether Worker including contract worker insured under the ESI Act,1948
Documents to be checked : ESIC record

15) Whether Owner evaluated of contractor safety performance

Documents to be checked : Evaluation of contractor safety performance

16) Whether Contractor submitting accident details on periodic basis to owner

Documents to be checked : Accidents records of Contractor

h) PLANT LAY OUT AND DESIGN

Planning, Design and Layout:

Plant or factory premises vary in size and manpower employment. There are giant petrochemical
and fertilizer plants on one end and small factory in a single room on the other end. Under the
Factories Act, more welfare facilities are required from bigger factories depending on number of
workers arid male-female employment. Stringent safety provisions are applicable to chemical
plants and major hazard (MAH) installations. Before starting factory permission from local
authority and other related government departments is also required. Where pollution is possible,
permission from State/Central Environment Department and Pollution Control Board is also
necessary.

Definition of a 'factory' is given under the Factories Act 1948 and it is the main Act (together with
State Factories Rules) applicable to the layout, design, construction and working of a factory.

A plant should be located after considering siting criteria and be constructed by considering
statutory requirements.

Travel Chart:

Travel chart is a simple and useful, method to analyses deficiencies in the layout of a factory and
in planning a good layout.

The deficiencies in a poor layout are:

1. Congestion on the shop floor.

2. Excessive waiting time of machines and materials.
3. Poor space utilization.
4. Absence of easy access to machines, tools and materials.
5. Excessive handling of materials.
6. Irregular flow of process and materials.
7. Back tracking and zigzag movements.
8. Absence of necessary aisles and routes.
9. Unbalanced activities resulting in poor utilization of men, machines and materials, and
10. Inflexibility of layout allowing no scope for expansion or alteration needed with time.

34
The travel chart technique detects above deficiencies to improve the plant layout and suggests
follow-up action necessary. It is a mathematical approach which measures quantitatively the
movements of materials and in-process work. The purposes of such measure are:

1. To assess the quantities and the nature of materials flowing from area to area and from
machine to machine.
2. To reduce movements to minimum. .
3. To relocate contributing and user areas on the basis of percentage contribution, and
4. To arrange operations in each section for self-sufficiency.

Unit movement is noted by multiplying distance and frequency. From the data of number of
components, their weights, distances travelled, frequency of trips etc., templates for the machines
and equipment and other details, the travel charts are prepared.

The study of travel chart suggests improvements in materials handling methods and machines in
operation, types of containers, aisles, travel routes etc.

General Principals of Planning and Design:

They are as under:

1. Siting criteria.
2. Good transportation facilities.
3. Safe handling and storage facilities.
4. Personal and Welfare facilities.
5. Engineering, utility and safety facilities.
6. Walkway, stairs, .platform, ramps etc.
7. Good lighting and ventilation.
8. Elevators and lifting machines.
9. Boilers and pressure vessels.
10. Fixed and portable machinery and equipment.
11. Electrical installation.
12. Fire protection.
13. Other provisions for health and safety, viz. effluent disposal, water, first-aid,
emergency power, equipment and emergency planning etc.

General principles of any workplace design:

They are as under

1. Plan the ideal, then the practical.

2. Plan the whole, then the detail.
3. Plan the work process and equipment around the system requirements.
4. Plan the workplace layout around the process and equipment.
5. Plan the final enclosure around the workplace layout
6. Use trials to evaluate alternatives and to check the final design.

Design aspects should include proper buildings and roads layout, storage & process layouts,
proper heights, lights, depths, spacing and dimensions considering ergonomic requirements,
loads and climatic factors and specific process hazards.

35
Some notable points for good planning and design are:
Sound foundations, stable construction and loading, non-congested machinery layout (safety
distance 1 m), no overcrowding (otherwise claustrophobia is possible), minimum floor area per
worker (1 to 2 m2), minimum alley width, safe roadways, walkways, yards etc., prescribed
ventilation area (15% of floor area), sufficient natural and mechanical ventilation, humidity control,
sufficient natural and artificial lighting, open plant for chemical processes, dykes, boundaries and
blast walls (to' withstand 7 kgf/cm2 force), safe layout and erection of chemical vessels and
equipment, ergonomic considerations, segregation of noisy and dusty processes, fencing and
covering of water-ways, reservoirs, ditches, floor openings, gutters etc., separate entrance and
exit gates, parking plots, safe layout of control room, provision of fire prevention and protection
systems, safe storage of flammable, explosive and toxic materials, waste disposal arrangements
for solid, liquid and gaseous wastes, effluent treatment plant (ETP), scrubbers, incinerators, flare
or exhaust as per requirement, safe discharge of smoke, fumes, dusts, gases etc., proper layout
of utilities (water, power, steam, air, oil, inert gas etc.) and ancillary services, safe transportation
and security arrangement, hazards identification and removal, safe pipe work, follow-up of
standards, codes and reliability criteria, limitation of inventory, fail-safe design, built-in safety
devices etc.

Thus, points of plant layout and design are numerous and selection of particular point depends on
process, technical and safety requirements.

General Principals of Plant Layout

1. Size, shape, location, construction, buildings layout and other facilities should permit
efficient utilization of machines, processes and materials. Need and possibility of one
storey or multi-storey structure should be decided.
2. Layout should be properly planned to allow smooth flow and efficient use of men, materials,
methods, processes, time cycle etc. and should allow good and .safe working conditions to
prevent any accident or risk.
3. Enough work space (2 m2 per 'person) should be provided for workers to work without
restriction.
4. Proper roads, walkways, tracks, alleys, catwalks etc. should be provided for free passage
of men and materials to avoid delay and obstruction.
5. Sufficient doors, windows, ventilators and open space must be provided for good ventilation
and lighting.
6. Installation of machinery, floors, stairs, lifting machines, electric wiring etc. must be done to
ensure safety. Allow at least I m space around each machine.
7. Keep the handling of materials to the minimum. Use mechanical means to reduce manual
strain.
8. Provide safe means of access to all work places.
9. Provide safe transport facilities for men and materials.
10. Provide adequate emergency exits.
11. Purchase and arrange in orderly manner machines and equipment with built-in safety.
12. Isolate high noise, vibration, fire, explosion and toxic hazards. Design a work bench, table,
booth, roof, ladder, platform, sheet, support etc. with safety standards to avoid such
hazards.
13. Allow space for future expansion.
14. Provide repair and maintenance workshop, welfare facilities and education and training
facilities.
15. Use appropriate colours, notices, signs, labels, posters etc. for safety.
16. Provide easy locations of fire alarms, fire fighting equipment, personal protective
equipment, emergency assembly points, medical centre, safety office etc.
17. Provide and maintain good housekeeping.

36
Other factors of plant layout and design from safety point of view are:
1. Safe design and construction using safety standards and good engineering practices.
2. Statutory requirements for plant layout and design.
3. Containment of leakage and accidents.
4. Segregation of different risks.
5. Safe storage, process, utilities and waste disposal design.
6. Safe control room location & design.
7. Emergency control devices.
8. Fire fighting and gas leak control facilities. Ample water storage.
9. Auto controls, alarms, trips, interlocks and necessary safety devices.
10. Railings and guarding at chances of fall, cross over and on moving machinery.
11. Roads of sufficient width and signs.
12. Safe loading, unloading, transport and piping facilities.
13. Security round the clock.
14. Wind direction and speed indicator with recorder to know wind direction and speed.
15. First aid centre and ambulance van.
The site layout is prepared first, then the plot and equipment layouts. Site is subdivided into
blocks or plots. Equipment layout includes P & I diagrams and fire equipment layout. This is as
under –

Plant Layout

Site Layout Plot Layout Equipment Layout

Preliminary layout General considerations Hazards General considerations

Main layout Fire fighting materials
Segregation Escape P & I diagram
Separation distances Construction Fire equipment layout
Fire containment Operation
Services/Utilities Maintenance
Effluents
Transport of materials
Emergencies
Security

37
Legal Requirements :

Sr. Statute Section/sub-section Provisions

No. / rule / sub-rule

1. The Sec. 2 cb : General Provide and ensure risk free environment to the
Factories Duties of the workers at workplace.
Act, 1948 Occupier
Sec. 7a 2(a): Provision and maintenance of plant and
General duties of the systems of work in the factory that are safe and
occupier without risks to health.
Sec. 13 b (i): Walls and roofs shall be of such material and
Ventilation and so designed that such temperature shall not be
temperature exceeded but kept as low as practicable.
Sec. 37-2: Explosive Where in any factory the plant or machinery used
or inflammable dust, in a process such as is referred to in sub-section
gas, etc (1) is not so constructed as to withstand the
probable pressure which such an explosion as
aforesaid would produce, all practicable
measures shall be taken to restrict the spread
and effects of the explosion by the provision in
the plant or machinery of chokes, baffles, vents
or other effective appliances.
Sec. 39-2: Power to to furnish such drawings, specifications and
require specifications other particulars as may be necessary to
of defective parts or determine whether such building, ways, machinery
tests or plant can be used with safety
of stability
Sec. 40: Safety of If it appears to the Inspector that any building or
buildings and part of a building or any part of the ways,
machinery machinery or plant in a factory is in such a
condition that it is dangerous to human life or
safety, he may serve on 1*[the occupier or
manager or both] of the factory an order in writing
specifying the measures which in his opinion
should be adopted, and requiring them to be
carried out before a specified date and until it has
been properly repaired or altered.
2. The Schedule 8 2. Description of the industrial activity
Manufacture 6. Description of safety -relevant units, among
Storage and others.
Import of
Hazardous
Chemicals
Rules
1989/2000

Guidance for compliance:

Aspect to be Reviewed

1) Are the approved layout of the plant by chief inspector available and is same as that of
existing layout.

38
 2) Whether hazardous operations in the plant are separated from each other (as per the risk
assessment)?
3) Are all the equipment provided with adequate space for working, maintenance etc.
4) Are the storage tanks provided with enough space/ clearance between them?
5) Whether the plant layout has taken care of the movement of firefighting equipment and
emergency exits?
6) Whether equipment sustainability is considered at design stage?

Documents to be checked:

▪ Verify the documents of Plant Design and layout

▪ Any modification procedure.
▪ Documents related to changes carried out and letters sent to authorities for the changes.

i) MEDICAL MANAGEMENT OF ACCIDENTS

Introduction:

As per the Factories Act the employer has a legal duty to provide adequate
facilities for the safety, health and welfare of employees. There are specific
provisions in the Act with respect to the requirement of first-aid appliances and
occupational health center.

Background:

Ambulance room shall be used only for the purpose of first-aid treatment and rest.

First-aid is the immediate care given to the victim of an accident or sudden illness before
the arrival of a qualified expert. The purpose of First-aid is to preserve life, assist
recovery, prevent aggravation and minimize complications at a later date with the help of
such material as may be available.

Legal Requirements:

Sr. Statute/Act Section/Rule/sub- Provisions

No. rule
1 The Factories Act Sec.45: (First Aid 1. There shall, in every factory, be provided
1948 Appliances) and maintained so as to be readily
accessible during all working hours first-aid
boxes or cupboards equipped with the
prescribed contents, and the number of such
boxes or cupboards to be provided and
maintained shall not be less than one for
every one hundred and fifty workers
ordinarily employed at any one time in the
factory.

2. Nothing except the prescribed contents shall

be kept in a first-aid box or cupboard.

39
 3. Each first-aid box or cupboard shall be kept
in the charge of a separate responsible
person, who holds a certificate in first-aid
treatment recognized by the State
Government and who shall always be
readily available during the working hours of
the factory.

4. In every factory wherein more than five

hundred workers are ordinarily employed
there shall be provided and maintained an
ambulance room of the prescribed size,
containing the prescribed equipment and in
the charge of such medical and nursing staff
as may be prescribed and those facilities
shall always be made readily available
during the working hours of the factory.

2 The Model Section 1. Every ambulance room shall be under the

Rules under 87:.Ambulance charge of at least one whole-time qualified
the Factories Room. medical practitioner (hereinafter referred to
as medical officer) assisted by at least one
Act, 1948
qualified nurse or dresser-cum-compounder
and one nursing attendant in each shift.

Provided that where a factory works in more

Rule prescribed than one shift, the Chief Inspector, if he is
satisfied that on account of the size of the
under section 112
factory, nature of hazards or frequency of
read with sub section accidents, it is not necessary to employ a whole
(4) of section 45 time medical officer for each shift separately,
may, with the previous approval of the State
Government, grant exemption from the provision
of this sub-rule and permit employment of only
one whole-time medical officer for more than
one or all shifts, subject to the conditions that –
(a) There shall be no relation in respect of
nursing staff; and
(b) The medical officer is readily available on
call during the working hours of the factory.
4) The ambulance room shall be separate from
the rest of the factory and shall be used only for
the purpose of first-aid treatment and rest. It
shall have a floor area of at least 24 square
metres and smooth, hard and impervious walls
and floors, and shall be adequately ventilated
and lighted by both natural and artificial means.
There shall be attached to it at least one latrine
and urinal of sanitary type.

40
Sr. Statute/Act Section/Rule/sub- Provisions
No. rule

3 The CEA Regulation 27 - First-aid boxes or cupboards conspicuously

Regulation, Provisions applicable marked and equipped with such contents as the
2010 to protective State Government may specify, shall be
equipment- provided and maintained in every generating
station, enclosed sub-station, enclosed
switching station and in vehicles used for
maintenance of lines so as to be readily
accessible during all working hours and all such
boxes and cupboards shall, except, in the case
of unattended sub-stations and switching
stations, be kept in charge of responsible
persons' who are trained in first-aid treatment
and one of such persons shall be available
during working hours.
4 The BOCW Section 36 First Aid- Every employer shall provide in all the
Act, 1996 places where building or other construction work
is carried on such first aid facilities as may be
prescribed

5 The Building Rule Number 226 The employer shall ensure at a construction site
and Other :Ambulance room of a building or other construction work that,—
Construction
Workers’ a. in case five hundred or less workers are
employed at such construction site there is
(Regulation of
an ambulance room at such construction
Employment site or an arrangement with a nearby
and Conditions hospital for providing an ambulance room
of Service) and such ambulance room is in the charge
Central Rules, of a qualified nurse and the service of such
1998 ambulance room is available to building
worker employed at such construction site at
every time when he is at work;
b. in case more than five hundred building
workers are employed at such construction
site there is an ambulance room with
effective communication system and such
ambulance room is in the charge of a
qualified nurse and the service of such
ambulance room is available to a building
worker employed at such construction site at
every time when he is at work, and such
ambulance room is in overall charge of a
construction medical officer;
c. an ambulance room referred to in clause (a)
or clause (b) is equipped with the articles
specified in Schedule IV, annexed to these
rules;
d. record of all cases of accidents and
sickness treated at the ambulance room
referred to in clause (a) or clause (b) is
maintained and produced to the inspector
having jurisdiction on demand.

41
Sr. Statute/Act Section/Rule/sub- Provisions
No. rule

5 The Building Rule Number The employer shall ensure at a construction site
and Other 231. First-aid boxes of a building or other construction work that—
Construction
Workers’ a. sufficient number of first-aid boxes or
(Regulation of cupboards are provided and maintained for
providing first-aid to the building workers;
Employment
b. every first-aid box or cupboard is distinctly
and Conditions
marked “First-Aid” and is equipped with the
of Service) articles specified in Schedule III annexed lo
Central Rules, these rules;
1998 c. nothing except appliances or requisites for
first-aid is kept in a first-aid box or cupboard
and such box or cupboard is so kept as to
protect it against contamination by dust or
other foreign matter and against penetration
of moisture and such box or cupboard is
kept in the charge of a person trained in
first-aid and is always readily available
during working hours.
6 Part 7 10 . Safety in 10.15.2 Depending on the scope and nature of
Construction Demolition of the work, a person, qualified in first-aid shall be
Management, Buildings available at work site to render and direct first-
aid to casualties. He shall maintain a list of
Practices and
individuals qualified to serve in first-aid work.
Safety Enough first-aid kit, including a stretcher and a
10.15 First-Aid cot with accessories shall be provided at site. A
telephone may be provided to first-aid assistant
with
telephone numbers of the hospitals
prominently displayed.
14. Habitat and The project authorities should, depending on
Other Welfare size of the project, number of workers
requirements for employed, location of the project, etc, provide
First aid and medical facilities for the workers.
Construction
14.8 First Aid and Medical Facilities
Workers
1. First aid centre shall be established in the
habitat with the required medical facilities.
Trained first aiders/ male nurse/doctor shall
be employed in the First Aid Centre
depending on the number of workers
accommodated. Sufficient number of first-
aid boxes shall be provided and maintained
and the box shall be distinctly marked .First-
aid. and shall be equipped with specified
articles.
2. An emergency vehicle shall be provided or
an arrangement shall be made with an
identified nearby hospital for providing
ambulance for transportation of serious
cases of accident or sickness of workers to
the hospital promptly. Such vehicle should

42
 be maintained in good repair and should be
equipped with standard facilities. The
contact details, including phone numbers of
such nearby hospitals shall be readily
available to different managers/
supervisors/first-aid facility in- charge. These
phone numbers shall also be suitably
displayed at site.
3. Details of all the first-aid/medical treatments
shall be logged in the first aid register.
4. Health check-up of all the workers shall be
done at least once in six months by a
registered medical practitioner.
5. The medical facilities shall meet the
provisions of Building and other
Construction Workers (Regulation of
Employment and Conditions of Service)Act,
1996 and rules framed thereunder.
7 Part 8 Building Annex B Regulation 27, Provisions applicable to
Services . protective Equipment
Section 2
Electrical And First-aid boxes or cupboards conspicuously
Extracts from marked and equipped with such contents as the
Allied
Central Electricity State Government may specify, shall be
Installations provided and maintained in every generating
Authority (Measures
Relating to Safety station, enclosed substation, enclosed
switching station and in vehicles used for
and Electric Supply)
maintenance of lines so as to be readily
Regulation, 2010 accessible during all working hours and all such
Further Amended In boxes and cupboards shall, except in the case
2015 of unattended substations and switching
stations, be kept in charge of responsible
persons who are trained in first-aid treatment
and one of such persons shall be available
during working hours.
9.6 Cold Room Safety

The cold temperatures inside a low temperature

cold room can cause increase in blood viscosity
and risk to life unless proper precautions are
taken. First-aid kit to be provided.
8 Part 11: 12. Constructional Health and hygiene infrastructure is needed for
Approach To Practices the construction site as well and the labour
Sustainability infrastructure, especially if labour camps are off
12.3.7 Setting Up Of site. In addition to the construction project
Health And Hygiene specific injury and emergency treatment
facilities, facilities shall be provided for
Infrastructure
conducting periodic health check-ups for the
workers so that the effects of construction
activities on the health are monitored. Medical
facilities shall be established with suitable
expert physicians and paramedics, availability of
appropriate medicine supplies, diagnostic
facilities and organized record keeping.

43
Audit Check Points :

1) Are adequate numbers of first aid boxes provided? Check location details
2) Are qualified / trained first aiders available in each shift?
3) How many qualified/trained first aiders are available at each plant/department?
4) How many persons are trained/given refreshers training in first aid in a year?
5) Whether Ambulance room is provided for first aid treatment and rest?
6) Does Ambulance Room conform to the provisions of the existing statutes?
7) Are the Medical Attendants/Doctors available?
8) What facilities are available for transportation of the injured to hospital?
9) Are the names of the trained first aiders displayed?
10) Are the name of nearest hospitals and its telephone number available?

Documents to be checked:

List of qualified / trained first aiders and their certificates.

1. First –aid boxes replenishment schedule.
2. First-aid training record.
3. Medical emergency response plan

Observations to be made during Field visit:

1. Check First aid boxes in departments, their location, contents, record of use, display of
names of first aiders etc.
2. Check availability of well equipped Ambulance and driver.
3. Check facilities at Ambulance Room and availability of qualified doctor(s) and
paramedical staff.

J ) MANAGEMENT OF EMERGENCY

Several types of chemicals are handled in industry in huge quantities. Many of them are
hazardous in nature. Furthermore, there is the ever-increasing aspiration on the part of the
people who put emphasis on efficiency, production, growth and progress. This naturally puts a
strong commercial pressure on the industry to use modern technology and involve larger sizes of
plants and inventories and faster processes of production.

While handling chemicals adequate safety measures should be taken to control hazards and
prevent accidents. An accident involving a hazardous chemical has a potential to cause serious
injury, death or damage beyond the immediate vicinity of the accident site.

Background:

The imperatives of preparedness to minimise adverse effects of accidents occurring in

manufacture, storage and transport of chemicals is well recognised. Emergency which can affect
with the premises is called the ‘on- site emergency’. When the effect of emergency situation
spreads beyond boundary or in the industrial pocket or in the community is the ‘off-site
emergency’. Plan needs to be made based on envisaged scenarios. These plans are to be
designed to provide measures to contain an accident, minimise effects.

The statues dealing the provisions for preparing emergency plan are as follows:

• Factories Act, 1948 and State Factories Rules.

• The Manufacture, Storage and Import of Hazardous Chemicals (MSIHC) Rules, 1989.
• The Chemical Accidents (Emergency Planning, Preparedness and Response) Rules,
1996 (CAPPR Rules, 1996)

44
 • The Petroleum and Natural Gas Regulatory Board (Codes of Practices for Emergency
Response and Disaster Management Plan) Regulations, 2010.
• The Central Electricity Authority (Safety Requirements for Construction, Operation and
Maintenance of Electrical Plants and Electric Lines) Regulations, 2011.
• The Building and Other Construction Workers (Regulations of Employment & Conditions
of Service) Central Rules, 1998.
• The Dock Workers (Safety, Health and Welfare) Regulations, 1990
• The Explosives Rules, 2008
• The Gas Cylinders Rules, 2016
• The Ammonium Nitrate Rules, 2012
• The Static and Mobile Pressure Vessels (Unfired) Rules, 2016
• The Mines Rescue Rules, 1985

Legal Requirements :
Sr. Legislation Section / Provisions
No. Subsection
/ Rule /
Sub-Rule/
Regulation
1 Factories Sec 41 Provisions related to hazardous process –
Act, 1948 (B-4) Compulsory disclosure of information by the Occupier:
• With the approval of the Chief Inspector, prepare an
on-site emergency plan with the detailed disaster
control measures
• Make known to the workers and general public living
in the vicinity about safety measures required to be
taken in emergency.
2 Model Rules 82-D(1) Required information to be provided to the workers
made under regarding measures to be taken by them in case of spillage
Factories Act or leakage of hazardous substances vis-à-vis the
emergency plan of the factory, in particular the evacuation
procedure. The information provided in the form of booklets
or leaflets and cautionary notice at workplaces in the
language understood by majority of workers.
82-E Information to be provided general public including factory’s
emergency warning system and action to be taken by them
during emergency.
82-F Provide required information to local authority including
information provided to general public
82-G Provide required information including copy of emergency
plan to District Emergency Authority
82-I • The occupier of a factory carrying on a hazardous
process shall prepare a draft on-site emergency plan
and submit it to the Chief Inspector. The Chief Inspector
may make such modification in the plan as necessary, in
consultation with the occupier and approve the same.
• The occupier to submit a copy of the approved plan to
the District Emergency Authority
• The occupier will intimate the workers the provisions of
the emergency plan and hold rehearsals of the plan
periodically. He shall review the plan from time to tome
and make necessary changes therein under intimation
to the Chief Inspector and the District Emergency
Authority

45
Sr. Leglislation Section / Provisions
No. Subsection /
Rule / Sub-
Rule/
Regulation
3. Control of These Rules supplement to the Rules 82-D to 82-I referred above of
Industrial Major the model Rules
Accidents
Rule 5 Notification of major accidents : Notify the major
Hazards
accident to CIF within 4 hours and thereafter furnish
(CIMAH) Rules
report to Inspector and CIF I a format provided as
under the
Schedule-3
Factories Act
Rule 12 • Prepare on-site emergency plan as per schedule 6
and keep it up-to-date
• Conduct mock-drill at least once in every six months
• Detailed report of the mock-drill shall be made
available to the Inspector
Rule 13 Relevant information to be provided to neighbourhoods
who are likely to be affected including safety measures
and do’s and don’ts to be adopted during major
accident.
4 Manufacture, Rule-13 • Prepare and keep up-to-date an onsite emergency
Storage and plan as per Schedule – 11
Import of • Conduct mock-drill every six months and its detailed
Hazardous report shall be made immediately available to the
Chemicals authority.
Rules, 1989 Rule-14(2) The occupier to provide relevant information to the
authority for preparing off-site emergency plan.
Rule -14 (4) Puts obligation on the Authority to ensure that a rehearsal
of the off-site emergency plan is conducted once a year.
Rule 14 Off-site Emergency Plan is required to be prepared in
Schedule 5 consultation with District Collector or District Emergency
Authority.
Rule – 15 Provide information to the persons outside of the industry
directly or through district emergency authority about
nature of major accident hazard and safety measures with
do’s and don’ts to be followed in the event of a major
accident.
5 Chemical Rule 9(2)(a) Puts statutory obligation on the Districts Crisis Group as
Accident and its functions to assist in preparing district off-site
(Emergency Rule 9(2)(g) emergency plan and conduct on full-scale mock drill of a
Planning, chemical accident each year and send a report of the
Preparedness strength & weakness of the plan to the State Crisis
and Response Group.
Rules, 1996) Rule Puts statutory obligation on the Local Crisis Group as one
10 (2) (a) of its functions to prepare local emergency plan of the
And industrial pocket and to conduct one full-scale mock drill
Rule of a chemical accident every six months and send a
10 (2) (e) report to the District Crisis Group
6 NGRB Regulation To develop Emergency Response & Disaster
Regulations, 4.2 Management Plan as per the content in the Regulation-5
2010
Regulation Carry out mock drills for on-site emergency plan once in
12.1 three months and for off-site emergency plan once in
twelve months

46
Sr. Leglislation Section / Provisions
No. Subsection /
Rule / Sub-
Rule/
Regulation
7 CEA Regulation 9 Emergency Management Plan:
Regulations, • Formulate On-site Emergency Management Plan as
2011 per Schedule-III covering fire, explosion, gas leakage,
natural calamities and crisis situations arising in the
event of strikes, terrorist threat and sabotage
• Conduct mock drill at least once every six months
• Provide information to the District Collector for
preparing off-site emergency plan.
8 BOCW Rules, Rules 36 Emergency Action Plan
1998 • Make emergency plan for construction site if more
than 500 workers are employed and submit it for
approval of the Director General
• Emergency Plan to cover emergencies like fire &
explosion, collapse of lifting appliance & transport
equipment, collapse of building, sheds & structures,
etc, gas leakage or spillage of dangerous goods or
chemicals, drowning of building workers, sinking of
vessels and landslides getting building workers
buries; floods, storms & other natural calamities
9 Dock Workers Regulation Emergency Action Plan : All ports shall have an approved
Regulations, 112 emergency action plan acceptable to the Chief Inspector
1990 to handle emergencies like fires & explosions; collapse of
lifting appliances, buildings, sheds, etc., gas leakage &
spillage of dangerous goods, drowning of dock workers,
sinking of vessels, retrieval of transport equipment from
dock basin and floods; storms & other natural calamities.
10 Explosives Rule 26 Approval of manufacturing process –
Rules, 2008 (3-e) For manufacturing explosives, the Company should have
emergency response planning and preparedness such as
first aid and the Plan to be tested once in a year,
11 Gas Cylinder Rules 29 (3) For importing gas cylinders the owner should have
Rules, 2016 necessary infrastructure, handling transportation and
storage facility including emergency action plan and
qualified and trained technical manpower.
12 Ammonium Rules 15 Safety and Security Management Plan –
Nitrate Rules, Prepare and submit the Safety and Security Management
2012 Plan to the Licensing Authority and to the District
Authority with the security aspect duly vetted by the police
authorities for approval
13 SMPV Rules, Rules 29 One of the requirements under Schedule II (N) for an auto
2016 LPG dispensing station is to have emergency plan.
Requirements relating to emergency planning to be
checked with the license issued by the authority.
14 Mines These rules apply to coal and metalliferous underground
Rescue mines to provide for the establishment of rescue stations
Rules, 1985 and conduct of rescue work of persons in case of
explosion or fire, an inrush of water or influx of gases.

47
On-site Emergency Plan

The on-site emergency plan must be related to the assessment of the risk and hazards in the
factory and it is the responsibility of the works management to formulate it. The plan must
therefore be specific to the site. On very simple sites, the emergency plan may consist merely of
putting key personnel on stand-by and calling outside emergency services for help during an
emergency. On large multi-process sites, the plan may well be substantial document. The
typical components of the plan of such sites are as follows:

• Plant Emergency Organization

− Designated person in charge/alternates
− Functions of each key individual and group
− Telephone numbers (office and home) for key people/alternates)

• Plant Risk Evaluation

− Quantity of hazardous materials
− Location of hazardous materials
− Properties of each (MSDS sheets)
− Location of isolation valves
− Special fire fighting procedures (if any)
− Special handling requirements

• Area Risk Evaluation

− Properties of hazardous materials at nearby plants
− Nearby residence and population centre
− Contacts (names, telephone numbers) at other sites
− Established procedures for notification of chemical release at other sites in area.

• Notification Procedures and Communication Systems

− Alarm Systems
− Communication equipment (radios, hot lines, etc.) Plant Management , Local
officials and response agencies Neighbouring industry, Nearby residents
− Names and telephone numbers (with alternates) list
− Designated person for media contacts
− Procedure for notifying families of injured employees
− Central reporting office

• Emergency Equipment and Facilities

− Fire fighting equipment
− Emergency medical supplies
− Toxic gas detectors (where needed)
− Wind direction/ speed indicators
− Self-contained breathing apparatus
− Protective clothing
− Other on-site equipment to be specified according to local conditions
− Containment capabilities

• Procedure for Returning to Normal Operations

− Interface and lines of communications with offsite officials

48
 • Training and Drills
− Knowledge of chemicals (properties, toxicity, etc.)
− Procedures for reporting emergencies
− Knowledge of alarm systems
− Location of fire fighting equipment
− Use of fire fighting equipment
− Use of protective equipment (respirators, breathing air, clothing, etc.)
− Decontamination procedures for protective clothing and equipment
− Evacuation procedures
− Frequent, documented simulated emergencies

Regular Tests of Emergency Organisation/Procedures

− Simulated emergencies
− Documented, frequent alarm system
− Frequent tests of fire fighting equipment
− Evacuation practice
− On-going emergency preparedness committee

Plan Updates
− Annual or more frequent drill if needed
− Reflect results of drills and tests

• Emergency Response Procedures

− Communications
− Evacuation or safe haven
− Medical (include handling of multiple injuries)
− Special procedures for toxic gas releases (chlorine, etc.)
− Hurricane procedures (coastal area only)
− Utility failure procedures
− Individual unit emergency procedures
− Bomb threat procedures

• Detailed Operating Manuals (for each process unit and utility system)
− Start-up /Shut-down emergency procedures
− Analysis of potential incidents
− Emergency response and action to be taken for each incident.

Off-site Emergency Plan

The off-site emergency plan is an integral part of any major hazard control system. It should be
based on those accidents identified by the factory management which could affect people and the
environment outside the factory. Thus, the off-site plan follows logically from the analysis that
took place to provide the basis for the on-site plan and the two plans should therefore
complement each other. The off-site plan in detail should be based on those events which would
have severe consequences should also be considered. Incidents which would have severe
consequences yet have a small probability of occurrence will be in this category, although there
will be certain events which are so improbable that it would not be sensible to consider them in

49
detail in the plan. These events might include aircraft crashes on to the installation. However,
the key feature of a good off-site emergency plan is flexibility in its application to emergencies
other than those specifically included in the formation of the plan.

The roles of the various agencies who may be involved in the implementation of an off-site plan
are important aspects of the plan. Depending on local arrangements, the responsibility for the
off-site plan will be likely to rest either with the factory management or, as is the case under the
Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989 under the Environment
Protection Act, 1986, with the local authority i.e. District Emergency Authority. Either way, the
plan must identify an emergency co-ordinating officer who would take overall command of the off-
site activities. As with the on-site plan, an emergency control centre will be required within which
the emergency co-ordinating officer can operate.
An early decision will be required in many cases on the advice to be given to people living “within
range” of the accident – in particular whether they should be evacuated or told to go indoors. In
the latter case, the decision can regularly be reviewed in the event of an escalation of the
incident.

A plan should have sufficient flexibility built-in to cover the consequences of the range of
accidents identified for the on-site plan, it is suggested that it should cover in some detail the
handling of the emergency to a particular distance form each major hazard works. This distance
may be judged to be similar to the separation zone distance or the information-to-the public
distance.

Guidance to check compliance:

1) Whether the Quantity of Hazardous Chemical store in the plant exceed the threshold
limit specified MSIHC Rule 1989?
2) Frequency of Mock drill Conducted? and Scenarios of Mock drill covered in past drill ?
3) Whether the drill is conducted during Night, Holidays?
4) Check in the drill report, whether deficiencies are reported. If reported, what actions have
been taken?
5) Whether potential accidents and emergencies identified (document check)
6) Whether Emergency plan is prepared and approval from the Factory
Inspectorate.(document check)
7) If the Emergency plan is not approved whether the factory has got the acknowledgment
from the office of Inspectorate for submitting the Plan (document check).
8) Whether the Plan is prepared as per the Contents of MSIHC Rules, PNGRB Regulations
or CEA Regulations In other cases check the Plan has been outlined the actions to be
taken when specified emergency situations arise, and at least the following as per the
nature of factory or industry. Some important aspects of the contents are as follows:
Location of emergency control centre (checking site) and responsibility, authority and
duties of personnel with specific roles during the emergency (e.g. fire-wardens, first-aid
staff, nuclear leak/toxic spillage specialists); (document check and discussion
9) Details of actions to be taken by personnel during an emergency including those actions
to be taken by external personnel who are on the site of the emergency, such as
contractors or visitors.(document check and discussion)
10) Evacuation procedures. (document check and discussion)
11) Identification and location of hazardous materials, and emergency action required
(document check and discussion)
12) communication within the factory, with statutory bodies; neighbours and the public;
(document check and discussion)
13) Availability of necessary information during the emergency e.g. plant layout drawings,
hazardous material data, procedures, work instructions and contact telephone numbers.
(document check and discussion).
14) The involvement of external agencies in emergency planning and response should be
clearly documented. (document check and discussion)

50
 15) What actions or steps have been taken by industry for informing the workers and nearby
communities about the major emergencies and what they have to do during such
emergencies?(document check and discussion)

k) EMPLOYEE SELECTION, PLACEMENT AND PARTICIPATION

Introduction

Employee selection and placement is the process of putting right men on right jobs. It is a
procedure of matching organizational requirements with the skills and qualifications of people.
The pre-placement examination is required to determine and record the health condition of
prospective employees so they can be assigned to jobs suitable to their mental ability and
physical capacity. Also, periodic health examination of the employees, those are exposed to
hazardous process or materials are also equally important. This will help the management to
ascertain that the engineering and hygiene controls provided are effective. Also, enable early
detection of the adverse effects on the individuals.

Neither management nor worker can accomplish the safety excellence alone. Each has
responsibility and must accept and carry his share. If both get together and discuss the problem
of accidents and their effect on production, morale and income, each may see the mutual benefits
of willing participation and wholehearted cooperation. Hence, participation of each and everyone
in Occupation Safety and Health (OSH) is an essential in an accident prevention programme of
an organization.

Safety Responsibility

• Management

Safety primarily is the legal and moral obligation of the employer. The employer must have
sincere and continuing interest in providing for the safety for his employees. The interest is
demonstrated by:
(i) initiation of a sound safety programme with the policies, procedures and staff
necessary to make it effective.
(ii) provision of safe working conditions, machinery and equipment; providing for protective
measures which are adequately maintained.
(iii) provision of adequate personal protective equipment wherever necessary.
(iv) development of effective training programmes for supervisors and for other employees.
(v) setting up of the proper atmosphere which will lead to the encouragement of employee
interest and participation by making available channels through which employees may
offer suggestions, advice and recommendations for the improvement of safety and
health.
(vi) for selecting and placing employees management to consider,
- Whether a particular employee is suitable for a particular job?
- If a particular employee making repeated mistakes i.e. unsafe acts, management to
identify the root causes and if require relocate the employee.
- Rotate the employees from hazardous areas to non-hazardous areas and vice
versa. Review the medical health checkup record of the employees working in
hazardous areas.

51
• Workers

Cooperation in the safety programme is the obligations of each individual employee. This is
demonstrated by:

(i) working safely at his job. The conscientious safety-minded worker abides by safety
rules and regulations and does not take shortcuts or use unsafe practices.
(ii) having regards at all times for the safety of his fellow workers and others about him.
(iii) using his influence and knowledge to prevent accidents.
(iv) calling prompt attention to unsafe conditions.
(v) contributing his ideas, suggestions and recommendations for the improvement of
safety at proper level.
(v) participating in campaigns, provide suggestions related to OSH and report near
misses.

Legal Requirements

There are provisions under the following statutes which relate to the selection and placement of
the employees and also participation such as a formation of safety committee, training and
campaigns.

• The Factories Act, 1948 and the State Rules made there under
- Section 23 put condition for employment of young person’s on dangerous machines.
- Section 41-C has specifies specific responsibility of the occupier in relation to hazardous
processes viz. maintaining health records and appointing qualified & experienced person for
supervising the work.
- Section 41-G is related to worker’s participation in safety management.
- State Rules have provisions of placement of employees such as dangerous operations,
rehabilitation of workers working in high noise areas, etc.
• The Building and Other Construction Workers (Regulation of Employment and Conditions of
Service ) Central Rules,1998 and the State Rules
• The Central Electricity Authority (Safety Requirements for Construction, Operation,
Maintenance of Electrical Plants and Electric Lines) Regulations, 2011

Guidance to check

The following points to be considered for knowing the system or procedure for selecting and
placing employees in an organization. Whether any norms are available for selection of different
category of employees
1) Whether any norms are available for selection of different category of employees?
2) Whether pre-employment medical examination is being conducted for employees?
3) Is there any procedure to evaluate safety awareness and record of the employees during
their promotion?
4) How the employees have been selected and placed on the hazardous process or
dangerous operations? Are such employees are trained and their refresher training?

Some statues have provision to organize campaigns, competitions, etc. for wide participation of
the employees. These types of activities can be verified by going through documents,
photographs, etc.

Some organizations have safety suggestion scheme, reporting of near misses, conduct daily
“Tool Box” meetings before starting the job, etc. Such initiatives should also be checked.

52
l) SAFETY CULTURE

The safety culture of an organization is the product of individual and group values, attitudes,
perception, competencies and patterns of behavior that determine the commitment to, and the
“style and proficiency” of an organization’s health and safety management.

Parker and Hudson Safety Culture Model

The Parker and Hudson model is as follows:

▪ Pathological (i.e. anarchy)

▪ Re-Active
▪ Calculative (i.e. compliant)
▪ Pro-Active
▪ Generative (i.e. embodying a ‘healthy paranoia’)

1. Traditional Safety improvement tactics Versus initiatives to improve Safety Culture

Traditional Improvement Tactics

• Attacking high frequency / severity events

• Addressing causal factors (e.g. PPE inadequate)
• Addressing root cause (training, systems, procedures)
• Safety stand-downs
• Signage

53
Improving Culture

1. Strong Leadership

▪ Visible, demonstrated commitment

▪ Clear, meaningful policies and principles
▪ Challenging goal and plans
▪ High standards of performance

2. Appropriate Structure

▪ Line Management accountability

▪ Supportive safety staff
▪ Integrated committee structure
▪ Performance measurement and progressive motivation

3. Focused Processes and Action

▪ Through investigations and follow-up

▪ Effective audits and re-evaluation
▪ Effective communication processes
▪ Training & safety management skills.

2. Path for strengthening Safety culture:

The six sets of behaviour required to develop a world class safety culture are:

• Analysis (before blame)

• Lead Measurement
• Workforce Ownership
• (Effective) Communication
• Modelling Safety
• Challenging Unsafe Acts

54
3. Creating Safety Culture:

Safety cultures consist of shared beliefs, practices, and attitudes that exist at an establishment.
Culture is the atmosphere created by those beliefs, attitudes, etc., which shape our behaviour. An
organizations safety culture is the result of a number of factors such as:

▪ Management and employee norms, assumptions and beliefs;

▪ Management and employee attitudes;
▪ Values, myths, stories;
▪ Policies and procedures;
▪ Supervisor priorities, responsibilities and accountability;
▪ Production and bottom line pressures vs. quality issues;
▪ Actions or lack of action to correct unsafe behaviours;
▪ Employee training and motivation; and
▪ Employ involvement or “buy-in”

In a strong safety culture, everyone feels responsible for safety and pursues it on a daily basis;
employees go beyond “the call of duty” to identify unsafe conditions and behaviours, ad intervene
to correct them. For instance, in a strong safety culture any worker would feel comfortable
walking up to the plant manager or CEO and reminding him or her to wear safety glasses. This
type of behaviour would not be viewed as forward or over-zealous but would be valued by the
organization and rewarded. Likewise co-workers routinely look out for one another and point out
unsafe behaviours to each other.

A company with a strong safety culture typically experiences few at-risk behaviours, consequently
they also experience low accident rates, low turn-over, low absenteeism, and high productivity.
They are usually companies who are extremely successful by excelling in all aspects of business
and excellence.

Creating a safety culture takes time. It is frequently a multi-year process. A series of continuous
process improvement steps can be followed to create a safety culture. Employer and employee
commitment are hallmarks of a true safety culture where safety is an integral part of daily
operations.

A company at the beginning of the road toward developing a safety culture may exhibit a level of
safety awareness, consisting of safety poster and warning signs. As more time and commitment
are devoted, a company will begin to address physical hazards and may develop safety
recognition programs, create safety committees, and start incentive programs.

Top management support of a safety culture often results in acquiring a safety director, providing
resources for accident investigations, and safety training. Further progress towards a true safety
culture uses accountability systems. These systems establish safety goals, measure safety
activities, and charge costs back to the units that incur them. Ultimately, safety becomes
everyone’s responsibility, not just the safety director’s Safety becomes a value of the organization
and is an integral part of operations. Management and employees are committed and involved in
preventing losses. Over time the norms and beliefs of the organization shift focus from eliminating
hazards to eliminating unsafe behaviours and building systems that proactively improve safety
and health conditions Employee safety and doing something the right way takes precedence over
short term production pressures. Simultaneously, production does not suffer but is enhanced due
to the level of excellence developed within the organization.

3.1 Building a safety culture

Any process that brings all levels within the organization together to work on a common goal that
everyone holds in high value will strengthen the organizational culture. Worker safety and health
is a unique area that can do this. It is one of the few initiatives that offer significant benefits for the

55
front-line work force. As a result, buy-in can be achieved enabling the organization to effectively
implement change. Obtaining front line buy-in for improving worker safety and health is much
easier than it is to get buy-in for improving quality or increasing profitability. When the needed
process improvements, are implemented all three areas typically improve and a culture is
developed that supports continuous improvement in all areas. The following represents the major
processes and milestones that are needed to successfully implement a change process for safety
and health. It is intended to focus you on the process rather than individual tasks. It is common to
have a tendency to focus on the accomplishment of tasks, i.e. to train everyone on a particular
concern or topic or implement a new procedure for incident investigations, etc. Sites that maintain
their focus on the larger process to be followed are far more successful. They can see the “forest”
from the “trees” and thus can make mid-course adjustments as needed. They never lose sight of
their intended goals, therefore, the tend not to get distracted or allow obstacles to interfere with
their mission. The process itself will take care of the task implementation and ensure that the
appropriate resources are provided and priorities are set.

Management Processes Typically Ripe for Improvement:

▪ Define safety responsibilities for all levels of the organization, e,g, safety is a line
management function.
▪ Develop upstream measures, e.g. number of reports of hazards/suggestions, number of
committee projects/successes, etc.
▪ Align management and supervisor through establishing a shared vision of safety and health
goals and objectives vs. protection.
▪ Implement a process a process that holds managers and supervisors accountable for
visibly being involved, setting the proper example, and leading a positive change for safety
and health.
▪ Evaluate and rebuild any incentives and disciplinary systems for safety and health as
necessary.
▪ Ensure the safety committee is functioning appropriately e.g. membership, responsibilities /
functions, authority, meeting management skills. Etc.
▪ Provide multiple paths for employees to bring suggestion, concern, or problems forward.
One mechanism should use the chain of command and ensure no repercussions. Hold
supervisors and middle managers accountable for being responsive.
▪ Develop a system that tracks and ensures the timeliness in hazard correction. Many sites
have been successful in building this in with an already existing work order system.
▪ Ensure reporting of injuries, first aids, and near misses. Educate employees on the
accident pyramid and importance of reporting minor incidents. Prepare management for
initial increase in incidents and rise in rate. This will occur if under-reporting exists in the
organization. It will level off, then decline as the system changes take hold.
▪ Evaluate and rebuild the incident investigation system as necessary to ensure that it is
timely, complete and effective. It should get to the root causes and avoid blaming workers.

Obtain Top Management “Buy-in” – This is the very first step that needs to be accomplished.
Top managers must be on board. If they are not, safety and health will compete against core
business issues such as production and profitability, a battle that will almost always be lost. They
need to understand the need for change and e willing to support it. Showing the costs to the
organization in terms of dollars (dire and indirect costs of accidents) that are being lost, and the
organizational costs (fear, lack of trust, feeling of being used, etc.) can be compelling reasons for
looking at needing to do something different. Because losses due to accidents are bottom line
costs to the organization, controlling these will more than pay for te needed changes. In addition,
when successful, you will also go a long way in eliminating organizational barriers such as fear,
lack of trust, etc. Issues that typically get in the way of everything that the organization wants to
do.

Continue Building “Buy-in” for the needed changes by building an alliance or partnership
between management, the union (if one exist), and employees. A compelling reason for the

56
change must be spelled out to everyone. People have to understand. WHY they are being asked
to change what they normally do and what it will look like if they are successful. This needs to be
done up front If people get wind that something “is going down” and haven’t been formally told
anything, they naturally tend to resist and opt out.

Build Trust – Trusting is a critical part of accepting change and management needs to know that
this is the bigger picture, outside of all the details. Trust will occur as different levels within the
organization work together and begin to see success.

Conduct Self Assessments/Bench Marking – To get where you want to go, you must know
where you are starting from. A variety of self-audit mechanisms can be employed to compare
your site processes with other recognized models of excellence such as Star VPP sites, Visiting
other sites to gain first-hand information.

Initial Training of Management-Supervisory staff, Union Leadership (if present), and safety and
health committee members, and a representative number of hourly employees. This may include
both safety and health training and any needed management, team building, hazard recognition,
or communication training, etc. This gives you a core group of people to draw upon as resources
and also gets key personnel onboard with needed changes.

Establish a Steering Committee comprised of management, employees, union (if one exists),
and safety staff. The purpose of this group is to facilitate support, and direct the change
processes. This will provide overall guidance and direction and avoid duplication of efforts. To be
effective, the group must have the authority to get things done.

Develop Site Safety Vision, key policies, goals, measures, and strategic and operational plans.
These policies provide guidance and serve as a check-in that can be used to ask yourself if the
decision you’re about to make supports or detracts from your intended safety and health
improvement process.

Align the Organization by establishing a shared vision of safety and health goals and objectives
vs. production. Upper management must be will to support by providing resources (time) and
holding managers and supervisors accountable for doing the same. The entire management and
supervisory staff need to set the example and lead the change. It’s more about leadership than
management.

Define Specific Roles and responsibilities for safety and health at all levels of the organization.
Safety and health must be viewed as everyone’s responsibility. How the organization is to deal
with competing pressures and priorities, i.e. Production, versus safety and health, needs to be
clearly spelled out.

Develop a System of Accountability for all levels of the organization. Everyone must play by
the same rules and be held accountable for their areas of responsibility. Signs of a strong culture
is when the individuals hold themselves accountable.

Develop Measures and an ongoing measurement and feedback system. Drive the system with
upstream activity measures that encourages positive change. Examples include the number of
hazards reported or corrected, numbers of inspections, number of equipment checks, JSA’s, pre-
start-up reviews conducted, etc.

While it is always nice to know what the bottom line performance, is, i.e. accident rates,
overemphasis on these and using them to drive the system typically only drives accident
reporting under the table. It is all too easy to manipulate accident rates which will only result in
risk issues remaining unresolved and a probability for more serious events to occur in the future.

57
Development Policies for Recognition, rewards, incentives, and ceremonies. Again, reward
employees for doing the right things and encourage participation in the upstream activities.
Continually re-evaluate these policies to ensure that they do not become entitlement programs.

Awareness Training and Kick-off for all employees. It’s not enough for a part of the
organization to be involved in some manner. A kick-off celebration can be used to announce it’s a
“new day” and seek buy-in for any new procedures and programs.

Implement Process Changes via involvement of management, union (if one is present), and
employees using a “Plan To Act” process Total Quality Management (TQM).

Continually Measure performance, Communicate Result, and Celebrate Success. Publicizing

results is very important to sustaining efforts and keeping everyone motivated. Everyone needs to
be updated throughout the process. Progress reports during normal shift meetings allowing time
for comments back to the steering committee opens communications, but also allows for input.
Everyone needs to have a voice, otherwise, they will e reluctant to buy-in. A system can be as
simple as using current meetings, a bulletin board, and a comment box.

On-going Support – Reinforcement, feedback, reassessment, mid-course corrections, and on-

going training is vital to sustaining continuous improvement.

LEGAL REQUIREMENTS

SN Legislation Section / Rule Provision

1. The Factories Sec. 7A: (1) Every occupier shall ensure, so far as is
Act, 1948 General duties reasonably practicable, the health, safety and welfare
of the occupier of all workers while they are at work in the factory.
Section 41B(2) The occupier of the factory involving hazardous
process is required to prepare detailed policy and
intimate Chief inspector.
Sec. 111: (1) No worker in a factory--
Obligations of
workers (a) shall wilfully interfere with or misuse any
appliance, convenience or other thing provided in a
factory for the purposes of securing the health, safety
or welfare
of the workers therein;
(b) shall wilfully and without reasonable cause do
anything likely to endanger himself or others; and
(c) shall wilfully neglect to make use of any appliance
or other thing provided in the factory for the purposes
of securing the health of safety of the workers therein.

(2) If any worker employed in a factory contravenes

any of the provisions of this section or of any rule or
order made thereunder, he shall be punishable with
imprisonment for a term which may extend to three
months, or with fine which may extend to one
hundred rupees, or with both.

58
SN Legislation Section / Rule Provision

2 Model Rules Rule 79 - 7 (a- (7) Function and duties of the Safety Committee shall
under the d) – Safety include –
Factories Act Committee –
1948. Prescribed (a) assisting and cooperating with the management in
under Section achieving the aims and objectives outlined in the
The Model 41 and 41 G of ‘Health and Safety Policy’ of the occupier;
Rules have The Factories
been framed by Act, 1948. (b) dealing with all matters concerning health, safety
DGFASLI. and environment and to arrive at practicable solutions
Based on these to problems encountered;
model rules,
State Factories (c) creating safety awareness amongst all workers;
Rules has been
prepared by (d) undertaking educational, training and promotional
respective activities;
States, hence Rule 82B (5) – (4) The Health and Safety Policy should contain or
the state 4 (a), 5 (a, b, deal with:
factory rules of g), 7 (a, b)
the states have concerning (a) declared intention and commitment of the top
similar Health and management to health, safety and environment and
provision, Safety Policy – compliance with all the relevant statutory
however the Prescribed requirements;
rule number under Section
may be 7A(3), 41B(2) (5) In particular, the Policy should specify the
different. and 112 of The following:
Factories Act,
1948 (a) arrangements for involving the workers;
(b) intention of taking into account the health and
safety performance of individuals at different levels
while considering their career advancement;
(g) arrangements for informing, educating and
training and retraining its own employees at different
levels and the public, wherever required.

(7) The Policy shall be made widely known by –

(a) making copies available to all workers including

contract workers, apprentices, transport workers
suppliers, etc.
(b) displaying copies of the policy at conspicuous
places; and
3 Building and Rule 39 Establishment employing fifty or more building
other workers has to prepare Health and Safety policy in
construction Hindi and local language understood by the majority
workers of building workers.
(Regulation of
employment The policy should be displayed at conspicuous
and conditions places.
of service )
Central
Rules,1998

59
SN Legislation Section / Rule Provision

4 Central Regulation Owner is required to formulate a written statement of

Electricity 4,(4),(a) policy in respect of safety and health of employees.
Authority (
Safety
Requirements
for
Construction,
Operation,
Maintenance of
Electrical
Plants and
Electric Lines)
Regulations ,
2011

Guidance for compliance:

1) Has the management carried out any systematic Safety Culture assessment through any
reputed agency?
2) Has the corrective actions been taken?
3) What are their attitudes towards safety reviews and audits?
4) Whether the response of management to safety violation is lenient or strict?
5) Whether workers are aware of the consequences of their wrong actions?
6) Are laid down safe working procedures followed strictly?
7) What is the attitude of the workers towards their own mistake, which can prejudice
safety?
8) Do the workers report near miss incidents and suggest safety improvements?
9) Are the workers aware of the system of rewards and sanctions relating to safety matters?
10) What is the attitude of workers towards use of personal protective equipment?

Documents to be checked:

1) Verify the documents of Guideline for top management commitment towards Safety and
Health.
2) Top Management visit reports and its implementation
3) Safety Committee meetings and their management input
4) Records of “Safety only” meetings
5) Action taking for any non compliance or penalty system for Contractor.

m) STATUTORY LICENSES/PERMISSIONS, APPROVALS AND RECORDS

For setting up and running of an industry, the following licenses, permissions/ approvals are
required. Statutes wise of such requirements are listed below:

1. The Factories Act, 1948 and State Rules framed under it.
• Approval of site of factory and building plans (Sec.6 and rules framed there under)
• Permission to construct, extend or take into use any building as a factory (Sec.6 and
rules framed there under)
• License to use any premises as a factory (Sec.6 and rules framed thereunder)

60
 • Approval of certificate of stability of the building of factory (Sec.6 and rules framed
thereunder)
• Appraisal of site by State Govt. Site Appraisal Committee for establishment of
hazardous process factories (factories covered under Sec.2(c b) and Sec.41A.)
• Approval of onsite emergency plan and detailed disaster control measures (factories
covered under Sec.2 (cb) and Sec. 41 (B).
• Approval for exceeding daily hours of work in order to facilitate the change of shifts
(Sec. 54)
• Water supply for drinking other than public water supply (Rule 40) source approved by
Health Officer
• Records of minutes of meeting of safety committee
• Inspection register of factory inspector
• Reporting of accident to factory inspector
• Compliance report against note of factory inspector
• Record of periodical medical check-up employees
• Records of checking of lifting machines ( 12 months) in prescribed format
• Record of inspection of hoist (once in six months) as per prescribed format
• Record of hydro testing of air receivers ( once in 12 months)

2. The Building and Other Construction Workers (Regulation of Employment and

Conditions of Service) Central Rules, 1998
• Registration of Establishment (Sec.7, Rule23)
• Registration of building workers(Sec.12)
• Notice of:
- Commencements of building construction (Sec.46)
- To carry out excavation and tunnelling work (Rule119)

• Approval for:
- Health and Safety Policy(Rule39)
- Ventilation system installed in a free air tunnel (Rule153)
- Procedure of decompression of all workers to atmospheric condition at tunnelling
work [(Rule166C(vi)]
- Decanting of workers at tunnelling work [(Rule166C(vii)]
- Working in a compressed air environment at pressure exceeding 3 bar
[(Rule166C(xii)]
- Chute having height exceeding12meters [(Rule177C(ii)]
- Trestle scaffold more than three tier or working platform at height more than 4.5
meters above ground floor [Rule202(a)]
- Type of counter weights to be used for balancing suspended scaffold [(Rule204 (b)]

• Permission to :
- Use material lock for compression and decompression of workers in tunnelling
work [(Rule166C(iv)]
- Appoint common Safety Officer [Rule209(3)]

3. The Boiler Act, 1923 and Indian Boiler Regulations, 1950

• Registration of boiler(Sec-7)
• Renewal of Certificate (Sec-8).
• Use of Boiler Pending grant of certificate (Sec-10).

61
 • Alteration and renewal to boilers (Sec-12) and Steam-Pipe (Sec-13) (Reg.392):-The
owner of the registered boiler to submit the report to the Chief Inspector for alteration
and renewal of steam pipe.
• Application for recognition (Reg.4A):- An application for recognition as competent
authority; well-known steel, tube & pipe maker and foundry/forge.
• Renewal of Certificate of recognition (Reg.4E).
• Application for registration of existing competent authority (Reg.4F).
• Registration of Second Hand boilers not in accordance with standard conditions(Reg.7).
• Hydraulic test of boilers for registration of boilers (Reg.377).
• Grant of certificates (Reg.389).
• Submission of plans of steam pipes (Reg.395).
• Safety of persons working inside the boilers (Reg.396): The owner to obtain the
approval of Chief Inspector in writing before person enters for working.

4. The Explosives Act, 1884 and Rules framed thereunder:

a) TheExplosivesRules,2008
• Authorization of explosives(Rule6)
• Licensesformanufacture,import,export,transport,possessforsaleoruse(Rule7)
• Approval of manufacturing process(Rule26)
• Priorapprovalbeforeconstructionofthepremisesfromtheconcernedlicensing
authority(Rules99&101)
• No objection certificate before construction from District Magistrate or DG Mines
Safety as the case may be(Rule102)

b) The Gas Cylinders Rules, 2016

• Approval to fill any cylinder with any compressed gas or import or possesses or
Transport any cylinder(Rule 3)
• Approval for manufacture cylinders, valves, LPG regulators and other fitting.
• License for import of gas cylinders (Rule29) compression of acetylene (Rule40)
And filling and possession of cylinder (Rule43)
• Prior approval of specifications and plans of premises (Rule47)

c) The S.M.P.V.(Unfired) Rules,1981 (Amended in 2016)

• Approval for manufacturing & repair or modifications of pressure vessels (Rule4
and Rule6)
• Approval of vehicle for transport of compressed gas in a pressure vessel (Rule
35)
• Prior approval of specifications and plans of vessels and premises (Rule46)
• Licenses for storage of compressed gas [Rule(45)] and transport of compressed
gas (Rule48)
• Prior approval for alterations in the licensed premises (Rule53)

5. The Petroleum Act,1934 & Rules, 2002

• Approval of containers of petroleum (Rules 4,5,6) and approval of tank vehicles (Rule
63)
• Approval of the design & route of pipelines (Rule89)
• Approval of the additions and alterations in the pipelines (Rule97)
• Approval of Refinery (Rule163)
• Approval of smoking zone (Rule171)
• Approval of equipment meant for blending tetraethyl lead (Rule182&183)

62
 • License of vessel for carriage of petroleum in bulk by water (Rule33), License for
transport in bulk class A&B by road (Rule75), License of premises meant for loading
and unloading (Rule76), License for storage of petroleum(Rule116), Approval of
specifications & plans of premises proposed to be licensed for imported storage
(Rule131)
• Approval for alteration in licensed premises (Rule147)

6. The Environment (Protection) Act,1986 and Rules framed thereunder

• The Environmental Clearance from the Department of Environment of concerned
State Govt./ Ministry of Environment and Forests, Govt. of India. (As per EIA
notification under Rule 5 of the EP Rules,1986).
• Approval and notification of site by the occupier of MAH installation (Rule7 of MSIHC
Rules,1989). (Rule13 of MSIHC Rules,1989), Information to be given to person
liable to be affected by a major accident (Rule15).
• Preparation and submission of safety report and preparation of on-site emergency
plan (Rules10 and13 of MSIHC Rules,1989)
• Authorization for handling bio-medical waste and operating biomedical waste facility
[Rule10of the Bio-Medical Waste Management Rules, 2016]
• Permission to store bio-medical waste for a period of more than 48 hrs. [Rule 8(7) of
Bio-Medical Waste Management Rules, 2016]
• Registration of importers and recyclers of used Lead Acid Batteries (Rule 5&8 of
Batteries (Management and Handling) Rules, 2001)
• Authorization for handling hazardous wastes(Rule 5 of the Hazardous Wastes
(M.H&TM) Rules,2008]
• Grant of authorisation for managing hazardous and other wastes [Rule 6 of the
Hazardous Wastes (M&TM) Rules,2016]
• Permission to import or export of hazardous wastes [Rule12-14 of the Hazardous
Wastes (M&TM) Rules,2016]
• Approval for design & layout of treatment, storage and disposal facility for hazardous
wastes [Chapter IV, Rule16ofHazardousWastes(M&TM)Rules,2016]
• Registration of manufacturers and recyclers of plastic carry bags [Rule9 of The
Plastic Waste (M&H)Rules, 2011].

7. The Water(Prevention & Control of Pollution)Act,1974

• Consent for establishment and operation of any industry, operation or process (Sec.25)

8. The Air (Prevention & control of pollution) Act, 1981

• Consent for establishment or operation of any industrial plant (Sec.21)
9. The Public Liability Insurance Act, 1991&Rules
• Taking one or more insurance policies by every owner handling hazardous
substances(Sec.4)
• Contribution by the owner to the Environmental Relief Fund (Rule11)

10.The Insecticides Act,1968 & Rules1971

• Registration of insecticides (import or manufacture) (Sec.9 & Rule 6)
• License to manufacture, sell, stock, exhibit for sale or distribute o r to undertake
commercial pest control operations (Sec.13&14& Rules9&10).Amendment &Transfer of
license(Rules13&14)
• Approval of package(Rule17), Approval of leaflet and Label(Rule18)

63
11. CEA Regulations 2010
• Keeping of records and inspection thereof (Chapter II, Rule 8) Central Electricity Authority
(Measures relating to Safety and Electric Supply) Regulations, 2010.
• Deposit of maps (Chapter II, Rule 9) Central Electricity Authority (Measures relating to
Safety and Electric Supply) Regulations, 2010.
• Deposit of printed copies(Chapter II, Rule 10) Central Electricity Authority (Measures
relating to Safety and Electric Supply) Regulations, 2010.

Guidance to check
1) Ensure the compliances of all the above applicable statutory requirements and their
validity period.
2) Check the conditions mentioned in the licenses/approvals and insure their compliances.
3) Particularly check the various reports of the competent person such as lifting tackles,
pressure vessels and see any comments or instructions put by the competent person and
verify with the concern about measures taken.

n) MOTIVATIONAL AND PROMOTIONAL MEASURES FOR OH & S

Introduction

Various studies have revealed that a “motivated” person works more effectively with observance
of safe practice than someone who is uncommitted and unwilling. Many of the problems faced at
work are connected with lack of motivation, and therefore some understanding of the
motivational aspect of human behaviour helps in management of OSH.

In recent years more emphasis is given on Behaviour Based Safety (BBS) and one of the
methods which can help in getting the positive safe behaviour is Motivation. There are ways to
motivate the workers in the industry such as training & education and also by effective use of
safety promotional measures.

Safety Promotional measures include activities such as participative safety activities, safety
suggestion schemes, safety contests, safety posters, safety awareness programs. Individual and
group Safety awards also help in motivating an employee for increasing his safety performance.
Appreciation by way of praising and recognizing the safety efforts of individuals improves safety
behaviour satisfying need for recognition.

Legal requirements

The following statutes have the provision of motivational and promotional measures.
• The Factories Act, 1948 and the State Rules made there under
• The Building and Other Construction Workers (Regulation of Employment and Conditions of
Service ) Central Rules,1998 and the State Rules
• The Central Electricity Authority (Safety Requirements for Construction, Operation,
Maintenance of Electrical Plants and Electric Lines) Regulations, 2011

Motivation for Safety

Motivation is a process by which a need is aroused and satisfied. It is a sort of inner urge or drive
or impulse, which causes behaviour. Motivation for safety cannot be disassociated from
motivation to work because better Job performance and better safety performance are usually
correlated. The theory of “Need Hierarchy” (Maslow 1954) postulated that human needs are

64
arranged in order of hierarchy-physiological, safety, social, ego and self-actualisation. The
Motivation Hygiene Theory (Herzberg 1959) suggest that there are two distinct group of factors
e.g.:
i) Hygiene factors, which include company policy, working conditions salary, supervision,
welfare facilities.
ii) Motivators which include achievement, recognition, advancement and job itself. According
to this theory, absence of hygiene factor will cause dissatisfaction but their presence will not
cause satisfaction or motivation. To motivate, the motivators must be present. Quite often it is
observed that in spite of having knowledge about safety rules and regulations, people follow
short-cut methods involving in accidents. Accidents statistics seldom reveals individual
experience about accidents in majority of cases and one may go on taking risks with the
belief that accidents occur to other and not to self. This risk taking behaviour can be
understood in terms of the individual’s motivational dynamics. It may be noted that most of
the factors influencing individual’s efforts towards better safety performance depends on the
work environment and workers attitude towards risks and moulds their behaviour. Some
specific work environment factors relating to safety performance are payment system,
importance given to safety performance by the management, conflicting goals of production,
safety, maintenance departments, work organisation in terms of providing need satisfaction.
Quite often it is observed that two contrary systems in the work environment control the
behaviour of workers and they opt for compromises which are exhibited in their behaviour
and that such behaviour will be usually risk taking.

The fundamental assumption of behavioural science is that man is not careless, negligent,
irresponsible and unconcerned for safety. Man is born with self-reservation instinct to save his
life and property.

Management System

According to leading behavioural scientist (Resins Likert) there are four management systems as
follows:
i) Authoritarian
ii) Benevolent Authoritarian
iii) Consultative
iv) Participative

It has been found that the greater the Management system is participative, the higher will be the
motivation and better will be safety performance.

There are six Parameters for Management System

i) Leadership
ii) Communication
iii) Motivation
iv) Decision Making
v) Goal Setting
vi) Control.

Reasons for Maintaining Interest

i) Accident prevention basically depends upon the desire of people to work safely.
ii) Each employee is frequently required to use his own imagination, common sense and self-
discipline to protect himself. He should, therefore, be stimulated to think beyond his
immediate work procedures in order not put to safety in questionable situation.
iii) Just as most products and services require steady and imaginative sales promotion, safety
also requires constant and skilful promotion.

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iv) Supervisors and worker are accustomed to the modern techniques of advertising and sales
promotion. So the basic element of accident prevention can be made more understandable
and acceptable if they are presented in a similarly interesting fashion.

Indications of need for a Programme

i) Increased Accident Rates

ii) Housekeeping is deteriorating
iii) Disregard or indifference or helplessness towards the suggestions of the safety engineer.

Programme Objectives and Benefits

A well-planned programme can create and maintain interest in safety.

Benefits

1) Helps developing safe work habits and safe attitudes, but it cannot compensate for
unsafe conditions and unsafe practices.
2) Focuses attention on specific causes of accidents, although by itself it cannot
eliminate them.
3) Supplements safety training, yet it cannot be considered a substitute for a good
training programme.
4) Gives employee a chance to participate in accident prevention activities.
5) Provides a channel of communication between workers and management.
6) Improves employee, customer and public relations,

Problems in the Way of Motivation

1) Size of organisation.
2) Nature of work
3) Performance can be bought with money.
4) The law cannot achieve peoples’ co-operation.

Some basic human interests

1) Tasteful use of appeal
2) Material featuring children and animals.
3) Use of humour with telling effects; the humour should have a light touch, it should be
good nature and it should not ridicule.
4) A positive and constructive approach is generally better than a negative approach.
5) Variety is essential. Safe practices should become routine, but their presentation
should not be.

Promoting Workers’ Interest

A successful safety programme requires cooperation, teamwork, interest, and enthusiasm on the
part of all employees. Every normal person had a desire to belong to, or be a part of an
organisation as a group, and a group that is interested in safety.

Basic Factors that influence Actions of People

Fear of personal Injury

No one wants to be injured. Employees need to be informed about hazards and told how these
hazards can results in injury.

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Fear of Economic Loss

Employees used to be advised of an economic losses that results from injuries. Beside from
physical suffering due to injuries, there are also wage losses, possible loss of future earning
power and the threat to family, well-being and security.

Desire for Reward

Everyone appreciates being recognised for his accomplishments. By rewarding workers for good
safe work, extended period of work without injury, and other safety accomplishments, their
interest can be aroused and maintained.

Desire for Leadership

Some employees have a greater desire and ability for leadership than others. Those who have
this specific desire should be used to guide and be exampled to others in promoting the safety
program.

Desire to Excel and be Outstanding

This factor can be used in contests to many kinds where individuals and group can prove that
they excel in preventing accidents.

Protection of Others

No other wants intentionally or unintentionally to cause injury to a fellow worker or an innocent

bystander. Workers need to be shown that if they cause an accident, or set a poor example, it
might result in injury to themselves or to others.

Example by Management

Any management regardless of the size of the organisation, can eliminate the majority of its work
injuries. Most injuries result from a combination of physical hazards and human error which easily
can be corrected. The correction will usually prevent injury. Safety performance requires that all
physical hazards be reduced to the minimum and every means to be taken to control bad habits
and practices. Suggestions for accomplishing this would include:

− Providing safe physical, mechanical and chemical work environment.

− Providing safe work methods, processes, and procedures.
− Providing necessary training and qualified supervision.
− Providing protective devices and equipment’s.

Example by supervision

Supervisors are the key to the control of work methods and practices. They can promote safety
with the men under them by the example shown in their own attitude toward safety. Some
methods used successfully to promote safety are as follows:

• Giving safety instruction for each job.

• Setting a good example by wearing personal protective equipment or clothing,
and by following safe procedures.
• Requesting worker to do job safely and to use protective equipment.

67
Education and Training

The more one knows about safety, the safer he acts.

The knowledge of how to reach and maintain top
safety performance is available. Training in safe
work practices is essential to good work
performance. To be effective, a regular program of
safety training should be established.

Promotional Methods

Safety Meetings - Meetings are so widely used as to

be considered essential to an effective safety
programme. A great variety of interest creating
activities such as, safety play, talks, demonstrations
are used. They are helpful if properly used.

Safety Contests - One of the oldest and most widely

used means of promoting safety interest and effort is
the safety contest. It is extremely important that
contest rules be clear and definite and as far as
possible known to all contestants. The purpose of the contest must never be forgotten.

Bulletin Boards Every establishment, regardless of size, should have one or more bulletin
boards. It is important that the board will be, attractive, well finished, and properly maintained.
− Material should be arranged neatly, and outdated material to be removed regularly.
− Posters and notices should be rotated often.
− Lighting should be good.
− The board should be located where they can be easily seen by all employees.

Publications - House journals are valuable for providing safety material when it is new,
interesting, and suitably written. Material should be pertinent to condition, and timely put.

Signs and Slogans - These are widely used to promote safety. Properly used, they give an
instant message, emphasizing an attitude of readiness to do everything possible to prevent work
injuries. They should be:
− Simple
− Definite as to meaning
− Eye catching

Safety Posters – Display of safety posters can reach a large audience with brief, simple
messages designed to convey information, to change attitude and to change behaviour. Such
posters have great value in safety programme. These posters are used to remind employees to
work safely, suggest behaviour patterns that prevent accidents.

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Guidance to Check Compliance (Documentary evidence)

1) Ensure the compliances of all above applicable statutory requirement

2) Does the organization have any OHS suggestion schemes?
3) Details of awards received by the company
4) Details of safety contests organized in the factory.
5) Annual appraisal forms.
6) Safety and health literatures e.g. Pocket books/in house Newsletters/ etc.
7) Safety days/safety week any other SHE related promotional activity reports and
photographs.
8) What is the percentage of workers participating in various safety promotional activities?
9) How is the OHS information including accident statistics disseminated in the factory?

o) HAZARD IDENTIFICATION & JSA

Introduction:

A critical part of any safety and health program is the identification, assessment, elimination and/
or the control of hazards in the workplace. It is impossible to eliminate all hazards, so the goal is
to reduce and/or control the hazards with critical and high potential and manage the hazards to
the lowest reasonable risk level so as to protect workers from harm. This process is called risk
assessment.

Risk management is a four step process i.e. i) identify hazards in the workplace, ii) assess the
risk of those hazards iii) implement control measures, which will eliminate or minimise the risk
due to the identified hazards and iv) periodically review the control measures which have been
put in place.
Legally the onus to manage the risk at the workplace is placed on the management. Hence,
management has to implement risk management programme in the organization effectively.

Background:
Risk Assessment is a systematic method for identifying hazard in each activity of process and
evaluating the potential risks to reduce / minimize up to acceptable level.

The Risk assessment broadly includes:

• Hazard Identification and Risk Assessment (HIRA) / Qualitative Risk Analysis
• Quantitative Risk Analysis (QRA)
• Job Safety Analysis (JSA)
• Hazard and Operability Study (HAZOP)
• Safety Report
• PHA Study / FMEA Study

69
Legal Requirements

SN Legislation Section / Rule Provision

1. The Factories Act, Sec. 7-A : General Provide and ensure risk free
1948 Duties of the Occupier environment to the workers at
workplace.
Model Rules under Rule 7 (e) – Safety Discussing reports on safety,
the Factories Act Committee – Prescribed environmental and occupational health
1948. under Section 41 and 41 surveys, safety audits, risk assessment
G of The Factories Act, and disaster management plans and
The Model Rules 1948. implementation of the recommendations
have been framed by made in the reports.
DGFASLI. Based on Rule 82A (11.2) – Site Enclose a copy of the report on Risk
these model rules, Appraisal Committee Assessment study.
State Factories Rules Rule 82B (5) – Relevant techniques and methods, such
has been prepared concerning Health and as safety audits and risk assessment for
by respective States, Safety Policy – periodical assessment of the status on
hence the state Prescribed under health, safety and environment and
factory rules of the Section 7A(3), 41B(2) taking all the remedial measures.
states have similar and 112 of The
provision, however Factories Act, 1948
the rule number may Rule 82G (a) : A report on status relating to risk
be different. concerning Disclosure of assessment and environmental impact
Information to District assessment and the measures taken for
Emergency Authority: prevention of accidents.
2. The Building and Rule 39 - Health and techniques and methods for
Other Construction Safety policy assessment of risk to safety, health and
Workers‘ (Regulation environmental and remedial measures
of Employment and therefor;
Conditions of
Service) Central
Rules, 1998
3. The Manufacture, Rule 10 – Safety For new and existing industrial activity
Storage and Import Reports and Safety safety report to be prepared by the
of Hazardous Audit Reports occupier as per the content specified in
Chemical Rules, Schedule 8 of the Rule and submit to
1989 the authority.
Items 5 and 7 under the schedule are
related to hazard analysis and
assessment.
Guidance for compliance:

Aspect to be Reviewed

1) Whether there is a system of Hazard Identification in the establishment?

2) Are all the hazardous activities/operation identified?
3) Whether planning has been made to prevent these hazards and minimize the risk?
4) Does the company use Risk analysis technique?
5) Are all the hazardous activities/operation identified?
6) Is there any measure or step taken to reduce the risk?
7) Whether Hazard and Operability Study (HAZOP) is carried out for the chemical
processes?

70
 8) In case toxic or hazardous chemicals are used, does the company carried out
Consequence analysis and Quantitative Risk analysis?
9) Does the recommendation in Consequence analysis /Risk Assessment being used for
better safety systems?
10) Whether Safety Report as required under MSIHC Rules has been prepared and updated
and its copy has been submitted to the concerned authority.

Documents to be checked:

1) Verify the documents of Hazard Identification [HAZOP, HIRA (Qualitative risk analysis)
etc.]
2) In case of Chemical /Process Plant having toxic and flammable chemicals –
Consequence analysis report / Quantitative risk analysis Report and Safety Report.
3) Check the status of implementation of the recommendations of the above mentioned
techniques/methods by HIRA Register, etc.
4) Safety Report as required under the MSIHC Rules.

JOB SAFETY ANALYSIS

A job safety analysis is a technique that focuses on job tasks as a way to identify hazards before
they occur. It focuses on the relationship between the worker, the task, the tools, and the work
environment. Ideally, after identify uncontrolled hazards, the steps to be taken to eliminate or
reduce them to an acceptable risk level.

Why is job safety analysis important?

Many workers are injured and killed at the workplace every day. Safety and health is the
important feature and add value to the business, job and life. It can help prevent workplace
injuries and illnesses by looking at workplace operations, establishing proper job procedures,
and ensuring that all employees are trained properly.

One of the best ways to determine and establish proper work procedures is to conduct a job
safety analysis. A job safety analysis is one component of the larger commitment of a safety
and health management system.

What is the value of a job safety analysis?

Supervisors can use the findings of a job safety analysis to eliminate and prevent hazards in
their workplaces. This is likely to result in fewer worker injuries and illnesses; safer, more
effective work methods; reduced workers’ compensation costs; and increased worker
productivity. The analysis also can be a valuable tool for training new employees in the steps
required to perform their jobs safely.

For a job safety analysis to be effective, management must demonstrate its commitment to
safety and health and follow through to correct any uncontrolled hazards identified. Otherwise,
management will lose credibility and employees may hesitate to go to management when
dangerous conditions threaten them.

What jobs are appropriate for a job safety analysis?

A job safety analysis can be conducted on many jobs in workplace. Priority should go to the
following types of jobs:

71
  Jobs with the highest injury or illness rates;
 Jobs with the potential to cause severe or disabling injuries or illness, even if there is no
history of previous accidents;
 Jobs in which one simple human error could lead to a severe accident or injury;
 Jobs that are new to operation or have undergone changes in processes and procedures;
and
 Jobs complex enough to require written instructions.

Legal Requirements

SN Legislation Section / Rule Provision

1. The Factories Act, 1948 Sec. 7-A : General Provide and ensure risk free
Duties of the Occupier environment to the workers at
workplace.
Model Rules under the Rule 7 (e) – Safety Discussing reports on safety,
Factories Act 1948. Committee – environmental and occupational
Prescribed under health surveys, safety audits, risk
The Model Rules have Section 41 and 41 G assessment and disaster
been framed by of The Factories Act, management plans and
DGFASLI. Based on 1948. implementation of the
these model rules, State recommendations made in the
Factories Rules has been reports.
prepared by respective Rule 82B (5) – Relevant techniques and methods,
States, hence the state concerning Health such as safety audits and risk
factory rules of the states and Safety Policy – assessment for periodical
have similar provision, Prescribed under assessment of the status on health,
however the rule number Section 7A(3), 41B(2) safety and environment and taking
may be different. and 112 of The all the remedial measures.
Factories Act, 1948
2. The Building and Other Rule 39 - Health and techniques and methods for
Construction Workers‘ Safety policy assessment of risk to safety, health
(Regulation of and environmental and remedial
Employment and measures therefor;
Conditions of Service)
Central Rules, 1998

Guidance for compliance:

Aspect to be Reviewed
1) Whether the activities requiring Job Safety Analysis been identified?
2) Whether the Job Safety Analysis has been carried out for the identified jobs?
3) Whether the checklists have been prepared on each Job Safety Analysis and are being
used while carrying out the job?
4) Is there any measure or step taken to reduce the risk?

Documents to be checked:

1) Verify the documents of Hazard Identification ( required for JSA)

2) Check the status of implementation of the recommendations mentioned in JSA.

72
p) PRODUCT SAFETY (INCLUDING MSDS)

Introduction:

Many of the industries supply dangerous machines and hazardous products/articles to the
customers for their use. During the use of such machines, goods and chemicals the customers
are exposed to the hazards associated with them. Therefore, the customers are required to know
the hazards, risks and precautions to be taken while handling them.

Background:

As per Section 7 A (2) (c) of the Factories Act, 1948 and as per Rule 17(2) of the Manufacture
Storage and Import of Hazardous Chemicals Rules, 1989, the occupier who has a control over
industrial activity in which a hazardous chemical is handled, should arrange to obtain or develop
information in the form of Material Safety Data Sheet and same should be supplied to customer.
Further the section 7B of the Factories Act also places certain duties on the manufacturers,
designers, suppliers of articles for use in factories.

Legal Requirements :

SN Statute Section / sub- Provisions

section
1 The MSIHC Rule number Collection, development and dissemination of
Rules,1989 17 (2) information
2 The Rule number Occupier should provide information to the workers
Maharashtra 4 (2) (b) (ii) including antidotes necessary to ensure their safety
Factories General and health
(Control of responsibility
Industrial Major of Occupier
Accident
Hazard) Rules,
2003
3 Model Rules, Rule 82 C- The occupier of every factory carrying on hazardous
DGFASLI Collection, process should arrange to obtain or develop
development information in respect of every hazardous substance
and in the form of Material Safety Data Sheet as
dissemination prescribed.
of information Further every container of hazardous substance
should be clearly marked or labeled with certain
information for identification.
4 Model Rules, Rule 82 D Every Safety Data Sheet of Hazardous Chemicals
DGFASLI Disclosure of should reveal the potential Hazards of the chemical,
information to safe practices and engineering control to minimize /
workers control the hazards. The data sheet shall include the
following information, as per Annexure- 3

73
S Statute Section / Provisions
N sub-section
5 The Explosive Rule 14 No person shall import, export, tender for transport, cause
Rules, 2008 Packing of to be transported, possess or sell any explosive unless –
Explosives o it is packed in the manner laid down in Schedule II;
o the container or package is marked in accordance with
rule 15;
o the packages conform to the relevant standard of
Bureau of Indian Standards or other standards
accepted and approved by the Chief Controller;
packages of explosives for export or import conform to the
requirements of the tests as specified for various
classifications under International Maritime Dangerous
Goods Code (hereinafter referred to as the IMDG Code in
these rules) or International Air Transport Authority code or
United Nations recommendations on the transport of
Dangerous Goods and permitted by the Chief Controller:
Provided that nothing in this rule shall apply to explosives in
the process of manufacture.

The firecrackers for export purpose shall have different

colour packing and shall carry a declaration printed thereon.
“Not for sale in India. Only for export”.

For the purpose of requirements of clause (c), container or

package shall be tested in the Departmental Testing Station
or other Testing Stations recognized by the Chief Controller.
For testing in the Departmental Testing Station, fees as
specified in Part 2C of Schedule IV shall be payable.

An explosive which is not an authorised explosive but which

is required to be transported for the purposes of test in
connection therewith shall be packed in such manner as
may be directed by the Chief Controller.
Rule 15 Marking on packages: The outer package shall be marked
Marking on in conspicuous indelible character, by means of a stamping,
explosives embossing or painting with:
and o the word “EXPLOSIVES”;
Packages o the name of authorised explosive;
o the number if any of the Class and the Division
including sub-division to which it belongs;
o the safety distance category of explosive;
o the name of the manufacturer;
o identification number of the package;
o the net weight of explosives;
o gross weight of the package;
o date of manufacture and batch number;
o UN Classification and UN Identification number (for
export packages);

74
S Statute Section / Provisions
N sub-section
6 The Rule 15 o in case of plastic explosives, the words “marking agent
Explosive Marking on added as per International Civil Aviation Organisation
Rules, 2008 explosives Resolution A 27-8” referred in sub-clause (iv) of clause (c)
continued and under sub-rule (2) of rule 10; and
Packages o a paper slip containing the above details shall be kept
inside the package : Provided that in the case of safety
fuse or fireworks, clauses (a) and (l) may be omitted and
the words “safety fuse” or “Fireworks” shall be marked.

In case of fireworks, the names of the items, for example -

amorces, paper caps, serpents eggs etc. as appropriate shall
be marked.

Every manufacturer shall on the box of each fire cracker shall

mention details of its chemical content, sound level and that it
satisfies requirements as laid down by the Chief Controller.
Firecracker meant for export shall have a different colour
packing from those intended to be sold in India and a clear
print indicating that they are not to be sold in India
Marking on explosives of Class 2 and Class 3.— In the case of
explosives of Class 2 and Class 3, each of the cartridges or
primary containment of explosives shall be printed or
embossed legibly on it with—
o the word “EXPLOSIVES”;
o the name of explosives and in case of plastic explosives
additional words ‘marking agent added’;
o weight of explosive;
o diameter of the cartridge;
o name of manufacturer; and
o in case of permitted explosive, the letter P1, P3 or P5 as the
case may be.

Marking on explosives of Class 6.—In the case of explosives

of Class 6 Divisions 2 and 3 the name of the manufacturer in
full or abbreviated form shall be printed or embossed legibly on
every metre or on every piece, as the case may be. The
abbreviated form, if used, shall be registered with the Chief
Controller.

Marking on fireworks—In case of fireworks, explosive

composition, quantity of such composition, whether sound
emitting crackers or colour or light emitting crackers, sound
level, a caution or warning indicating the name of the item,
manufacturer’s name, method of firing and precautions to be
taken both in words and pictorial view shall be printed on each
piece of fireworks and cardboard box and where adequate
space is not available on the fireworks, such caution or
warning shall be printed on a separate label and inserted in the
smallest packet or carton.

75
S Statute Section / Provisions
N sub-section
7 The Rule 15 Marking on other classes of explosives. Explosives of classes
Explosive Marking on other than those mentioned in sub rules above shall be
Rules, 2008 explosives marked as directed by the Chief Controller.
continued and
Packages Defacing of marking prohibited. No person shall alter or deface
any printing or marking on the explosives or packages thereof.

Guidance to Check Compliances

1) Whether hazards arising from use of the products are identified?

2) Whether material safety data sheet prepared for the products?
3) Are all the products labelled and packed appropriately?
4) Whether safety instructions are given along with products?
5) Whether dangerous machines manufactured as per the standards?
6) Whether particulars of dangerous machines have been marked on the machine?
7) Whether operational manual has been supplied to the customer?

q) SAFETY TRAINING

Introduction
Workers need to understand and apply the safety procedures, proper tools and protective
equipment for performing specific tasks as part of their job. They also require training in how to
rectify hazards that they observe. Similarly, supervisors and managers must be aware of the
physical, chemical and psychosocial hazards present in their workplaces as well as the social,
organizational and industrial relations factors that may be involved in the creation of these
hazards and in their correction. Thus, education and training of all employees is a first step in
engaging them in discharging their OSH responsibilities effectively. The statutes also require
occupiers/employers to provide and make adequate arrangements for training of all workers.
Such trainings are to be imparted on regular basis either in-house or can be arranged outside.
Certain jobs or responsibilities require concerned employees to under-go specific training related
to OSH.

The management should identify the training needs for all types of employees based on proper
assessment. Programmes should be designed on the principles of adult learning with right mix of
theoretical and practical inputs. The impact of training should also be assessed using in-process
and end of process techniques as well as on the job evaluation. Schedule of training programmes
should be prepared on annual/quarterly basis along with the target participants and their
numbers, responsible personnel, venue, faculty and budget requirement. Proper records of all
training programmes conducted in-house as well as list of personnel under-gone training out-side
should be maintained.

76
Legal obligations

The following are the obligations on the management for providing training to the employees.

S Statute Section / Provisions

N sub-section
1 The Factories Section Occupier to provide information, instruction, training and
Act, 1948 7A(2-c) supervision necessary to ensure the health and safety of
workers under section
Section The occupier of a hazardous process industry to disclose
41-B information regarding dangers, health hazards and the
measures to overcome such hazards associated with
handling of the materials or substances to workers and
general public in the vicinity
Section Every worker has a right to get trained either within the
111(A) factory , or, at a approved training centre/ institute
State Rules have also provisions related to training and education to all
workers like informing meaning of each term used in MSDS, measures
taken to prevent injury, PPE, meaning of various labels & marking used on
container, role of worker vis-a-vis the emergency plan, etc
2 The CEA Regulation 6 Engineers, supervisors and Technicians engaged for
Regulations, operation and maintenance of electric plants should have
2010 successfully undergone the type of training
Regulation 7 Owner of every transmission or distribution system should
arrange for training of personnel engaged in operation and
maintenance either in-house or at any recognized
institute
3 The Building Rule 39 Management should make arrangements for training of
and Other building workers, trainers, supervisors or other persons
Construction engaged in the construction work
Workers‘
((Regulation of
Employment
and Conditions
of Service)
Central Rules,
1998
4 The Insecticides Rule 42 The manufacturers, distributors of insecticides and operators
Rules, 1971 to arrange for suitable training in observing safety
precautions and handling safety equipment provided to
workers
5 The Rule 4 Occupier to provide to the persons working on the site with
Manufacture, the information, training and equipment including antidotes
Storage and necessary to ensure their safety
Import of
Hazardous
Chemicals
Rules 1989
6 Hazardous and Rule 6-b The occupier of the facility to provide persons working in the
Other Wastes site with appropriate training, equipment and the information
(Management necessary to ensure their safety
and Tran
boundary
Movement)
Rules 2016

77
S Statute Section / Provisions
N sub-section
7 Atomic Energy Rule 7 In respect of license for operation of a radiation installation
(Radiation the workers must have appropriate training and instructions
Protection) in radiation safety
Rules, 2004
8 The Central Rule 9 The drivers engaged in transportation of hazardous
Motor Vehicles materials by Road has to complete the 3-day training course
Rules, 1989

OSH Training

The organisations should develop training programme after the assessment of current capability
against the required competency profile. An organization should also establish and maintain
documented procedures for evaluation of training provided to its workers and its effectiveness.

• Training Coverage

A health and safety training programme should cover but are not limited to the following
aspects:

a) Health and safety policy of organization

b) Way in which health and safety is organized in the workplace.
c) Health and safety procedures in the organization,
d) Specific hazards and risk controls,
e) OH&S legislation and
f) Emergency procedures.

• Training Target Groups

A training programme may need to address a number of target groups including;

a) Senior management;
b) Line mangers/supervisors;
c) Employees;
d) Those with specific responsibilities (first aid, fire, safety committee members, etc.)
e) Sub-contractors;
f) Operators who require certificates under legislation; and
g) Site visitors.

• Training Records

Training records should normally include:

a) Information about those who have been trained,

b) What the training course covered,
c) When the training took place,
d) Who provided the training, and
e) Feedback from trainees.

• Training Operational Cycles

OH&S training is typically provided at certain key times in an operational cycle including:

78
 a) at induction for new employees,
b) when employees are transferred to new jobs,
c) on movement into managerial or supervisory positions,
d) on engagement of sub-contractors,
e) when modification in the system is carried out, and
f) after a time gap as a refresher training as per organisation’s policy

Guidance for auditing

The following information to be sought and verified during the audit:

1) Is there any training department?

2) Whether training needs have been identified?
3) Is there any programme of induction training, its duration and topics covered?
4) Duration of induction training for each category of employees and contents.
5) Whether the assessment of the trainee worker is done or not?
6) What infrastructural facilities with audio-visual support are available for training?
7) Do the programmes cover the plant safety rules, hazard communication and any other
special safety rules or procedures unique to the plant or specific departments?
8) Whether the training programmes are conducted in the local language?
9) Are all the employees trained and what is the frequency of such training?
10) Do the training programmes cover safety and health aspects and if so how much (in
terms of number of sessions/hours) ?
11) Do the trained supervisors train their own employees in safety and health aspects?
12) Is the retraining performed whenever new hazards/process changes are followed/
introduced?
13) How are the senior management personnel trained in safety and health?
14) How many employees have been trained in safety and health in the last five years ? Give
break up with details.
15) How many man-days/hours are used in training the employees?
16) How do you ensure that the training is put to use by the employees trained in safety and
health.
17) What is the training plan for the next two years? obtain details.
18) What documentation system has been established regarding safety and health training?

r) CHANGE MANAGEMENT
Incidents and accidents especially the well-known major accidents like Flixborough (UK),
Seveso (Italy) and Bhopal (India) have shown that the effects of process / plant malfunction may
not only be hazardous to operators but also catastrophic to human life, environment and property.
The need for modification may arise from the physical ageing of plant systems, structures and
components or past incidents or accidents within the plant or change in regulatory requirements,
or changes in expected performance of the plant. The timing of a plant modification must be
integrated into the operational schedule of the plant. Some modifications can stretch over several
years, where parts of the modification project are implemented during extension or expansion of
the current plant. Some minor modifications may be implemented during plant operation, but such
cases should be scrutinized even more carefully, because they may increase the likelihood for
disturbances. In spite of careful planning of plant modifications, changes to the plans are often
required. Good industry practice requires that process and plant modifications should not be
undertaken without having undertaken a safety, engineering and technical review.

Process or Plant modification is an integral part of Occupational Health and Safety Management.
An organization’s OH&S management system can translate its intentions to prevent incidents into
a systematic and ongoing set of change in processes and can reinforce the organization’s

79
commitment to proactively improving its OH&S performance. One of the most infamous process
industry accidents of the 20th Century, the Flixborough disaster, that was caused by an
insufficiently analysed modification to the existing plant . Most companies usually adopt internally
developed plant modification procedures that have been developed through,(i) Corporate history
and experience;(ii) Good industry practice; (iii)Input from Safety, Health and Environmental
department; (iv)Input from Operations department;(v)Input from Technical department; (vi)Input
from engineering department.

Legal Requirements:
Sr. Statute Section/sub- Provisions
No. section /
rule/sub-rule
1 The Factories Act, Sec 7A (2) The provision, maintenance or monitoring of such
1948 (e) working environment in the factory for the workers
that is safe, without risks to health and providing
information to workers which are necessary to ensure
health and safety of all workers at work.
The manufacturer should ensure, so far as is
Sec 7B (1) reasonably practicable, that the article is so
designed and constructed as to be safe and without
risks to the health of the workers when properly used.
2. Model Rules Rule 4 Permission in writing should be obtained from
under The the State Government or the Chief Inspector in case
Factories Act, of plant modification.
1948.
3. The Maharashtra Rule 3 An application for obtaining previous permission for
Factories Rules. factory extension shall be made to the CIF as made
1963 in Form I.
Rule 73 (L) The OH&S Policy should cover the modification /
expansion of the plant.
4. Central Electricity Rule 4 The Owner shall establish a sound and scientific
Authority management system to establish procedures to
Regulations, 2011 identify hazards that could give rise to the potential of
(Construction, injury, health impairment or death and measures to
Operation and control impact of such hazards.
Maintenance of
electric plants &
electrical lines)
5. The Petroleum Rule 162 The design and layout approval of facilities / process
Rules, 2002 units in new crude oil refineries shall be as approved
by Chief Controller of Explosives.
6. The Static Mobile Rule 33 A certificate of safety in the proforma prescribed by
Pressure Vessels the Chief Controller and signed by a competent
(Unfired) Rules person shall be furnished to the licensing authority
2016 before any vessel is used for the storage of any
compressed gas or whenever any addition or
alteration to the installations or foundations for the
vessel is carried out.
6 The Manufacture, Rule 4 , The occupier who has control of industrial activity
Storage and shall provide evidence that he has identified and
Import of taken adequate steps to prevent major accident
Hazardous hazards (release of toxic chemicals/explosion/fire).
Chemicals, 1989 Rule 11 All the plant modifications should be taken into
account in the Safety Report.

80
Guidance to check compliance:

During the Audit of a plant/site, as an Internal Auditor the following points needs to be checked for
Process / Plant Modification:
• Whether there is a system of change management and written procedure for effecting any
change in the existing plant, equipment or process?
• Whether safety aspects are also the part of plant modification procedure?
• Whether the P&I diagrams and other related documents are updated accordingly?
• Whether the system of change of management is documented and information is shared?
• Whether there is a system of training of employees in case of change in the existing plant/
equipment or process?

81
 A-2 PHYSICAL HAZARD

a) Housekeeping
b) Machine and general area guarding
c) Material handling
d) Electrical safeguarding
e) Safety in storage and warehousing
f) Hazard assessment of new equipment
g) Hazards from radiation sources
h) Control measures for specialized industrial hazards like work at height and
work in confined space

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a) HOUSEKEEPING

Introduction:
Good housekeeping can eliminate some workplace hazards and help get a job done safely and
properly. Poor housekeeping may frequently contribute to accidents by hiding hazards that cause
injuries. If the sight of paper, debris, clutter and spills is accepted as normal, then other more
serious health and safety hazards may also be taken for granted. Housekeeping is not just
cleanliness. It includes keeping work areas neat and orderly; maintaining halls and floors free of
slip and trip hazards; and removing of waste materials (e.g., paper, cardboard) and other fire
hazards from work areas. It also requires paying attention to important details such as the layout
of the whole workplace, aisle marking, the adequacy of storage facilities, and maintenance. Good
housekeeping is also a basic part of accident and fire prevention. Effective housekeeping is an
ongoing operation, it is not a hit-and-miss clean-up done occasionally. Periodic "panic" clean-ups
are costly and ineffective in reducing accidents.

Poor housekeeping can be a cause of accidents, such as:

• Tripping over loose objects on floors, stairs and platforms

• being hit by falling objects
• slipping on greasy, wet or dirty surfaces
• striking against projecting, poorly stacked items or misplaced material
• cutting, puncturing, or tearing the skin of hands or other parts of the body on projecting
nails, wire or steel strapping

Good housekeeping results in:

• reduced handling to ease the flow of materials

• fewer tripping and slipping accidents in clutter-free and spill-free work areas
• decreased fire hazards
• lower worker exposures to hazardous substances (e.g. dusts, vapours)
• better control of tools and materials, including inventory and supplies
• more efficient equipment clean-up and maintenance
• better hygienic conditions leading to improved health
• more effective use of space
• reduced property damage by improving preventive maintenance
• improved morale improved productivity (tools and materials will be easy to find)

Background :

There are several requirements relating to housekeeping, orderliness in different statutes. It is the
duty of occupier to provide and maintain the places of work safe and free from any health hazards
to workers. The manager of a factory is required to maintain the records relating to the conditions
of workplaces and working environment. Even the workers are required to maintain the facilities
provided for their safety in proper manner and do not act in a manner which will make these
facilities unsafe. The some statutes require certain specific places of work to be maintained in
proper order.

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Legal Requirements :

Sr. Statute Section/ Sub Provision

No. Section/ Rule/
Sub Rule
1. The Factories Act Section 11 Every Factory shall be kept clean and free from
1948 effluent arising from any drain, privy or other
nuisance and in particular removal of accumulated
dirt, cleaning of floor, proper provision for draining,
painting of walls, doors and window frames- once in
5 years etc.
Section 19 Latrines and urinals shall be maintained in a clean
and sanitary condition. Sweepers must be employed.
Section 20 Spittoons must be maintained in clean and hygienic
condition.
Section 32 Floors, Stairs, & Means of Access: All floors , steps,
Stairs and Gang ways must be free from
obstructions and substances likely to cause person
to slip.
Section 38 Precaution in case of Fire:- the factory must provide
and maintain safe means of escape for all person in
event of fire.
Section 42 Washing facility provided to worker shall be kept
clean
Section 47 Shelters, rest room and lunch room must be kept in
clean condition.
Section 48 Creches: It must be adequately lighted and ventilated
and maintained in a clean and sanitary condition.
2. The Model Rule Rule 68 Fire Exits sufficient to provide safe escape of the
under Factory Act occupants in case of fire or other emergencies shall
1948 be provided and must be free from any obstruction.
Factory must provide un obstructed access to fire
fighting equipment’s. No material of flammable
nature shall be allowed to accumulate on floors and it
shall be removed at least once in day, or shift or
most often and must be kept in suitable metal
container.
3. The Petroleum Schedule 119. Cleanliness of installation, service station or storage
Rule 2002 shed: The ground in the interior of an installation or
service station and the protected areas surrounding
any installation, service station or storage shed shall
be kept clean and free from all vegetation, waste
material and rubbish.
4. The BOCW Act Section 34 Accommodation: After the completion of construction
1996 activity, the employer shall, at his own cost remove
or demolitions of the temporary structures erected by
him for the purpose of providing living
accommodation, cooking place or other facilities to
the building workers and restore the ground in good
level and clean condition.
Section 35 Creches: It must be adequately lighted and ventilated
and maintained in a clean and sanitary condition.

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Sr. Statute Section/ Sub Provision
No. Section/ Rule/
Sub Rule
5. The Rule 5 Duties and responsibilities of employers, employees and
BOCW others: It shall be the duty of the employer to maintain the
Central latrines, urinals, washing facilities and canteen in a clean and
Rule hygienic condition. The canteen shall be located in a place
1998 away from the latrines and urinals and polluted atmosphere and
at the same time be easily accessible to the building workers.
Rule 8 Duties and responsibilities of workers: It shall be the duty of a
building worker to keep the latrines, urinals, washing points,
canteen and other facilities provided by the employer for
securing his welfare in a clean and hygienic condition.
Rule 243 Latrine and urinal accommodation:
Every latrine or urinal shall be adequately lighted and shall be
maintained in a clean and sanitary condition at all times.
Every latrine or urinal other than those connected with a flush
sewage system shall comply with the requirements of the public
health authorities.
The water shall be provided by means of a tap or otherwise so
as to be conveniently accessible in or near every latrine or
urinal.
The walls, ceilings and partitions of every latrine or urinal shall
be whitewashed or colour-washed once in every period of four
months.
Rule 244 Canteens: The canteen shall be maintained in a clean and
sanitary condition; waste water from such canteen shall be
carried away in suitable covered drains and shall not be
allowed to accumulate in the surroundings of such canteen,
suitable arrangements shall be made for the collection and
disposal of garbage from such canteen.

Guidelines for checking compliance:

1) Whether the drain cover or grating is provided on Drain?
2) Whether there is any designated walk way or aisles marking carried out on shop floor?
3) Whether the walkways are free from obstructions or spillage of materials or chemicals?
4) The condition of floor, walls, Ceiling, window panel etc of plant are they clean or painted
at regular intervals?
5) Whether the Fire exits are free from obstructions?
6) Whether the approach to fire fighting equipment’s is approachable?
7) The condition of Latrines, urinals, spittoons, crèches, shelter, rest room, lunch room &
their cleaning schedule?
8) Whether the storage area around Flammable, Hazardous Chemical and Gases are free
from all vegetation, waste material and rubbish?
9) Is there a system to deal with the spillage?
10) Are sufficient disposable bins provided? Are they clearly marked? Are they suitably
located? Are containers of refuse (waste) & trash emptied at the end of every day or soon
after they are full? Are the containers or bins regularly cleaned?
11) Are drip trays positioned wherever necessary?
12) Any inter-departmental competition for good housekeeping organised?
13) Are good housekeeping practices and standards made known to the employees?
14) Are there any working conditions, which make the floors slippery?
15) Does the company have adequate measures to suppress polluting dust arising out of
materials stored in the open?

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Documents to be checked:

Spill control procedures.

House-keeping competition records
Waste collection and disposal procedure

b) MACHINE AND GENERAL AREA GUARDING

Introduction:
Machines are used to change the shape and form of materials, which the human body cannot
do. Whenever man and machine meet, the possibility of accidents is always there. Some
statistics shows that nearly one-third of reportable accidents in factories are due to machinery –
whether it is moved by power or operated manually. Statistics also shows that number of
accidents due to fall/trip/slip because of unguarded floor opening, means of access etc. are also
high. In order to make the workplace safe it is necessary to provide safeguard.

Background:

For an accident to take place from a machine part two things should happen together, one the
person is in contact with the machine and the moving part of the machine is unguarded. The aim
of machine guarding is that these two things do not take place simultaneously. In other words, a
machine guard is a barrier or device to prevent a person or his clothing coming in contact with the
dangerous parts of the machinery.

The legal aspects are mentioned in Section 7A and Section 21 under the Factories Act
1948. To maintain the safe guarding on machinery, the Specification for principles of
mechanical guarding of machinery is mentioned in IS 9474:1980.

The aspects for providing safeguard to “Floors, stairs and means of access” is mentioned in
section 32 under the Factories Act 1948. IS 4912: 1978 describes about “the requirement for
floor and wall openings, railing and toe-boards”. that the checking of all the floors, steps, stairs,
passages and gangways with sound Construction to be done and also properly maintained.

Legal Requirements:
The appropriate sections and rules with provisions of the particular legislation, those have
requirements for machine and general area guarding, are listed below:

Sr. Legislation Section/sub- Provisions

section / Rule /
No.
sub-rule /
Regulation
1 The Sec. 7 A Occupier has to ensure the health, safety and welfare of all
Factories workers while they are at work in the factory.
Act, 1948 Sec. 7 A (a) Occupier has to ensure the provision and maintenance of
plant and systems of work in the factory that are safe and
without risk to health
Sec. 7 A (c) Occupier has to ensure the provisions of information,
instruction, training and supervision to ensure the health
and safety of all workers at work
Sec. 7 A (d) Occupier has to ensure the maintenance of all places of
work and the provision and maintenance of such means of
access to, and egress from, such places as are safe and
without such risks

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 Sr. Legislation Section/sub- Provisions
section / Rule /
No.
sub-rule /
Regulation
1 The Sec. 21 In a factory the machinery shall be securely fenced by
Factories safeguards of substantial construction and safeguards shall
Act, 1948 be maintained and kept in position while the machine is in
motion or in use.
Sec. 22 (a) for all machinery driven by power and installed in factory
shall be encased or effectively guarded as to prevent danger
Sec. 22 (2) No woman or young person shall be allowed to clean,
lubricate or adjust any part of a prime mover or of any
transmission machinery while in motion
Sec. 23 No young person shall be allowed to work at any machine,
unless he has been fully instructed as to the dangers arising
in connection with the machine and the precautions to be
observed
Sec. 28 In every factory, the cage of every hoist or lift used for
carrying persons shall be fitted with a gate on each side from
which access is afforded to a landing
Sec. 32 In every factory, all floors, steps, stairs, passages and
gangways shall be of sound construction, properly
maintained, and kept free from obstructions and substances.
It is also necessary to ensure safety, steps, stairs, passages
and gangways shall be provided with substantial handrails
and fenced.
2. The Model Rule – 61 A In a factory fencing of machines and Safeguards and safety
Rules devices in respect of all machines referred to in Schedule to
made rule 57 shall be provided.
under the
Factories
Act
3. The BOCW Sec. 40 (i) At construction site, safeguarding of machinery shall be
Act, 1996 available for each moving machine
4. The BOCW Rule 8 No building worker, shall remove or interfere with any
Rules, fencing, gangway, gear, ladder, hatch covering, life-saving
1998 appliances, lighting or other things
Rule 37 Fencing of motor to be done at construction site
Rule 65 (b) The employer shall ensure at a construction site of a building
or other construction work that hoist shafts are provided with
rigid panels or other adequate fencing
Rule 66 The employer shall ensure at a construction site of a building
or other construction work that safe means of access is
provided to every part of a lifting appliance and the
operator‘s platform on every crane or tip driven by
mechanical power is securely fenced and is provided with
safe means of access and where access to such platform is
by a ladder.

Guidance to check the compliance:

While checking the compliance regarding machine guarding and general area guarding in line
with the statutory requirement, an auditor should check the following points

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 1) Whether machinery and equipment which can cause physical injuries to workers have
been identified?(document check)
2) Whether Dangerous & Moving Parts of transmission machinery, electric generators,
motors, couplings and other machinery are adequately guarded?(Field observation)
3) Are all fixed guards securely bolted in position and in good condition? ?(Field
observation)
4) Are all interlock guards for prevention of physical injury in good condition? ?(Field
observation)
5) Whether workers bypass the interlock guards (other than for maintenance work)? (Field
observation)
6) Are all emergency stop buttons and pull chord provided, clearly labelled and effective for
conveyer belts ?(Field observation)
7) Are the workers employed at moving machines aware of the danger of working with loose
clothing? ?(Field observation)
8) Are the openings where there is free fall hazard adequately covered or fenced securely?
?(Field observation)
9) Whether Pedestal grinding machine has Tool rests provided in front of the wheels
adjusted to a gap of not exceeding 3 millimetres or mm
10) A notice is displayed near the moving machines as per statutory provision u/s 30 of the
Factories Act, 1948.
11) Display of a notice on the use of safety goggles for grinding machines– where?
12) Ring test is carried out at the time of replacing grinding or abrasive wheels? (Field
observation)
13) Moving acrylic guards are provided on both the grinding wheels? (Field observation)
14) SOP displayed in local language? (Field observation)

c) MATERIAL HANDLING

MANUAL

Introduction:
Manual Material Handling is an important activity undertaken in almost all industries and it has
associated hazards. If we look into the accident statistics nationally and internationally we can
find that the one of the most common cause of accident is fall of substance and hit by object both
of which can happen during material handling. Moreover there are possibilities of occupational
illness too.

Background:

The circumstances in which workers carry and lift load manually can pose bodily injuries, muscle
pain, backache, stress to internal organs and also mental stress. To control these ill effects
manual material handling shall be executed safely.

88
Legal Requirements:

Sr. Statute Section / sub- Provisions

section / rule
No.
sub-rule
I The Factories Section 34 The maximum weight that can be lifted by adult male,
Act 1948 & female or young person as follows:
Sr Person Max. wt of material
Model Rules Rule 64 no article, tool or
under the appliance (in KGs)
Factories Act A) Adult male 55
1948
B) Adult female 30
The BOCW Rule 38
Rules 1998 C) Young person 30
(Male 15-18 yrs)
D) Young person 20
(Female 15-18 yrs)
E) Young person (Male 16
14-15 yrs)
F) Young person 14
(Female 14-15 yrs)

Guidance to check compliance

1) Whether workers are trained about the technique of safe material handling of lifting and
carrying?(document checking)
2) Whether workers are lifting heavy loads manually more than that stipulated in statutes? (Max.
weight of material for adult male and female are 55 Kg and 30 Kg respectively) (field
observation)
3) Whether appropriate PPEs (w.r.t hazards) are worn by workers during manual lifting
operation? (field observation)
4) Whether Workers engaged in the job of Manual Material Handling are made aware of the
hazards involved in the operation? Safety Induction Training and it is documented?
(document checking)
5) Whether workers are lifting with safe manual lifting techniques so that they do not suffer from
e.g. back-ache or sprain? (field observation)

MECHANICAL
Introduction:
Lifting machines and tackles are general term for any equipment that can be used to lift and
transport loads faster and easier – which human endeavour cannot. Mechanical material handling
involves machines and the correct way of operating it is important to maintain a safe workplace.
The related statutory provisions are given in the Factories Act (FA) 1948, the Model Rules (MR)
made under The Factories Act 1948, The Building and Other Construction Workers (BOCW) Act
1996 and the Central Rules 1998; the Dock Workers (Safety, Health and Welfare) Act and Rules
(DWR) etc.

Background:

Every factory premises, construction sites or temporary structures need mechanical devices such
as lifting tools and tackles for transporting material from one place to another. Even business

89
buildings, temporary structures, office, etc, need the help of lifting devices. However, during
mechanical lifting operations there are risks of accidents and these accidents may be severe in
nature. Hence to minimize its ill effects mechanical material handling should be performed in safe
manner.
Legal Requirements :
Sr. Statute Section / sub- Provisions
section / rule
No.
sub-rule
1 The Factories Section 28 • “Lifting Machine / appliances” - is a general term for any
Act 1948 & 29 equipment that can be used to lift loads – For eg. Crane,
crab, winch, pulley block, gin wheel, transporter or runway
etc.
• “Lifting Tackle / loose gears” - chain sling, rope sling,
and hook, shackle, swivel, coupling, socket, clamp, tray or
similar appliance, whether fixed or movable, used in
connection with the raising or lowering of loads with the
BOCW Central Rule 2 help of lifting machines.
Rules 1998 • Competent person (CP) – Competent person can be an
individual or an institution, based on the qualification of
persons and the facilities available to carry out the tests of
lifting machines. Role of CP is therefore a legal advisor to
the factory in respect of carrying test, examination and
inspection of lifting machines and tackles etc. CPs are
generally recognized by the Chief inspector for the
purpose of carrying out tests, examination and inspection
of chain, ropes, shackles, etc. in a factory under the
provision of the FA 1948. Based on the qualifications and
experience of persons employed in a factory and the test
facilities available in the factory, the persons within the
factory may also be declared as CP for the purposes.
• "Responsible person" means a person appointed by the
employer, the master of the ship, the owner of the gear or
port authorities, as the case may be, to be responsible for
the performance of a specific duty or duties and who has
sufficient knowledge and experience and the requisite
authority for the proper performance of the duty or duties.
2 The Factories Section 28 All lifts / hoist / lifting machine / chains / tackles should be of
Act 1948 & 29 good construction, sound material, adequate strength for
the purpose for which it is used and free from defect and
The BOCW Rule 55 should be maintained in good repair and working order.
Rules 1998
3 The Factories section 28 ✓ Every hoist way & lift way shall be sufficiently protected
Act 1948 by an enclosure fitted with gates and every such
enclosure shall be constructed as to prevent any person
or thing from being trapped between any part of lift and
hoist and any fixed structure and moving part.
✓ The maximum SWL to be plainly marked and no load
greater than this shall be carried.
✓ an efficient automatic device shall be provided &
maintained to prevent the cage from over-running.
4 The DWR 1990 Rule no. 41 As per the Dock Regulation Testing of lifting machines /
(1) & 47 (1) appliances and tackles / loose gears should be conducted
before make into use for 1st time and after that at least once
The BOCW Rule 56 in every period of 5 years. (as per SCHEDULE I)
Rules 1998

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Sr. Statute Section / sub- Provisions
section / rule
No.
sub-rule
5 The DWR 1990 Rule no. 41 Periodic examination by competent person:
(1) & 47 (1) ✓ For hoist & lift - examined once in 6 months
The FA 1948 Sect 28 ✓ Lifting machines / appliances - thorough examined once
in 12 months
The BOCW Rule 70(b) ✓ Lifting tackles / loose gears- thorough examination once
Rules 1998 in 12 months
✓ Maintaining a register of examination in prescribed
form.
6 The DWR 1990 Rule no. 41 thorough examination of chains once in every month by
(1) & 47 (1) responsible person
The BOCW
Act 1996 Sect 70(c)
7 The BOCW Act Sect 71 (a & The employer shall ensure at a construction site of a
1996 b) construction work that—
(a) no rope is used for building or other construction work
unless—
(i) it is of good quality and free from patent defects; and
(ii) in the case of wire rope, it has been tested and
examined by a competent person in the manner
specified in Schedule I annexed to these rules,
(a) every wire rope of lifting appliance or lifting
gear used for construction work is inspected by a
responsible person, once at least in every 3 months:
Provided that after any such wire is broken in such
rope, it shall thereafter be inspected once at least in
every month by the responsible person;
8 The FA 1948 Sect 29 ✓ Each lift, lifting machine / appliance & lifting tackle /
loose gears, chains, rope should be marked SWL with
The BOCW Sect 61 its identification no. which will relate with the number on
Act 1996 the certificate / register.
✓ A table showing the SWL of every kind and size of
chain, rope or lifting tackle in use should be displayed.
9 The DWR 1990 Rule 42 ✓ Every crane, if so constructed that the SWL may be
varied by raising or lowering of the jib or otherwise,
The BOCW Sect 57 shall have attached to it an automatic indicator of SWL
Act 1996 which shall also give a warning to the operator
wherever the SWL is exceeded. If it is not possible to
install an automatic safe load indicator, provision on the
crane of a table showing the safe working loads at the
corresponding inclinations or radii of the jib shall be
considered sufficient compliance.
✓ Cut-out shall be provided which automatically arrests
the movement of the lifting parts of the crane in the
event of the load exceeding the SWL wherever
possible.

91
Sr. Statute Section / sub- Provisions
section / rule
No.
sub-rule
10 The FA 1948 Sect 29 Any person below 18 years of age who is not trained
should not be permitted to do the following.
The BOCW Sect 64 (b & ✓ Operate any lifting machine.
Act 1996 c)
✓ Give signals to the operator of lifting machine.

11 The DWR Rule 54 Sect No Pulley blocks shall be used in dock work unless the sfe
1990 62 (b. iii) working load and its identification marks are clearly
The BOCW stamped / marked upon it.
Act 1996
12 The DWR Rule 56 No chain or wire rope shall be used in dock work with a
1990 knot in it.
Sect 76
The BOCW
Act 1996

Load against Angle - As the angle made by sling with the lifting object
decreases, the tension in the sling increases and some cases the tension
(load) in the sling crosses the SWL of the sling which causes breakage of
sling and then lead to accidents, hence to avoid accidents, for a particular
load as per the formation of angle made by the sling with the lifting object,
sling should be selected.

92
Guidance to check compliance
1) Whether Lifts are periodically inspected & tested by competent person, duly authorised
by DISH / CIF?(document check)
2) Whether Records of test reports are available in prescribed Form as given in the State
Factories Rules? (document check)
3) Whether a copy of the certificate recognizing the Competent Person by the CIF/DISH as
per the Factories Rules is available?(document check)
4) Whether there is display of SWL (Safe Working Load), ID No. on lifts?(field observation)
5) Whether Lifts are periodically inspected by the user department with the help of
checklist? (document check)
6) Whether a record / list of all the lifting machines and tackles in use is maintained?
(document check)

d. ELECTRICAL SAFEGUARDS

Introduction:

Use of electricity is versatile and universal. There is no appliance, household and

industrial activity where electricity is not used. As electricity is produced by flow of
electron, a charged particle- the hazard of using electricity also exists. In case the
electrical current comes across the human body more than the permissible value, its
damage potential is high. There can be a state of shock, burn, thermal burn or blast
injury. A small amount of electrical current can cause injury, even death. Currents
greater than 75 mA can cause ventricular fibrillation (rapid, ineffective heartbeat)
resulting in death in a few minutes unless a defibrillator is used. Hence there is a need
to have procedures and systems in place while working with electricity in order to
provide protection from the electrical hazard and to prevent injury.

Background:

Because of the versatility in its use, the statute “Central Electricity Authority (Measures
relating to Safety and Electric Supply) Regulations, 2010” are made applicable all over
India.

These regulations apply to all aspects of the use of electricity within the workplace from
electrical supplies to the use of electrical equipment. The Regulation place a duties on
employers, employees and the self-employed to:

• Have the electrical systems constructed in a way that prevents danger.

• Maintain their electrical systems as necessary to prevent danger.
• Have work on, use of, or closure of, electrical systems carried out in a way that
prevents danger.

Industries are legally responsible for ensuring that everyone working for them practices
safety.

93
Legal Requirements : (Applicable CEA Regulations 2010)

Subject Regulation number/Rule number

Qualified Persons CEA Regulation No.3
A supplier or a consumer, or the owner, agent or manager of mine,
shall designate persons for the purpose to operate and carry out the
work on electrical lines and apparatus.
Electrical Safety Officer CEA Regulation No.5
shall designate an Electrical Safety Officer for ensuring observance of
safety measures.
Training CEA Regulation No.7 (3):-
Owner of every transmission or distribution system shall arrange for
training of their personal engaged in the operation and maintenance.
Personal Protective CEA 19 Handling of electric supply lines and apparatus: -
Equipment
Every person who is working on an electric supply line or apparatus
or both shall be provided with tools and devices.
Restricted Area CEA Regulation No.18
The owner of every installation shall affix permanently in a
conspicuous position a danger notice.
Documentation CEA Regulation No.8.
Keeping of records and inspection of Electrical Inspection.
Earthing & Rubber Mat. CEA Regulation No.19:
All non-current carrying metal parts of switchgear and control panels
shall be properly earthed.
Display of instructions Instructions for the resuscitation of persons suffering from electric
for resuscitation of shock shall be affixed.
persons suffering from
electric shock
CEA Regulation No.44: • All conductors and apparatus are so placed as to be inaccessible
except to a designated person.
• Shall maintain safety clearances for electrical apparatus as per
Bureau of Indian Standard specification.
• Shall ensure that the windings of motors or other apparatus are
suitably protected so as to prevent danger.
Regulation No.37 In case of installations provided in premises where inflammable
flame proof electrical materials including gases and chemicals are produced, handled or
fitting stored, the electrical installations, equipment and apparatus shall
comply with the requirements of flame proof, dust tight, totally
enclosed or any other suitable type of electrical fittings depending
upon the hazardous zones as per the relevant Indian Standard
Specifications.( IS-5572: 2009 - Hazardous area classification)

Qualified Persons: - CEA Regulation No.3 -

• Owner shall designate persons for the purpose to operate and carry out the work on
electrical lines and apparatus.
• Shall maintain a register wherein the names of the designated persons and the purpose
for which they are engaged, shall be entered.
• Engineers and supervisors appointed - Diploma in Engineering from a recognized
institute, or a degree in Engineering from a university.
• The Technicians to assist engineers or supervisors - Two years course from a Industrial
Training Institute recognized by the Central Government or the State Government.

94
Electrical Safety Officer: - CEA Regulation No.5 –
• All suppliers of electricity including generating companies, transmission companies and
distribution companies shall designate Electrical Safety Officer Officer(s) for ensuring
observance of safety measures specified under these regulations in their organisation, for
construction, operation and maintenance of power stations, sub-stations, transmission
and distribution lines.
• The Electrical Safety Officer shall be an Electrical Engineering degree holder with at least
five years of experience in operation and maintenance of electrical installations.

Training: - CEA Regulation No.7 (3) –

• Engineers, supervisors and Technicians engaged for operation and maintenance of
transmission and distribution systems electric plants should have successfully undergone
the type of training as specified in Schedule-II of CEA Regulations.

General safety requirements pertaining to construction, installation, protection, operation

and maintenance of electric supply lines and apparatus:- CEA Regulation No.12 –
• All electric supply lines and apparatus shall be of sufficient rating for power, insulation
and estimated fault current and of sufficient mechanical strength, for the duty cycle which
they may be required to perform under the environmental conditions of installation, and
shall be constructed, installed, protected, worked and maintained in such a manner as to
ensure safety of human beings, animals and property.

Personal Protective Equipment: - CEA Regulation No.19 –

• Every person who is working on an electric supply line or apparatus or both shall be
provided with tools and devices such as gloves, rubber shoes, safety belts, ladders,
earthing devices, helmets, line testers, hand lines and the like for protecting him from
mechanical and electrical injury and such tools and devices shall always be maintained in
sound and efficient working condition.
• No person shall work on any live electric supply line or apparatus and no person shall
assist such person on such work, unless he is designated in that behalf.

Restricted Area:- CEA Regulation No.18 –

• The owner of every installation of voltage exceeding 250V shall affix permanently in a
conspicuous position a danger notice in Hindi or English and the local language of the
District, with a sign of skull and bones of a design as per IS -2551 on:- every motor,
generator, transformer and other electrical plant and equipment / all supports of overhead
lines etc.

Documentation: - CEA Regulation No.8 –

• The generating company or licensee shall maintain records of the maps, plans and
sections relating to supply or transmission of electricity and submit the same to the
Electrical Inspector for inspection as and when required by him.

Earthing and insulating floors:- CEA Regulation No.19 (5) –

• All non-current carrying metal parts of switchgear and control panels shall be properly
earthed and insulating floors or mat conforming to IS-15652: 2006, of appropriate voltage
level shall be provided in front of the panels for the safety of operating personnel.

Display of instructions for resuscitation of persons suffering from electric shock: - CEA
Regulation No.28 –
• Instructions, in English or Hindi and the local language of the District and where Hindi is
the local language, in English and Hindi for the resuscitation of persons suffering from
electric shock, shall be affixed.

95
Requirement of Flameproof fitting: - CEA Regulation No.37 (IV)-
• In case of installations provided in premises where inflammable materials including gases
and chemicals are produced, handled or stored, the electrical installations, equipment
and apparatus shall comply with the requirements of flame proof, dust tight, totally
enclosed or any other suitable type of electrical fittings depending upon the hazardous
zones as per the relevant Indian Standard Specifications.

Testing, Operation and Maintenance: CEA Regulation No.46-

• All apparatus, cables and supply lines shall be maintained in healthy conditions and tests
shall be carried out periodically as per the relevant code of practice of the Bureau of
Indian Standards.
• Records of all tests, tripping, maintenance works and repairs of all equipment’s cables
and supply lines shall be duly kept in such a way that these records can be compared
with earlier ones.

Earth leakage protective device: - CEA Regulation No.42-

• Shall be controlled by an earth leakage protective device so as to disconnect the supply
instantly on the occurrence of earth fault or leakage of current.

IS 5216: Recommendations On Safety Procedures and Practices In Electrical Work:-

(This standard ( Part I ) gives recommendations regarding safety procedures and practices which
should, be followed to the extent applicable in all major electrical installations, such as generating
stations, sub-stations, industrial establishments, transmission and distribution lines, and cable
networks)

Permit -To-Work System:-

All work on major electrical installations shall be carried out under permit-to-work system unless
standing instructions are issued by the competent authority to follow other procedures.
In all cases, the issue and return of permits shall be recorded in a special register provided for
that purpose.

Safety Instructions for Working on Apparatus:-

• Unless a person is authorized to work on live low and medium voltage mains and
apparatus, all mains and apparatus to be worked upon shall be isolated from all sources
of supply before starting the work, proved dead.
• Only competent, experienced and authorized persons shall work on live mains and
apparatus, and such persons should take all safety measures.
• Warning boards shall be attached on or adjacent to the live apparatus.
• It shall be ensured that no other live parts come within safe distance of a person working
on low and medium voltage mains so that he does not come in accidental contact with it
unless he is properly protected.

Guidance for auditing for Electrical Safeguarding:

1) Are licensed electricians available for electrical work?
2) Whether area classification for electrical equipment has been carried out?
3) Do the electrical fittings conform to area classification for electrical equipment?
4) Is a ground fault current interrupter system (ELCB) in use?
5) Are all connections made by using appropriate plugs, receptacles or enclosures? Are
fuses provided?
6) Are there any make shift connection bare wires or damaged cables?
7) Is there a system of ensuring periodical inspection of hand tools, extension boards used
for electrical work?
8) Do the workers use proper types of PPE during the working on live line?
9) Is the separate work permit issued for working on high voltage line?

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 10) Whether the process(s) and equipment that generate and accumulate static charge have
been identified?
11) Whether all such equipment including pipelines for flammable materials are properly
bonded and earthed?
12) Whether earth pit resistance is measured and the record maintained?
13) Whether lightning arrestor has been installed and is adequate?

e) SAFETY IN STORAGE AND WAREHOUSE

When material is stored in vessels in plants it must ensured it is safely stored as there are
statutory requirements for the same which are covered below.

Materials Storage and Warehouse Safety Best Practices must be given due importance.
Working in warehouses are exposed to hazards that can result in traumatic injuries,
musculoskeletal disorders or illnesses from exposure to harmful chemicals

Warehouse inspection checklists are an essential safety management tool. Because warehouse
workers increasingly face problems like increased exposure to repetitive motions and high-stress
environments, checklists are particularly useful in preventing bodily strain-related injuries.

Safety inspections can also improve the feedback loop between worker health and company
safety policies. Discover problem areas or hazard trends by evaluating all checklist reports over a
given timeframe.

Legal requirement

Sr. Statute Section/ Provision

No. Sub
Section/
Rule/ Sub
Rule
1 The Factories Sect 31 If in any factory, any plant or machinery or any part
Act 1948 thereof is operated at a pressure above atmospheric
pressure, effective measures shall be taken to ensure
that the safe working pressure of such plant or
machinery or part is not exceeded.
2 Model Rules Rule 62 a suitable safety valve or other effective
under the pressure relieving device of adequate capacity to
factories Act ensure that the max. permissible working pressure of
1948 the pressure vessel shall not be exceeded. It shall be
set to operate at a pressure not exceeding the max.
Permissible working pressure and when more than one
protective device is provided, one of the devices needs
be set to operate at the
max. Permissible working pressure and the additional
device shall be set to discharge at a pressure not more
than 5% in excess of the max. permissible working
pressure
In-service test and examinations
a) Every pressure vessel / plant in service
shall be thoroughly examined by a competent
person
(i) externally, once in 6 months;
(ii) internally, once in 12 months:
Provided that if by reason of the construction of a

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pressure vessel / plant, a thorough internal examination
is not possible, this examination may be replaced by a
hydrostatic test which shall be carried out once in every
period of 2 years.
Provided further that for a pressure vessel / plant in
continuous process which cannot be frequently opened,
the period of internal examination may be extended to 4
years.
b) The pressure for the hydrostatic test to be carried
out shall be 1.25 times the design pressure or 1.5
times the maximum permissible working pressure,
whichever is less.
6) Pressure vessel or plant being taken into use
(a). No new pressure vessel / plant shall be taken into
use in the factory unless it
has been hydrostatically tested by a competent
person at a pressure at least 1.3 times the design
pressure, and no pressure vessel / plant which has
been previously used or has remained isolated or idle
for a period exceeding 2 months or which has
undergone alterations or repairs shall be taken into use
in a factory unless it has been thoroughly examined by
a competent person externally and internally, if
practicable, & has been hydrostatically tested by the
competent person at a pressure which shall be 1.5
times the max. permissible working pressure :
Provided, however, that the pressure vessel or plant
which is so designed and constructed that it cannot be
safely filled with water or liquid or is used in service
when even some traces of water cannot be tolerated,
shall be pneumatically tested at a pressure not less
than the design pressure or the max. permissible
working pressure as the case may be
(b) No pressure vessel or plant shall be used in a
factory unless there has been obtained from the maker
of the pressure vessel or plant or from the competent
person a certificate specifying the design pressure or
maximum permissible working pressure thereof, and
stating the nature of tests to which the pressure vessel
or plant and its fittings (if any) have been subjected,
and every pressure vessel or plant so used in a factory
shall be marked so as to enable it to be identified as to
be the pressure vessel or plant to which the certificate
relates and the certificate shall be kept available for
perusal by the Inspector.
(c) No pressure vessel or plant shall be permitted to be
operated or used at a pressure higher than its design
pressure, or the maximum permissible working
pressure as shown in the certificate
A report of every examination or test carried out shall
be completed in Form 11 and shall be signed by the
person making the examination or test, and shall be
kept available for perusal by the Inspector at all hours
when the factory or any part thereof is working.

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 The Rule 70.3.a Protection from lightning shall be provided for
Maharashtra • building in which explosives or highly flammable
Factories Rules substances are manufactured, used, handled or
1963 stored
• storage tanks containing oils, paints or other
flammable liquids
Rule 70.5 The material susceptible to spontaneous ignition should
be stored in dry condition and should be in heaps of
such capacity and separated by such passage which
will prevent fire. The materials susceptible to ignition
and stored in the open shall be at a distance not less
than 10 meters away from process or storage buildings
Rule 70.5 Cylinders containing compressed gas may only be
stored in open if they are protected against variation of
temperature, direct rays of sun, or continuous
dampness. Such cylinders shall never be stored near
highly flammable substances, furnaces or hot
processes. The room where such cylinders are stored
shall have adequate ventilation
Rule 70.9 In case of those factories where high hazard materials
are stored or used, the travel distance to the exit shall
not exceed 22.5 meters and there shall be at least two
ways of escape from every room

GUIDANCE FOR AUDITING-SAFETY IN STORAGE AND WAREHOUSE

• Whether pressure vessels / plants are marked with the following details on their body, -
✓ Identification Mark,
✓ Max. Safe Working Pressure (SWP)
✓ Capacity (in ltr / m3)
✓ Test date
✓ Due date
• Whether pressure vessels are periodically inspected & tested by a competent person?
• Whether Records of test reports are available in the prescribed Form as given in the State
Factories Rules?
• Whether a copy of the Certificate recognizing the ‘competent person’ issued by the CIF/DISH
is available?
• Whether there is red marking of Max. SWP (Safe Working Pressure) on the pressure gauges?
• Whether the Material Safety Data Sheet for all chemicals is available?
• Are the chemicals stored as per their hazardous properties including the incompatibility?
• Are all containers clearly, permanently labelled? Are all chemicals stored as per safety
regulations?
• Whether all racks and steel cages have sufficient load bearing capacity?
• Is adequate natural ventilation provided to store room? Is there any emergency exit?
• Whether adequate firefighting arrangement existing in flammable chemical storage?
• Whether methodology for handling spillages of hazardous chemical available along with the
equipment required handling the spillage / secondary containment?
• Whether aisles are marked and emergency exits displayed?
• Whether Lightening protection provided for bldg. having explosives or highly flammable
substance stored?

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 f ) NEW EQUIPMENT REVIEW / INSPECTION

The purpose of a pre-start-up safety review of new equipment is to help ensure that adequate
safety measures are in place and are operational BEFORE new equipment is placed and taken in
operations .

The pre-start up review confirms that prior to the introduction of a new equipment
• Construction of equipment is in accordance with design specifications;
• Safety, operating, maintenance, and emergency procedures are in place and adequate
• For new equipment PHA has been performed and recommendations have been resolved
or implemented before the equipment arrives on-site;
• For modified processes, the Management of Change requirements have been met; and
• Training of each employee involved in handling the equipment has been completed.

Legal Requirements :

SN Legislation Section / Rule Provision

1 Model Rules Rule 82B – Health The occupier shall revise the Safety Policy as
under the and Safety Policy – often as may be appropriate, but it shall
Factories Act Point No. 8 - necessarily be revised under the following
1948. Prescribed under circumstances;
Section 7A (3), 41B (a) Whenever any expansion or modification
(2) and 112 of The having implications on safety and health of
Factories Act, 1948 persons at work is made; or
(b) Whenever new substance(s) or articles are
introduced in the manufacturing process having
implications on health and safety of persons
exposed to such substances.
2 The Rule 73. L.5 In particular, the Policy should specify the
Maharashtra following: -
Factories Rules stating its intention to integrate health and
1963 safety in all decisions including those dealing
with purchase of plant, equipment, machinery
and material as well as selection and
placement of personnel.
Rule 73. L.8.b The occupier shall revise the Safety Policy as
often as may be appropriate, but it shall
necessarily be revised under the following
circumstances, namely whenever new
substance (s) or articles are introduced in the
manufacturing process having implications on
health and safety of persons exposed to such
substances
Rule 73. T.2 In the event of any change in the process of
operations or methods or work or when any
new substance is introduced in the process or
in the event of a serious accident taking place,
the information so furnished shall be reviewed
and modified to the extent necessary

100
 GUIDANCE FOR AUDITING- new equipment

1) System of risk evaluation for an addition of any process/ equipment / material in

existing system. This system includes assessment w.r.t safety
2) JSA is carried out after installation new equipment
3) All recommendations mentioned by each concern department including safety are
being complied and then inspection report gets closed.
4) P&I diagrams and other related documents (like SOPs, block diagram, process flow
chart, etc.) are updated accordingly before making any change and relevant training
is given to the workers.
5) What is the system for effecting any change in the existing plant, equipment?
(document check)
6) Is there system for evaluating hazards from new equipment?
7) Whether the P&I diagrams and other related documents are updated accordingly?
8) Whether written procedure for new equipment review / inspection is available?
9) Is any Job Hazard Analysis (JHA) carried out after installation of new equipment?
10) Whether the review inspection Checklist includes inspection with respect to safety
aspects like Electrical, Mechanical, Fire protection, Industrial hygiene and Process
safety.

g ) HAZARDS FROM RADIATION SOURCES

Radiation is a type of energy, like heat or light, emitted through space and matter and which
cannot be detected by any of our senses.

The ionising radiation in the electromagnetic spectrum consists of Alpha, Beta & X-rays (Hard &
soft). Gama radiation and neutrons of various energy intensities. These are having a variety of
application namely Research, Military, Industrial and Medical. Radiation safety is ensured by
judiciously adjusting time, distance & shielding.

Causes of Radiation:
• Death
• Cancer
• Skin Burns
• Cataract
• Infertility
• Genetic effect

Legal Requirements and Best practices:

The Radiation Protection Rules, 1971 framed under the Atomic Energy Act, 1962
Some of the important definitions contained in Rule 2 are :
“Adequate Protection, contamination, employer, operational limits, radiation, surveillance,
Radiological Safety Officer”. (R.S.O.)

Rule 3 . No person shall handle any radioactive material except in accordance with the terms and
conditions of a license granted to him by the Competent Authority (C.A) i.e. Atomic Energy
Regulatory Board (AERB) of Central Government.

Rule 5. Prohibition of employment of persons below the age of 18 years.

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Rule 6. Conditions precedent for the issue of license: No license for handling radio active
material shall be granted unless, in the opinion of competent authority:
- the request for such license is for the purpose envisaged by act.
- the equipment, facilities and work practices afford adequate protection.
- the person in charge of the radiation workers possesses adequate qualification to direct the
work.

Rule 7. Period of validity of a license: Every license issued under these rules shall, unless
otherwise specified, be valid for three years from the date of issue of such license.

Rule 8. Power to revoke or modify a license: License can be revoked by the C.A or the terms
and conditions governing the grant of license can be modified by him if he considers so in public
interest in accordance with the procedures laid down in these rules.

Rule 9. Power to withdraw a license: If the provisions of these rules are contravened by
license in the opinion of the C.A, he may withdraw the license in accordance with the procedures.

Rule 12. Radiological Safety Officer: Every employer shall designate, with the approval of the
C.A., either himself or a person under his employment as R.S.O. who shall in addition to his other
duties, perform the duties and functions specified in Rule 13.

Rule 13. Duties and functions of Radiological Safety Officer: The duties and functions of
R.S.O. in any radiation installation shall be :

a) to take all necessary steps for ensuring that operational limits are not exceeded.
b) to instruct the radiation workers under his charge on the hazards of radiations and on suitable
safety measures and work practices aimed at minimising exposure to radiations &
contamination.
c) to carry out any leakage test on any sealed sources as per Rule 34.
d) to regulate the safe movement of all radioactive material, including wastes, within the area
under his charge.
e) to investigate and initiate prompt & suitable remedial measures in respect of any situation
that could lead to radiation hazards.
f) to ensure that reports on all hazardous situations including spillage control as per Rule 47 or
as laid down in the notification issued by the C.A. regarding operational limits along with
details of any immediate remedial measures that may have been initiated, are made available
immediately to his employer.
g) to ensure that ultimate disposal of waste, containing radioactive material is done in a manner
approved by the C.A.

Rule 14. Action to be taken by the employer in certain cases: When an employer receives a
report on any hazardous situation as provided under Rule 13 (f), he shall forthwith notify such
situation to the C.A.

Rule 15. Radiation Surveillance :The C.A. shall by notification, specify appropriate radiation
surveillance procedures and the employer shall comply with the same. The surveillance
procedures may provide for:

- The planning, design, construction and operation of facilities involving the use of radiation
shall be done with the prior approval of and in accordance with the specifications laid down
by the C.A.
- The working conditions adopted and the monitoring and PPE provided shall be in accordance
with the specifications laid down by the C.A.
- The radiation workers shall be subjected to personal monitoring procedures specified by C.A.

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- The radiation workers shall be subjected to medical examination as per Rule 19 or Rule 20.
- Appropriate records shall be maintained on the results of any routine measurements &
investigation such as radiation and radio activity level measurements, personal monitoring
measurements and medical records as stipulated by C.A.
- An employer shall comply with any other special or general radiation surveillance procedures
that may be specified by C.A.
-
Rule 16. Prior approval of the C.A. necessary in certain cases: Any modification to any
existing radiation installation or any change in the working conditions therein shall be done only
with the prior approval of the C.A.

Rule 18. Duty of the employer to maintain certain records of the radiation workers: Every
employer shall maintain upto date records of personal medical and occupational histories of every
radiation worker in such form as may be specified by the C.A.

Rule 19. Medical examination of radiation workers: Every radiation worker, prior to
commencing work and subsequently at intervals not exceeding 12 months, shall be subjected to
the following medical examinations, and any other examinations which may be specified by the
C.A.

a) X-ray examination of the chest.

b) All general laboratory investigations such as the examination of blood and excreta.
c) Special investigations such as examination of the skin, hands, fingers, nails and eyes.

Rule 20. Power of the C.A. to modify medical examination of radiation workers: The
frequency and type of medical examinations specified in Rule 19 may be modified by C.A. in
special case where such modifications is considered necessary.

Rule 21. Duty of the employer to maintain complete medical records. Employer shall
maintain complete records of medical examinations as per Rule 19 & Rule 20.

Rule 22. Duty of the employer to send certain records to the C.A. when asked for:
Employer shall send to the C.A. relevant excepts from the records maintained as specified in
Rule 15, Rule 16 or Rule 21 to the C.A. in the form specified by it.

Rule 23. Period of preservation of records: The C.A. shall maintain appropriate records
including personal monitoring measurements and medical examinations in respect of every
radiation worker for the period during which such worker is engaged in work involving exposure to
radiation and such records shall be preserved during the lifetime of such worker, or for 20 years
after he ceases to do work, involving exposure to radiation whichever is shorter.

Rule 24. Power of the C.A. to requisition such records: All appropriate records as preserved
similar to Rule 23 which may have been maintained by any person prior to coming into force of
these rules may be requisitioned by C.A.

Rule 25. Power of the C.A. to give directions in certain cases: If in the opinion of C.A. any
radiation worker has been subjected to radiation exposure in excess of the operational limits, the
C.A. may specify appropriate steps to be taken for the purpose of reducing the hazards and the
employer shall comply with all directions and orders of C.A.

Rule 26. Duty of the employer to give alternative work in certain cases: If a radiation worker
has to discontinue radiation work under the orders of C.A. in exercise of his powers as per Rule
25, the employer shall make every reasonable effort to provide such a radiation worker with
alternative work not involving exposure to radiation.

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Rule 27 & 28. Resumption of radiation worker: If a radiation worker is declared by C.A. as fit
to resume radiation work, the employer shall permit him to do so and such subsequent work with
radiation shall be as planned by C.A.

Rule 33. Sealed & unsealed sources: Every employer shall maintain or cause to be maintained
registers containing, inter-alia the following particulars in respect of radioactive materials in his
charge, namely:-

- the shape, size and distinguishing marks if any, of each sealed sources.
- the activity with the date of measurement, physical & chemical forms & dose rates, if any, at
specified distances along with the date of measurement of the various radioactive materials.
- the date of receipt of radioactive materials.
- quantity of radioactive materials in the working area.
- location of the various radioactive materials, disposed of wastes along with dates and any
other relevant date.
- details of quantities of radioactive materials disposed of wastes along with dates and any
other relevant date.
-
Rule 36. Loss of radioactive material: If any radioactive material is found missing, the
employer shall make immediate efforts to trace it, and the C.A. shall be informed immediately
about the loss.

Rule 40. Precautions to be taken by the medical institution in certain cases : Every medical
institution, where sealed or unsealed sources are used for treatment in such a manner that as a
result, the radioactive material remains on or inside the body of the patient, shall be provided
with:-

- separate rooms for carrying out the treatment.

- separate exclusive wards for patients so treated.
-
Rule 42. Precautions to be taken regarding a sealed source: Every sealed source used in
industrial devices such as static eliminators, thickness gauges, density gauges, package
monitors and level gauges shall be provided with adequate and efficient cover plate, shutter or
shield, capable of being easily, security and quickly operated in order effectively to alternate the
useful beam.

Rule 44. Unsealed sources to be securely closed: All containers containing unsealed sources
shall be securely closed for preventing the escape of the material inside and shall be securely
closed for preventing the escape of the material inside and shall be properly labelled.

Rule 46. Ventilation systems involving air borne contamination: All ventilation system
involving air borne contamination shall be provided with appropriate ducts & filters to avoid its
spread or dispersal of any airborne contamination.

Rule 47. Spillage of radioactive material: In the event of spillage of any radioactive material
resulting in personal or airborne contamination the R.S.O. shall:
- take steps to arrange for the immediate decontamination of affected personnel.
- take steps to prevent any further spread of contamination.
- arrange for immediate decontamination of affected areas.
- forthwith inform employer details of the incident & remedial measures initiated, if any for
immediate onward transmission to the C.A.

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AERB Standards
1. Safety Code for Industrial Radiography. (AERB/SC/IR-1)
2. Safety Guide on Radiological Safety in open field industrial Radiography. (AERB/SG/IN-2
1987)
3. Safety Guide on Radiological Safety in enclosed Radiography installations. (AERB/SG/IN-1
1986)
4. Safety Guide for handling Radiation emergencies in Industrial radiography. (AERB/SG/IN-3
1989)
5. Safety Guide on procedure forwarding transport, handling & storage of radioactive
consignments. (AERB/SG/TR-3 1991)

Guidance for auditing for Hazards from Radiation Sources:

1) Whether licenses have been obtained for storage / handling of radioactive material?
2) Whether approved Radiological Safety Officer appointed?
3) Whether appropriate PPEs are used against radiation hazards?
4) Is the flooring of the radioactive material handling area amenable for proper
decontamination?
5) Is the storage room of radiation source as per the licence condition?
6) Are all persons working in the facility have radiation safety training?
7) Is the operators handling devices using radioactive materials qualified and possess the
necessary certificate?
8) Is the periodical radiation monitoring carried out?
9) Are the records of inventory of radioactive material maintained in the standard format and
submitted to the competent authority as per the period specified?
10) Are emergency handling tools available?
11) Are the personnel monitoring badges (TLD, Pocket dosimeter etc.) assigned and worn by
each radiation worker?
12) Are the radiation symbol and red light displayed as required?

h) CONTROL MEASURES FOR SPECIALIZED INDUSTRIAL HAZARDS LIKE

WORK AT HEIGHT AND WORK IN CONFINED SPACE

Working at Height Hazards and Control Measures

Working at height remains one of the biggest causes of occupational fatalities and major injuries.
Cases commonly involve over-reaching, over-balancing or the failure of a fragile surface. Falls
from height can also be due to unguarded holes in floors such as hatchways, inspection holes
and pits, and from falls into process tanks and machinery. Other significant hazards associated
with working at height include falling objects and the potential for a working platform to collapse or
overturn as well as contact with overhead electrical services.

The exact height at which employers have to implement controls will vary from country to
country(it is between 1.8 to 3 Meters), but generally, work at height can be taken to mean any
work where, if there are no precautions in place, a person could fall a distance liable to cause
personal injury (through a fragile roof, for example). It should be remembered that access and
egress to a workplace could also constitute working at height.

Workers in maintenance and construction are particularly at risk, but many other people in a
variety of jobs could also be at risk of falling from height. Such professions include: painters,
decorators and window cleaners and those who carry out ad hoc work without proper training,
planning or equipment. Whatever the task, any working at height needs to be planned in

105
advance, with careful consideration given to the selection and use of work equipment and means
of escape in an emergency.

Work at height (where unavoidable) should preferably be carried out from the safety of a platform
with suitable edge protection in place, but sometimes this may not be possible. In such situations,
a ladder may have to be used; however, ladders are best used only as a means of gaining
access to and from a workplace. They should only be used at a workplace for light work of short
duration and only after careful hazard identification, risk analysis and planning.

If a fall from height does occur, the consequences will depend on many factors such as the
distance fallen, the nature of the surface landed on, how the person lands and the age and health
of the individual. The severity of the injury is increased for example, when the fall is into the path
of a moving vehicle (or machinery) or into a tank which contains a hazardous substance.

Where possible, working at height should be avoided, usually by carrying out tasks from the
ground. Some practical examples include using extendable tools to remove the need to climb a
ladder. Other examples include the installation of cables at ground level, lowering a lighting rig to
ground level or assembly of edge protection on the ground.

Where work at height cannot be avoided, an existing safe place of work should be used. These
workplaces (and means of access or egress) should:

• Be stable and of sufficient strength and rigidity for their purpose

• Rest on stable and suitably strong surfaces
• Be of sufficient size to allow safe use for persons, plant and material
• Have suitable means for preventing a fall
• Have a surface which has no gap through which a person or material could fall and cause
injury
• Be constructed, used and maintained to prevent the risks of slipping, tripping or any
person being trapped between them and any adjacent structure
• For working at height Workers should be Medically Fit ,it Means he should not have
high/low blood pressure, heart ailments, prone to epilepsy, prone to vertigo Workers
slated to work at height must be thoroughly examined by a doctor, who is having a min.
degree of M.B.B.S.

Working at confined space Hazards and Control Measures

Many workers are injured and killed each year while working in confined spaces. An estimated
60% of the fatalities have been among the would-be rescuers. A confined space can be more
hazardous than regular workspaces for many reasons. To effectively control the risks associated
with working in a confined space, a confined space hazard assessment and control program
should be implemented for your workplace. Before putting together this program, make sure to
review the specific regulations that apply to your workplace.

If the confined space cannot be made safe for the worker by taking precautions then workers
should NOT enter the confined space until it is made safe to enter by additional means. All
confined spaces should be considered hazardous unless a competent person has determined
otherwise through a risk assessment.

What is Confined Space?

Generally speaking, a confined space is a fully or partially enclosed space that: is not primarily
designed or intended for continuous human occupancy has limited or restricted entrance or exit,
or a configuration that can complicate first aid, rescue, evacuation, or other emergency response

106
activities Can represent a risk for the for the health and safety of anyone who enters, due to one
or more of the following factors:
• its design, construction, location or atmosphere
• the materials or substances in it
• work activities being carried out in it, or the
• mechanical, process and safety hazards present

Confined spaces can be below or above ground. Confined spaces can be found in almost any
workplace. A confined space, despite its name, is not necessarily small. Examples of confined
spaces include silos, vats, hoppers, utility vaults, tanks, water supply towers, sewers, pipes,
access shafts, truck or rail tank cars, aircraft wings, boilers, manholes, pump stations, digesters,
manure pits and storage bins. Ditches and trenches may also be a confined space when access
or egress is limited. Barges, shipping containers and fish holds are also considered as possible
confined spaces.

What are the hazards in a confined space?

All hazards found in a regular workspace can also be found in a confined space. However, they
can be even more hazardous in a confined space than in a regular worksite.

Hazards in confined spaces can include:

• Poor air quality: There may be an insufficient amount of oxygen for the worker to
breathe. The atmosphere might contain a poisonous substance that could make the
worker ill or even cause the worker to lose consciousness. Natural ventilation alone will
often not be sufficient to maintain breathable quality air.
• Hazards from asphyxiants – Simple asphyxiants are gases which can become so
concentrated that they displace oxygen in the air (normally about 21 percent). Low
oxygen levels (19.5 percent or less) can cause symptoms such as rapid breathing, rapid
heart rate, clumsiness, emotional upset, and fatigue. As less oxygen becomes available,
nausea and vomiting, collapse, convulsions, coma and death can occur.
Unconsciousness or death could result within minutes following exposure to a simple
asphyxiant. Asphyxiants include argon, nitrogen, or carbon monoxide.
• Chemical exposures due to skin contact or ingestion as well as inhalation of 'bad' air.
• Fire hazard: There may be an explosive/flammable atmosphere due to flammable liquids
and gases and combustible dusts which if ignited would lead to fire or explosion.
• Process-related hazards such as residual chemicals, release of contents of a supply
line.
• Physical hazards – noise, heat/cold, radiation, vibration, electrical, and inadequate
lighting.
• Safety hazards such as moving parts of equipment, structural hazards, engulfment,
entanglement, slips, falls.
• Shifting or collapse of bulk material.
• Barrier failure resulting in a flood or release of free-flowing solid or liquid.
• Visibility (e.g., smoke particles in air).
• Biological hazards – viruses, bacteria from faecal matter and sludge, fungi, or moulds

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How prepare confined space for entry

The important thing to remember is that each time a worker plans to enter any work space, the
worker should determine if that work space is considered a confined space. Be sure the confined
space hazard assessment and control program has been followed. Please see the OSH Answers
document Confined Space - Program for more information.

The next question to ask is - Is it absolutely necessary that the work be carried out inside the
confined space? In many cases where there have been deaths in confined spaces, the work
could have been done outside the confined space!

Before entering any confined space, a trained and experienced person should identify and
evaluate all the existing and potential hazards within the confined space. Evaluate activities both
inside and outside the confined space.

Air quality testing: The air within the confined space should be tested from outside of the
confined space before entry into the confined space. Care should be taken to ensure that air is
tested throughout the confined space - side-to-side and top to bottom. Continuous monitoring
should be considered in situations where a worker is in a space where atmospheric conditions
have the potential to change (e.g., broken or leaking pipes or vessels, work activities create a
hazardous environment, isolation of a substance is not possible). A trained worker using
detection equipment which has remote probes and sampling lines should do the air quality
testing. Always ensure the testing equipment is properly calibrated and maintained. The sampling
should show that:

• The oxygen content is within safe limits - not too little and not too much.
• A hazardous atmosphere (toxic gases, flammable atmosphere) is not present.
• Ventilation equipment is operating properly.

The results of the tests for these hazards are to be recorded on the Entry Permit along with the
equipment or method(s) that were used in performing the tests. Please see the OSH Answers
document Confined Space - Program for more information about entry permits.

Air testing may need to be ongoing depending on the nature of the potential hazards and the
nature of the work. Conditions can change while workers are inside the confined space and
sometimes a hazardous atmosphere is created by the work activities in the confined space.

The traditional hazard control methods found in regular worksites can be effective in a confined
space. These include engineering controls, administrative controls and personal protective
equipment. Engineering controls are designed to remove the hazard while administrative controls
and personal protective equipment try to minimize the contact with the hazard.

108
However, often because of the nature of the confined space and depending on the hazard,
special precautions not normally required in a regular worksite may also need to be taken. The
engineering control commonly used in confined spaces is mechanical ventilation. The Entry
Permit system is an example of an administrative control used in confined spaces. Personal
protective equipment (respirators, gloves, ear plugs) is commonly used in confined spaces as
well. However, wearing of PPE sometimes may increase heat and loss of mobility. Those
situations should be carefully evaluated. When using PPE, always use as part of a PPE program
and be sure to evaluate all possible hazards and risks associated with PPE use.

Natural ventilation (natural air currents) is usually not reliable and not sufficient to maintain the air
quality. Mechanical ventilation (blowers, fans) is usually necessary to maintain air quality.

• If mechanical ventilation is provided, there should be a warning system in place to

immediately notify the worker in the event of a hazard or a failure in the ventilation
equipment.
• Care should be taken to make sure the air being provided by the ventilation system to the
confined space is 'clean' throughout the entire space.
• Ease of air movement throughout the confined space should be considered because of
the danger of pockets of toxic gases still remaining even with the use of mechanical
ventilation.
• Do not substitute oxygen for fresh air. Increasing the oxygen content will significantly
increase the risk of fire and explosion.
• The use of mechanical ventilation should be noted on the entry permit.
• Ensure air being removed from the confined space is exhausted away from workers on
the outside.
•
Work where a flame is used or a source of ignition may be produced (hot work) should not
normally be performed in a confined space unless:

• All flammable gases, liquids and vapours are removed before the start of any hot work.
Mechanical ventilation is usually used to
• Keep the concentration of any explosive or flammable hazardous substance less than
10% of its Lower Explosive Limit AND
• Make sure that the oxygen content in the confined space is not enriched. Oxygen content
should be less than 23% but maintained at levels greater than 19.5%. (These numbers
can vary slightly from jurisdiction to jurisdiction.)
• Surfaces coated with combustible material should be cleaned or shielded to prevent
ignition.
• Do not bring fuel or fuel containers into the confined space (e.g., gasoline, propane), if
possible. Ensure welding equipment is in good condition.
• Where appropriate, use spark-resistant tools, and make sure all equipment is bonded or
grounded properly.

While doing the hot work, the concentrations of oxygen and combustible materials must be
monitored to make certain that the oxygen levels remain in the proper range and the levels of the
combustible materials do not get higher than 10% of the Lower Explosive Limit. In special cases it
may not be possible, and additional precautions must be taken to ensure the safety of the worker
prior to entering the confined space.

If potential flammable atmosphere hazards are identified during the initial testing, the air in the
confined space should be cleaned or purged, ventilated and then tested again before entry to the
confined space is allowed. Only after the air testing is within allowable limits should entry occur as
the gases used for purging can also be extremely hazardous.

109
All potentially hazardous energy sources such as electrical, mechanical, hydraulic, pneumatic,
chemical, or thermal must be de-energized (or isolated) and locked out prior to entry to the
confined space so that equipment cannot be turned on accidentally. If lock out is not possible, the
hazardous energy must be controlled in a way that eliminates or minimizes worker exposure to
the hazards before workers are allowed to enter the confined space. It is important that any
method of control other than isolation and lockout must be evaluated and the effectiveness for
controlling the hazardous energy must be demonstrated. Any other situations or hazards may be
present in a confined space. Be sure that all hazards are controlled, for example:

• Any liquids or free-flowing solids should be removed from the confined space to eliminate
the risk of drowning or suffocation.
• All pipes should be physically disconnected or isolation blanks bolted in place. Closing
valves is not sufficient.
• Use two blocking valves, with an open vent or bleed valve between the blocking valves
when isolating pipelines or similar conveyances to prevent entry of materials and
hazardous contaminants.
• A barrier is present to prevent any liquids or free-flowing solids from entering the confined
space.
• The opening for entry into and exit from the confined space must be large enough to
allow the passage of a person using protective equipment

Legal requirement

Factory Act Section 36 – Precautions against Dangerous Fumes, Gases etc. (Entry To Confined
Space )

• No person shall be required or allowed to enter any chamber, tank, vat, pit, pipe, flue or
other confined space in any factory in which any gas, fume, vapour or dust is likely to be
present to such an extent as to involve risk to persons being overcome thereby, unless it
is provided with a manhole of adequate size or other effective means of egress.
• A certification in writing (Permit) has to be given by a competent person, based on a test
carried out by himself that the space is reasonably free from dangerous gas fume, vapour
or dust.
• Such person should wear suitable breathing apparatus and a belt securely attached to
Rope, the free end of which is held by a person outside the confined space.

110
 A-3 CHEMICAL HAZARD

a) Transportation of hazardous substances

b) Handling of hazardous substances

c) Storage of hazardous substances

d) Spill control measures

e) Material Safety Data Sheet (MSDS)

f) Gas cylinders

g) Labelling and colour coding

h) Hazardous waste management

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a) TRANSPORTATION OF HAZARDOUS SUBSTANCES

Introduction:
Transportation of hazardous substance is one of the sub-elements of the Chemical Hazards
element, which needs to be audited by the auditor while auditing the regulatory compliance of an
Industry. The transportation of hazardous substances can be done by various modes such as
road, pipeline, rail, air, water or combination of these modes. The transportation by any mode has
a greater risk of accidental release than that of a static installation. Hence legal obligations are
placed on the owner of hazardous substance for its safe transportation.

Legal Requirements:
The appropriate sections and rules with provisions of the particular legislation, those have
requirements for safe transportation of hazardous materials, are listed below:

Sr. Legislation Section/sub- Provisions

No. section /
Rule/sub-
rule/Regulation
Transportation by Road
1. The Motor Sec. 14(2) (a) The validity of licence is for a period of three year and
Vehicles Act, its renewal is subject to the condition that the driver
1988 has undergone a one-day refresher course of the
(amended prescribed syllabus.
2019) Sec. 146 (1) In addition to normal vehicle insurance, the transporter
is required to take an insurance policy under the Public
Liability Insurance Act, 1991 for carrying dangerous or
hazardous goods.
The MV Rule 9 Educational Qualifications of Drivers – Driver to
(Central) undergo 3-day duration training course and after
Rules, 1989 successful completion the licensing authority endorse
in the driving license
Rules 129 Provide Class Labels and Tachograph: Display a
distinct class labels and provide a tachograph (an
instrument to record the lapse of running time of the
motor vehicle; time speed maintained, acceleration
and deceleration.
(Now days people are using GPS systems)
Rule 129-A Fitting of Spark Arrestor: Fitted with a spark arrestor at
an exhaust pipe.
Rules 131 to Responsibilities of Consigner, Transporter and Driver
133

Rules,-130, Requirement of Hazard Class Labels: Describes

134, 137 position of displaying the labels
Rule, 132 Requirement of Transport Emergency Card: Driver to
carry the card with him. (Annexure -6)
The vehicle is equipped with necessary first-aid, safety
equipment tool box and antidotes as may be
necessary to contain any accident.

Rule 134 Emergency Information Panel: Provide its location and

display. (Annexure –7)

112
Sr. Legislation Section/su Provisions
No. b-section /
Rule/sub-
rule/Regula
tion
The MV Rule 135 Driver to be Instructed : Owner to ensure that the driver
(Central) has received adequate instructions and training to enable
Rules, 1989 him to understand the nature of goods being transported
by him, the nature of risk, precautions to be taken and
actions to be taken in case of any emergency.
Rule 136 Driver to Report to the Police Station: In case of accident
inform to nearest police station and owner of the goods
carriage or the transporter.
Rule 137 Hazard Class Labels: Describes goods wise hazard class
labels. (Annexure-8)
2. The Petroleum Sec 27 Notice of Accident: In case of accident notify the same to
Act, 1934 the nearest Magistrate or to the Officer-in-Charge of the
nearest Police Station and to the Chief Controller of
Explosives (CCE), Nagpur.
The Petroleum Rule 72 Means of extinguishing fires to be carried: A portable fire
Rules, 2002 extinguisher suitable for extinguishing petroleum fire to be
kept in a vehicle an easily accessible position and away
from the discharge faucets (valves) on every vehicle
transporting petroleum by road.
Rule 73 Vehicle to be constantly attended: It should be attended by
at least one person who is familiar with the rules in Part IV
(i.e., Rules 62 to 86) of the Petroleum Rules, 1976.
Rule 74 Prohibition as to parking: It should not be parked on a
public road or in any congested area or at a place within 9
metres of any source of fire
Rule 199 Notice of accident: As required under Sec 27, inform to
CCE by telegram within 24 hrs and officer-in-charge of the
nearest police station by the quickest means of
communication.
3 The Sec 8 Notice of Accident: The person in-charge of the vehicle
Explosives (carriage), is required to give notice thereof and of the
Act, 1883 attendant loss of human life or personal injury, if any, to
the CCE and to the officer in-charge of the nearest police
station.

The Chapter VI : Special Provisions Under Rule 47: Procedure to be

Explosives Rules followed during transportation; Rule 48 Certificate of
Rules, 2008 47,48, 50, safety, Rule 50: Documents to be available during
62 and 69 transport; Rule 62 – Prohibition of transport within Streets,
Public places and other specified areas; Rule 69 –
Accident to the vehicle, etc have elaborated the safe
transportation of explosives by road.
4. Static and Rule 43 Certificate of safety: A Certificate of Safety in prescribed
Mobile proforma is required to be submitted to the licensing
Pressure authority (CCE) before any vehicle is used for the
Vessels transportation of any compressed gas to the effect that the
(Unfired) vehicle meets with the provisions of the SMPV Rules.
Rules, 2016
(SMPV Rules) Rule 44 Inspection and maintenance of vehicles: The licensee for
any vehicle is required to ensure that it is at all times road-

113
 worthy, and that it is in a fit condition to fill, transport and
discharge its load safely.
Rules 48 & Licence for transport of compressed gas: No compressed
49 gas filled in a vessel should be transported by a vehicle,
except under and in accordance with the conditions for a
licence granted under the SMPV Rules.
Rule 67 Recording of Incidents and Notice of accident: The notice
of an accident required to be given under Sec. 8 of the
Explosives Act, 1884 should be given forthwith to CCE by
express telegram followed within 24 hours by a letter
giving particulars of the accident; and the officer-in-charge
of the nearest police station by the quickest route.
The Gas Rule 3 Filling, possession, import and transport of cylinder: No
Cylinders transportation of cylinders unless to have the test and
Rules, 2016 inspection certificates issued by the inspecting authority in
respect of cylinder and its valve are made available to the
Chief Controller and prior approval of the said authority is
obtained.
Rule 10 Restriction on delivery or dispatch of cylinder : No one can
deliver or transfer the cylinders without license.
Rule 20 Loading, unloading and transport of cylinders or cascade:
Transported as proper manner listed in Schedule VI of the
Rule.
Rule 67 Notice of accidents: To be given to CCE by fax, email
followed by a letter, district authority and officer-in-charge
of the nearest police station by quickest mode of
communication.
5. The Rules 20 to A separate Chapter – V with provisions for transportation
Ammonium 24 of Ammonium Nitrate with procedures, gereral
Nitrate Rules, requirements with documents to be available during
2012 transportation, etc have been spelled out.
6. Public Liability Sec 4 Duty of the owner to take out insurance policies: Every
Insurance Act, owner is required to take out, before he starts handling any
1991 hazardous substance, one or more insurance policies,
providing for contracts of insurance whereby he is insured
against liability to give relief under Sec. 3.
7. Hazardous Rule 18 Transportation of Hazardous and Other Wastes –
and Other • The occupier to provide the transporter the relevant
Wastes information regarding the hazardous nature of the
(Management wastes and measures to be taken in case of an
and emergency and label the hazardous and other wastes
Transboundary containers.
Movement) • The responsibility of safe transport shall be either of
Rules, 2016 the sender or the receiver whosoever arranges the
transport and has the necessary authorisation for
transport from the concerned State Pollution Control
Board. This responsibility should be clearly indicated in
the manifest.
Other provisions regarding interstate transportation are
provided in the Rule.
8. Bio-Medical Rule 10 Authorization for transporting bio-medical wastes
Waste
Management
Rules, 2016

114
Transportation by Pipeline
1 MSIHC Rules 7 to 15 • Approval and notification of site (Rule 7)
Rules,1989 for column 3
and 4 of part • Prepare on-site emergency plan (Rule 13)
II of Schedule
3 • Provide information for preparing off-site emergency
plan to the authority [Rule 14(2)]

• Provide information to nearby community on measures

requires to be taken by them during emergency (Rule
15)

Rules 10 -12 Preparation of Safety Report and submit to the Authority

only for [Rule 10(3)]. Update it for any modification in the activity
column 4 of or within 3 years as per [Rule 11(1) and 11(2)
part II of respectively]
Schedule 3 Conduct Safety Audit with the help of outside expert and
forward it with comments to the authority and conduct
fresh audit every year [Rule 10(4)(5)&(6)]
2 PNGRB Act, Sec 16 Obtain authorization from PNGRB for laying or operating
2016 pipeline to carry petroleum products or natural gas.
PNGRB These These regulations cover the design, materials,
Regulations, regulations fabrication, installation, inspection and testing,
2008 apply to commissioning, operation, maintenance, modifications
petroleum and and abandonment of CGD network for domestic,
natural gas commercial and industrial users.
pipelines
Transportation by Rail
1. Railways Red Tariff No. 20 It describes all the rules/regulations regarding
Tariff Rules, transportation by Rail of explosives and other dangerous
2000 goods notified by the Central Government in exercise of
powers conferred by Sections 67 and 87 of the Railways
Act 24 of 1989 enforced from 16th August 2000.

Transportation by Air
1. IATA Air transport of dangerous goods is required to conform
Dangerous to the International Air Transport Association (IATA)
Goods Dangerous Goods Regulations which govern the
Regulations packaging and labelling of HAZCHEM.

A set of technical instructions for the safe transport of

dangerous goods by air was also issued by International
Civil Aviation Organization (ICAO) in 1982–83.

Transportation by Water
1. The Merchant Maritime transportation of dangerous goods follow The
Shipping Merchant Shipping (Carriage of Cargo) Rules, 1995,
(Carriage of under The Merchant Shipping Act, 1958, and the
Cargo) Rules, conventions of the International Maritime Organization
1995, under (IMO); Maritime Pollution (MARPOL) Conference; and
The Merchant Safety of Life at Sea (SOLAS) Convention.
Shipping Act,
1958

115
Guidance to check the compliance
Industrial units are not only the recipients but also the consignors of hazardous substances. It is
in their business interest that the goods dispatched, reach the destination safely, in time and
without any problem in route. Their role is most important in terms of improving the status of
implementing various legal requirements. Keeping this in mind, the following systems are
expected to be implemented by the industrial units. The auditors can check the following systems
in line with the above legislations for the compliance.

• What potentially hazardous materials are transported to or from the site (including
wastes)
• What mode of transport are used?
1) Road,
2) Rail, and
3) Pipelines

1) Road
• Does the company employ licenced vehicle of its own / outside sources?
• Are the loading / unloading procedures in place and safety precautions displayed?
• Is there a provision to check the healthiness of road tanker with respect to explosives rules?
• Are loaded tankers or trucks parked in a specific area on-site?
• Do all truck and tanker drivers carry transport emergency (TREM) card or instruction booklet?
• Do all truck and tanker drivers get training in handling emergencies during transport?
• Are all the tankers marked for proper Hazchem code?
• Checking of driver’s license and its validity, this provides a certificate to the effect that the
driver had successfully undergone the requisite training for transportation of hazardous goods
and endorsed his license, authorizing him to drive vehicles carrying hazardous substances.
During audit ask the drivers where he is aware whom to contact during an emergency.
• System of checking documents with the driver and inspecting vehicles with check lists.
• Implementing system of vehicle entry, loading/unloading check list.
• Checking of compatibility with material last transported with the one intended to be loaded.
• Checking of placing of appropriate fire extinguishers in the vehicle.
• Checking of provision of separate earthing to tank and hoses.
• What arrangements have been made to prevent rolling of vehicles and loading/unloading
operation to be carried out under the supervision?

2) Rail
• What hazardous materials are transported by rail?
• Does the company have a direct siding on site?
• Are tankers or other wagons used in transportation?

3) Pipelines
• What materials are transported to and from the site by pipelines?
• Are the pipelines underground or over ground?
• Are corrosion protection measures employed in pipelines?
• Whether intermediate booster pumps are used?
• What is the maximum, minimum and average transfer rates?
• Are the pipelines extended in the public domain?
• Are the pipelines dedicated for each type of chemicals?
• Are the pipelines fitted with safety equipment such as leak detectors, automatic shut-off
valves etc.?
• What is the frequency and method of testing of the pipeline?
• Is there written procedure for tackling leakages in pipeline?

116
 Annexure – 1

TRANSPORT EMERGENCY CARD (TREMCARD)

Introduction:
In India most industrial products, including hazardous chemicals, are generally transported by
road. If a vehicle carrying a hazardous material meets with any accident, it can have disastrous
consequences. However, a prompt and correct response can mitigate the effect of the
consequences.

Transport Emergency Card (commonly called Trem card) is a useful document and is very helpful
for the responders in handling any emergency involving the product during its transportation by
road. The Trem card carries clear, concise information and guidelines on the immediate action
that should be taken either by the driver himself or by any other person in the event of an
emergency involving his vehicle during transit.

Format of Contents

A Trem card gives brief information/guidelines on the following:

(1) Name of the chemical and its basic properties

(2) Nature of hazard
(3) Protective devices to be used by emergency responders
Emergency action (“Notify police and fire brigade immediately.”)
(4) Action to be taken in case of a spillage
(5) Action to be taken in case of a fire
(4) First-aid in case of injury or exposure to the hazardous goods
(6) Address and telephone number of the consignor/manufacturer (or any other agency on
behalf of consignor/manufacturer) from whom additional information can be obtained in
an emergency on a round-the-clock basis.

The format of the Trem card is given in Annexure V of the Central Motor Vehicles Rules, 1989
and is based on the Trem cards designed by CEFIC (“Conseil European des Federations de
L’industrie Chimique” – European Council of Chemical Manufacturers’ Federations, Zurich,
Switzerland).

Statutory Requirements

Under Rule 132 of the Central Motor Vehicles Rules, 1989, the driver of the goods vehicle
transporting a hazardous substance is required to carry a Transport Emergency Card (commonly
called Trem card) pertaining to the specific hazardous substance being transported and not a
common document for all hazardous substances. It is the responsibility of the consignor of the
hazardous product to prepare and provide the Trem card to the driver of the vehicle for each
hazardous product transported by road.

The Rule 132 also requires that the owner should satisfy himself that such driver has sufficient
understanding of the nature of such goods and the associated risks involved in the transport of
such goods and is capable of taking appropriate action in case of an emergency during transit.

The driver must carry only one Trem card, which should pertain to the hazardous product loaded
in his vehicle. Rule 133 stipulates that the driver must ensure that the Trem card for the product
transported by him is kept in his (driver’s) cabin and is available at all times during transportation.

117
General

International standard requires the Trem cards to be printed in black and red colours on a white
card of A4 size (210mm x 297mm), if the Trem card is in one or two languages. (A4 size card can
accommodate the same text in two languages by printing on both sides.) If the Trem card is
required to be printed in more than two languages, then the size of Trem card can be reduced to
A5 size (148mm x 210mm).

CEFIC has developed Trem cards for a variety of chemicals and other hazardous substances and
published in the form of books. The set of these books has been reprinted in India by Indian
Chemical Manufacturers’ Association (ICMA) for the benefit of Indian industry. CEFIC stipulates
that if the Trem card has to carry the same text in more than two languages, then separate
language versions may be printed in a similar style, reduced to A5 size (148mm x 210mm), which
is exactly half of A4 size. This would enable printing of text up to four different languages in one
card of A4 size, using both sides (since A5 size is exactly half of A4).

Rule 132 of the Central Motor Vehicles Rules, 1989 does not specify the language in which the
Trem card should be prepared. However, an earlier Notification of the Government of
Maharashtra requires that the Trem card should be printed in English, Hindi and in the languages
of the States through which the vehicle carrying hazardous goods has to pass.

Since the information in the Trem card is in concise form, only the advice of prime importance can
be listed. The driver (who is specially trained under Rule 9 of the Central Motor Vehicles Rules,
1989) or the emergency responders will have to use their judgments in deciding the appropriate
measures to be taken in the particular circumstances. The consignor/manufacturer of the
dangerous goods should be contacted for more information, if required. Trem card carries the
name and telephone number of the consignor/manufacturer or his representative, who can
provide additional information. The consignor/manufacturer of hazardous goods or his
representative is required to provide this service round the clock.

118
 Annexure – 2
EMERGENCY INFORMATION PANEL ON VEHICLES
The Emergency Information Panel gives legend and label marking in appropriate shapes, sizes
and shades to be printed on the vehicles transporting any hazardous or dangerous goods. The
information should be simple, scientifically illustrated and less worded. Its objective is, if the
emergency information is depicted on a panel displayed on the vehicle transporting hazardous
goods, the general public will be made aware of the hazards.
In India, as per the Central Motor Vehicles Rules, 1989, (CMV), every goods carriage transporting
any hazardous or dangerous goods shall be legibly marked at prescribed three conspicuous
places, an emergency information panel containing: (a) Correct Technical Name, (b) UN Number,
(c) Hazchem Code, (d) In Emergency Dial, (e) Class label, and (f) Specialist Advice.

For all the above displays the size of the lettering has been prescribed in the rules. The place for
fixing Emergency Information Panels in vehicles transporting hazardous chemicals as follows:

119
 Annexure - 3

HAZARD CLASS LABELS

UN Classification of Goods Class Label

Hazard
Class
No.
1 2 3
1 Explosives

(e.g. Detonators, Ammunitions, Fireworks,

Trinitroaniline, Bombs)

Symbol (exploding bomb) : Black EXPLOSIVES

Background : Orange
Figure 1 at the bottom corner

2 1
Gases, Compressed, liquefied dissolved under pressure or deeply refrigerated
Flammable Gases
(e.g. Ethylene Oxide, LPG, Hydrogen)
FLAMMABLE
Symbol (Flame) : Black or White GAS
Background : Red
Figure 2 at the bottom corner 2

Non-flammable Gases

(e.g. Compressed Air, Argon, Carbon dioxide,

Nitrogen, Oxygen)
NON-FLAMMABLE
Symbol (Gas Cylinder) : Black or White COMPRESSED
Background : Green GAS
Figure 2 at the bottom corner
2
Poison (Toxic) Gases

(e.g. Ammonia, Chlorine, CO)

Symbol (Skull & crossbones) : Black
Background : White
Figure 2 at the bottom corner

Flammable Liquid

(e.g. Acetone, Benzene, Kerosene, Naphtha,

Petrol, Acetaldehyde, CS2, Toluene, Xylene)

Symbol (Flame) : Black or White FLAMMABLE

Background : Red
3
LIQUID
Figure 3 at the bottom corner

120
4 Flammable solids, substances liable to spontaneous combustion and
substances which on contact with water, emit inflammable gases

4.1 Flammable Solids

(e.g. Aluminium Powder, Sulphur,

Phosphorous) FLAMMABLE
SOLID
Symbol (Flame) : Black
Background : White with vertical red 4
stripes
Figure 4 at the bottom corner

4.2 Substances liable to spontaneous

SPONTANEOUSLY
combustion COMBUSTIBLE

(e.g. Cotton, Paper, Sodium Sulphide) 4

Symbol (Flame) : Black
Background : Upper half white Lower
half red
Figure 4 at the bottom corner

4.3 Substances which in contact with water

emit in-flammable gases

(e.g. Calcium Phosphate, Calcium, Barium

Sodium) DANGEROUS
Symbol (Flame) : Black or White WHEN WET

Background : Blue
Figure 4 at the bottom corner 4
5 Oxidising Substances
5.1 Oxidising Substances

(e.g. Potassium Nitrate, Potassium Bromate)

Symbol (Flame over a circle) : Black
Background : Yellow
Figure 5 at the bottom corner OXIDISING
AGENT

5.2 Organic Peroxide

Symbol (Flame over a circle) : Black

ORGANIC
Background : Yellow PEROXIDE
Figure 5 at the bottom corner

121
6 Poisonous (toxic) and infectious substances

6.1 Poisonous (toxic) substances

(e.g. Hydrogen Cyanide, Aniline, Arsenic Acid,

Lead Acetates, Cyanides)
Symbol (skull & crossbones) : Black
Background : White POISON
Figure 6 at the bottom corner

6.1 Harmful substances

The bottom half of the label should bear the

inscription :
HARMFUL
Stow away from foodstuffs
HARMFUL
Symbol (St. Andrew's cross over an ear of wheat) STOW AWAY
: Black FROM
FOOD
Background : White STUFFS
Figure 6 at the bottom corner
6.2 Infectious Substances
The bottom half of the label should bear :
INFECTIOUS SUBSTANCES (optional) and the
inscription
"In case of damage or leakage immediately notify
Public Health Authority" (optional) INFECTIOUS
Symbol (Three crescents superimposed on a SUBSTANCE
circle) : Black
Background :
White
Figure 6 at the bottom corner
7 Radioactive Substances
(e.g. Uranium, Thorium)
Symbol (3 segments of circle – a number and
lettering of the Class Label) : Black
Background : White
Figure 7 at the bottom corner
8 Corrosives
(e.g. Sulphuric Acid, Hydrochloric Acid, Nitric
Acid, Bromine, Acetic Anhydride)
Symbol (liquids spilling from two glass vessels
and attacking a hand and a metal) : Black
Background : Upper half white Lower half black
with white border
Figure 8 at the bottom corner

9 Miscellaneous Dangerous Substances

122
 b) SAFETY IN STORAGE HAZRDOUS CHEMICALS
&
c) HANDLING OF HAZRDOUS CHEMICALS

Introduction:

Chemical Safety is achieved by undertaking all activities involving chemicals in such a way as to ensure
the safety of human beings and protection of the environment. It covers all chemicals, natural and
manufactured, and the full range of exposure situations from the natural presence of chemicals in the
environment to their extraction or synthesis, industrial production, transport use and disposal. The primary
goal of any chemical industry should be to reduce, control or eliminate health hazards associated with
hazardous chemicals.

Classification of chemicals based on hazards

a. Flammable chemicals
b. Explosive chemicals
c. Corrosive chemicals
d. Toxic chemicals
e. Heat sensitive Chemicals
f. Oxidising chemicals (agents)
g. Water sensitive chemicals
h. Gases under pressure
i. Chemicals liable for spontaneous ignition
j. Reducing chemicals (agents)
k. Radio-active substances

Background:
As per the Public liability insurance Act,1991 “handling”, in relation to any hazardous substance, means
the manufacture, processing, treatment, package, storage, transportation by vehicle, use, collection,
destruction, conversion, offering for sale, transfer or the like of such hazardous substance;

Legal Requirement :
Sr. Legislation Section/sub- Provisions
No. section /
Rule/sub-
rule/Regulat
ion
The Factories First It has a list of 29 types of industries involving hazardous
1. Act, 1948 Schedule processes
Second It has a table showing permissible level of certain chemical
Schedule substances in Work Environment expressed in Time-Weighted
Average (TWA) Concentration for 8 hrs. as well as Short Term
Exposure Limit (STEL) (for 15 mins.). The permissible levels are
expressed both in parts per million (ppm) and milligram per cub.
meter (mg/m3).
Third It has a list of 29 types of Notifiable Diseases
Schedule
Section 7-A General Duties of the Occupier: Occupiers to ensure health,
safety & welfare of all workers while they are at work in the
factory.

123
 Section 14 Preventing accumulation of dust & fumes: Prevent
accumulation of dust and fumes which are offensive and injurious
to health in substantial quantities by effective measures, may
include application of exhaust appliance near to the point of origin
of such dust & fumes.
Section 31 Pressure Plant: Effective measures to be taken for ensuring safe
working pressure of pressure plant should not exceed.
Section 35 Protection of eyes: Effective screens or suitable goggles shall
be provided for protection of persons employed on such
manufacturing processes which may involve risk of injury to eyes
from flying particles or by exposure to excessive light.
Section 36 Precaution against dangerous fumes, gasses etc. : Person
entering the confined space shall wear suitable breathing
apparatus and a securely attached belt, free end of which is to be
held by a person outside the confined space.
Section 37 Explosive or inflammable dust gas etc.: Practicable measures
shall be taken to prevent explosion of dust, gases, fumes or
vapours by effective enclosures to the plant or machinery for
removal and prevention of accumulation of such gases or dust
etc. or by effectively preventing all possible sources of ignition.
Chapter IV-A Provisions relating to Industries involving hazardous
processes: A list comprising 29 types of industries (mentioned in
Schedule 1) is categories as those industries which involve
hazardous processes. The Act mentions certain special
provisions to be complied by such industries. The special
provisions are relating to:
• Compulsory disclosure of information by the Occupier (Section
41-B)
• Specific responsibility of the Occupier (Section 41-C)
• Emergency Standards (Section 41-E)
• Permissible limits of exposure of chemicals and toxic
substances (Section 41-F)
2 The Rule 10 Preparation of Safety Report and Safety Audit Report: The
Manufacture, occupier is required to send safety report to the concerned
Storage and authority to show that his industrial activities are being carried on
Import of safely (Refer Schedule 8) and shall update the safety audit report
Hazardous once in a year by conducting a fresh safety audit.
chemicals Rule 11 Updating of Safety Reports : Safety reports to be kept upto
rules, 1989 date, in respect of modifications that may be made to the
(Amended industrial activity as and when they occur, and periodically every
2000 ) three years.
Rule 13 Preparation of On-Site Emergency Plans: This occupier is to
prepare and keep up-to-date On-Site Emergency Plan (as per the
details specified in Schedule II) for dealing with possible major
accidents on his sites. Conduct mock drills of the On-Site
Emergency Plan once in a period of six months.
Rule 16 Disclosure of Information: The information required for the
public in case of a major accident shall be disseminated.
Rule 17 Collect, develop and disseminate information on Hazardous
Chemicals: Occupier should obtain or develop information in the
form of a MSDS sheet given in Schedule – 9 to the Rules in
respect of all the hazardous chemicals he handles. All the
containers of hazardous chemicals should be labelled/ marked to
identify their contents and given full data on their properties.

124
 Schedule 1 Part I – A list of indicative criteria of Toxic Chemicals, Flammable
Chemicals and Explosives.
Part II – A list of 684 Hazardous Chemicals
Schedule 2 Shows isolated storage at installations other than those covered
by Schedule 4 (a list of 30 chemicals and types of chemicals)
Schedule 3 Part I – Shows a list of 179 named chemicals in 4 groups
Schedule 6 Information to be furnished regarding notification of a major
accident
Schedule 8 Information to be furnished in a Safety Report
Schedule 9 CHEMICAL SAFETY DATA SHEET
Safety Data Sheet of hazardous chemical should reveal potential
hazards of the chemical, safe practices and engineering control to
minimize / control the hazards. The data sheet shall include the
following information, namely:
i) the chemical identity used on the label, chemical name with
classification (UN No., Hazchem No., CAS No.)
ii) hazardous ingredient of the substance
iii) physical and chemical characteristics of the hazardous
substance
iv) physical hazards of the hazardous substance, including the
potential for fire, explosion and reactivity
v) health hazards of the hazardous substance, including signs
and symptoms of exposure and any medical conditions
which are generally recognized as being aggravated by the
exposure to the substance
vi) the primary route(s) of entry
vii) the permissible limits of exposure prescribed in the Second
Schedule under section 41-F of the Factories Act 1948
viii) Emergency and First Aid Measures
ix) Manufacturer/Supplier Data
The occupier while obtaining or developing a Chemical Safety
Data Sheet in respect of a hazardous chemical shall ensure that
the information recorded accurately reflects the scientific evidence
used in making the hazard determination.
As per REACH there are 16 elements in the MSDS.
Schedule 11 Details to be furnished in the On-Site Emergency Plan
Schedule 12 Details to be furnished in the Off-Site Emergency Plan
3. The Section 27 Notice of Accidents with Petroleum : The occupier of the place
Petroleum or the person in charge of the petroleum or the person in charge
Act, 1934 of a carriage or master of the vessel shall give notice thereof and
of the attendant loss of human life, or injury to person or property,
if any, to the : -
(i) nearest Magistrate ,or
(ii) officer-in-charge of the nearest police station, and
(iii) Chief Controller of Explosives.
4. The Rule 31 Prohibition of smoking, fire, lights
Petroleum Rule 32 Restriction on loading & unloading by night
Rules, 2002 Rule-37 Petroleum in bulk on barges and flats
(Amended Rule-47 Prohibition of smoking, fire and lights during loading or
2011) unloading: There shall be no fire or artificial light or smoking on
board the ship or vessel or within 30 m of place of loading or
unloading of petroleum.
Rule-80 Precautions against movement of vehicles during loading or
unloading: Petroleum shall not be loaded into or unloaded from a
vehicle until its wheels have been secured by efficient brakes or

125
 by scotching and in the case of animal-drawn vehicle until the
animals have been unhitched and removed.
Rule-83 Restrictions on loading and unloading of petroleum at night:
Except where approved electric lights specified in Chapter IV are
exclusively used, loading or unloading of tank vehicles shall be
done between hours of sunrise and sunset.
Rule-84 Prohibition of fires and smoking: No fire or other artificial light
capable of igniting flammable vapour shall be allowed on any
vehicle containing petroleum Class A, or Class B or Class C in
bulk. No person shall smoke while attending such vehicle. No
article or substance capable of causing fire or explosion shall be
carried on such vehicle.
Rule-103 Hazardous area: An area is deemed to be hazardous where (i)
Petroleum with flash point below 650 C or any gas/vapour in a
concentration capable of ignition is likely to be present, (ii)
Petroleum or any flammable liquid with flash point above 65 0 C is
likely to be refined, blended, handled or stored.
Rule-117 Precautions against fire: No person shall smoke or carry
matches, fuses or other appliances which may cause ignition or
explosion in any installation, Adequate number of portable DCP or
other oil fire extinguisher shall be kept in storage shed. Scale of
fire fighting in other areas of installation should be as per
requirement in OISD Standard-117.
Rule-167 Situation of storage tanks and facilities for liquefied
petroleum gases: No storage tank or filling facility for liquefied
petroleum gases shall be nearer than 90 cm to any still, boiler or
furnace or nearer than 30 cm to any storage tank, pump house or
any facility for blending or filling of petroleum or to any protected
work.
5. The Gas Rule 5 Safety relief devices: Cylinders manufactured in India, if fitted
Cylinder with safety relief devices in their bodies, shall have such safety
Rules, 2016 devices manufactured and maintained in accordance with
IS:5903; Cylinders containing poisonous gases shall not be
provided with any safety device.
Rule 6 Marking on cylinders: Every gas cylinder shall be clearly and
permanently marked by stamping, engraving or similar processes
Rule 8 Identification colours: IS:4379 for industrial cylinders and
IS:3933 for medical cylinders.
Rule 9 Labelling of cylinders
Rule 14 Prohibition of smoking, fires, lights and dangerous substances
Rule 18 Handling and use: Conveyors, trolleys and cradles of adequate
strength shall, as far as possible, be used when moving the
cylinders. The cylinders shall be handled carefully and not be
subjected to any undue shock. Sliding, dropping or playing with
cylinders is prohibited.
Rule 21 Storage of cylinders: Cylinders shall be stored in a cool, dry,
well ventilated place under cover, away from boilers, open flames,
steam pipes or any potential sources of heat and shall be easily
accessible.
6. Public Liability Sub-section 1 Liability to give relief in certain cases on principle of no fault:
Insurance Act, of Section 3 Where death or injury to any person (other than a workman) or
damage to any property has resulted from an accident, the owner
shall be liable to give such relief as is specified in the Schedule
Section 4 for such death, injury or damage.
Duty of owner to take out insurance policies: Every owner

126
 shall take out, before he starts handling any hazardous
substance, one or more insurance policies providing for contracts
of insurance whereby he is insured against liability to give relief
under sub-section (1) of section 3:
The purpose of taking the policy under Public Liability Insurance
Act, 1991 is to give compensation to affected people those are
not associated with activity.
7. The Building Rule 43: An employer shall prevent concentration of dust, gases or fumes
and Other Dust, gases, by providing suitable means to control their concentration within
Construction fumes etc.: the permissible limit so that they may not cause injury or pose
Workers’ health hazard to a building worker at a building or other
(Regulation of construction work.
Employment Rule 44 : The employer shall ensure that corrosive substances, including
and Corrosive alkalis and acids, shall be stored and used by a person dealing
Conditions of substances: with such substances at a building or other construction work in
Service) such a manner that it does not endanger the building worker and
Central Rules, suitable protective equipment shall be provided by the employer
1998 to a building worker during handling or use of such substances at
a building or other construction work and in case of spillage of
such substances on the building worker, immediate remedial
measures shall be taken by the employer.
Rule 152 : Permissible limit of exposure of chemicals.—The employer shall
ensure at a construction site of a building or other construction
work that—
(a) the working environment in a tunnel or a shaft in which
building workers are employed does not contain any of the
hazardous substances in concentrations beyond the permissible
limits as laid down in the Schedule XII annexed to these rules;
(b) the responsible person referred to in rule 121 conducts
necessary test before the commencement of a tunnelling work for
the day and at suitable intervals as fixed by the Director General
to ensure that the permissible limits of exposure are not exceeded
and a record of such test is maintained and is made available for
inspection to the Inspector having jurisdiction, on demand.

Storage of Hazardous Chemicals (Bulk)

Bunds: The purpose of bund is to retain liquid so that it can be dealt with in a controlled manner.
Atmospheric storage tanks are generally provided with full bunds. If there are more than one tank inside
the bund the capacity should be that of the largest tank after allowing for the displacement due to the
other tanks.

127
Separation distances

The minimum recommended separation distance for storage tanks for class A and B flammable liquids
are given in Table – 2. (Institute of Petroleum, 1965, Refining Safety Code).

TABLE–1

Minimum safety distances for flammable, corrosive and toxic cases

Sr. Water capacity of vessels (in litres) Minimum distance from Minimum distance
No. building or group of between pressure
buildings or line of adjoining vessels
property
i. Not above 2,000 5 metres 1 metre
ii. Above 2,000 but not above 10,000 10 metres 1 metre
iii. Above 10,000 but not above 20,000 15 metres 1.5 metre
iv. Above 20,000 but not above 40,000 20 metres 2 metres
*v. Above 40,000 30 metres 2 metres

TABLE–2
Sl. Factor Type of tank roof Minimum distance
No.
1. Distance between tank and building Fixed roof A minimum of 50 ft. (15 m.)
containing flammable material e.g. A minimum of 20 ft. (6 m)
filling shed or storage building. Floating roof
2 Distance between tank boundary or Both types A minimum of 50 ft. (15m) any source
any source of ignition of ignition irrespective of should not
be within distance the bund.
3 Maximum tankage capacity in one Fixed roof 60,000 ton water capacity
bund 120,000 ton
Floating roof
4 Volume of bund Both types Net volume not less than 100% of
capacity of the largest tank.

Guidance to check compliance:

1) What are the hazardous substance handled in the factory?

2) Whether quantity of hazardous substances is above the threshold limit specified in the
Manufacture, Storage and Handling of Hazardous Substances Rule, 1989? If yes, then required
documentation is available as per the rule.

128
 3) Whether written procedure for handling the hazardous substance is available and operators are
trained for handling such substances including actions required in case of leakages and
spillages?
4) Are the employees aware of the hazards arising from hazardous substances and safety
precautions to be taken during handling of these?
5) Whether storage vessels are identified with the capacity as required under MSIHC, Rules 1989.
6) What are the storage pressure and temperature?
7) Whether vessels are above ground / underground?
8) If any of the tanks storing flammable material, whether electrical equipment and fittings are as
per electrical area classification?
9) Is the bunded area takes into account the total quantity of the largest tank?
10) Whether the bund perimeter takes into consideration of trajectory of leak from tank?
11) Are the vessels properly bonded and earthed and whether periodically checked and record
maintained?
12) Are the vessels fitted with remotely controlled isolation valves?
13) Are vessels provided with emergency vent, relief valve, bursting disc, level indicator, pressure
gauge, and overflow line?
14) Where do such vents discharge?
15) Are the vessels provided with alarms for high level, high temperature and high pressure?
16) Are standby empty tanks or any other alternate systems provided for emptying / transfer in case
of emergencies?
17) What are the provisions made for firefighting / tackling emergency situations around the storage
vessels?
18) Has any consequence analysis for loss of containment been carried out?
19) Whether the vessels are tested as per statute? Whether log sheets are filled up on daily basis for
recording the parameters of these vessels?
20) Whether monitors for detection of leakage of flammable / toxic material installed?
21) Whether the chemicals stored are as per their compatibility?

d) SPILL CONTROL MEASURES

Introduction:
The nature of the spill is determined by the risk from the hazardous substance and the level of
containment of the spill. Persons using, storing and transporting chemicals should always refer to the
Material Safety Data Sheet and have controls in place to minimise the effects of a chemical spill such as
double containment, bunding, drip trays or raised edges around work areas.

Legal Requirements:

The appropriate sections and rules with provisions of the particular legislation, those have requirements
for spill control measures are listed below:
Sr. Legislation Section/sub- Provisions
No. section /
Rule/sub-
rule/Regulati
on
1. The Rule 73 - M The occupier responsibility to develop and disseminate
Maharashtra information of hazardous substances and their procedures for
State Factories clean-up of spills and leaks.
Rules, 1963

129
 Sr. Legislation Section/sub- Provisions
No. section /
Rule/sub-
rule/Regulati
on
2. The Building Rule 44 : The employer shall ensure that corrosive substances, including
and Other Corrosive alkalis and acids, shall be stored and used by a person dealing
Construction substances: with such substances at a building or other construction work in
Workers’ such a manner that it does not endanger the building worker and
(Regulation of suitable protective equipment shall be provided by the employer
Employment to a building worker during handling or use of such substances at
and Conditions a building or other construction work and in case of spillage of
of Service) such substances on the building worker, immediate remedial
Central Rules, measures shall be taken by the employer.
1998
3. Model Rules 82-D(1) Required information to be provided to the workers regarding
made under measures to be taken by them in case of spillage or leakage of
Factories Act hazardous substances vis-à-vis the emergency plan of the
factory, in particular the evacuation procedure. The information
provided in the form of booklets or leaflets and cautionary notice
at workplaces in the language understood by majority of workers.
4. BOCW Rules, Rules 36 Emergency Action Plan
1998 • Make emergency plan for construction site if more than 500
workers are employed and submit it for approval of the
Director General
• Emergency Plan to cover emergencies like fire & explosion,
collapse of lifting appliance & transport equipment, collapse of
building, sheds & structures, etc, gas leakage or spillage of
dangerous goods or chemicals, drowning of building workers,
sinking of vessels and landslides getting building workers
buries; floods, storms & other natural calamities
5. Dock Workers Regulation Emergency Action Plan : All ports shall have an approved
Regulations, 112 emergency action plan acceptable to the Chief Inspector to
1990 handle emergencies like fires & explosions; collapse of lifting
appliances, buildings, sheds, etc., gas leakage & spillage of
dangerous goods, drowning of dock workers, sinking of vessels,
retrieval of transport equipment from dock basin and floods;
storms & other natural calamities.

Guidance to check compliance:

1) Whether spill control procedure is available?
2) Whether there is a system to deal with the spillage?
3) Whether spill collection pit / sump is available at the workplace?
4) Whether methodology for recovery / disposal of collected material has been established?

e) MATERIAL SAFETY DATA SHEET (MSDS)

Introduction:
Many of the industries supply dangerous machines and hazardous products/articles to the customers for
their use. During the use of such machines, goods and chemicals the customers are exposed to the
hazards associated with them. Therefore, the customers are required to know the hazards, risks and
precautions to be taken while handling them.

130
Background:

As per Section 7 A (2) (c) of the Factories Act, 1948 and as per Rule 17(2) of the Manufacture Storage
and Import of Hazardous Chemicals Rules, 1989, the occupier who has a control over industrial activity in
which a hazardous chemical is handled, should arrange to obtain or develop information in the form of
Material Safety Data Sheet and same should be supplied to customer. Further the section 7B of the
Factories Act also places certain duties on the manufacturers, designers, suppliers of articles for use in
factories.

Sr. Legislation Section/sub- Provisions

No. section /
Rule/sub-
rule/Regulation
1. The Rule 73 M The occupier of every factory carrying on a 'hazardous process'
Maharashtra shall arrange to obtain or develop information in the form of
Factories Material Safety Data Sheet in respect of every hazardous
Rules, 1963 substance. It shall be accessible upon request to a worker for
reference
2. Model Rule 82 C- The occupier of every factory carrying on hazardous process
Rules, Collection, should arrange to obtain or develop information in respect of
DGFASLI development every hazardous substance in the form of Material Safety Data
and Sheet as prescribed.
dissemination of Further every container of hazardous substance should be
information clearly marked or labelled with certain information for
identification.
3. The Rule 17 Collect, develop and disseminate information on Hazardous
Manufacture Chemicals: Occupier should obtain or develop information in
, Storage the form of a MSDS sheet given in Schedule – 9 to the Rules in
and Import respect of all the hazardous chemicals he handles. All the
of containers of hazardous chemicals should be labelled/ marked
Hazardous to identify their contents and given full data on their properties.
chemicals
rules, 1989
(Amended
2000 )
3 The Schedule 9 CHEMICAL SAFETY DATA SHEET
Manufacture Safety Data Sheet of hazardous chemical should reveal
, Storage potential hazards of the chemical, safe practices and
and Import engineering control to minimize / control the hazards. The data
of sheet shall include the following information, namely:
Hazardous x) the chemical identity used on the label, chemical name with
chemicals classification (UN No., Hazchem No., CAS No.)
rules, 1989 xi) hazardous ingredient of the substance
(Amended xii) physical and chemical characteristics of the hazardous
2000 ) substance
xiii) physical hazards of the hazardous substance, including the
potential for fire, explosion and reactivity
xiv) health hazards of the hazardous substance, including signs
and symptoms of exposure and any medical conditions
which are generally recognized as being aggravated by the
exposure to the substance
xv) the primary route(s) of entry
xvi) the permissible limits of exposure prescribed in the Second
Schedule under section 41-F of the Factories Act 1948
xvii) Emergency and First Aid Measures

131
 xviii) Manufacturer/Supplier Data

The occupier while obtaining or developing a Chemical Safety

Data Sheet in respect of a hazardous chemical shall ensure that
the information recorded accurately reflects the scientific
evidence used in making the hazard determination.

As per REACH there are 16 elements in the MSDS.

Guidance to check compliance:

1) Are the material safety data sheets available for all the chemicals handled, used and
manufactured in the factory?
2) Whether copies of MSDSs made available to all workers including contract workers?
3) Whether the latest MSDS are displayed at strategic locations?
4) Is it available in local language?

f) GAS CYLINDERS

Introduction:

"Gas cylinder" or "Cylinder" means any closed metal container having a volume exceeding 500 ml but not
exceeding 1000 litres intended for the storage and transport of compressed gas, including any liquefied
petroleum gas (LPG) container or compressed natural gas (CNG) cylinder fitted to a motor vehicle as its
fuel tank but not including any other such container fitted to a special transport or undercarriage and
includes a composite cylinder and cryogenic container, however, the water capacity of cylinder used for
storage of CNG, nitrogen, compressed air, etc., may exceed 1000 litres up to 3000 litres provided the
diameter of such cylinder does not exceed 60 cm;
Legal Requirements:
The appropriate sections and rules with provisions under The Gas Cylinder Rules 2016 are listed below:

Sr. Legislation Section/su Provisions

No. b-section /
Rule/sub-
rule/Regul
ation
1. The Gas Rule 3 Filling, possession, import and transport of cylinder: No transportation
Cylinder of cylinders unless to have the test and inspection certificates issued
Rules, 2016 by the inspecting authority in respect of cylinder and its valve are
made available to the Chief Controller and prior approval of the said
authority is obtained.
Rule 5 Safety relief devices: Cylinders manufactured in India, if fitted with
safety relief devices in their bodies, shall have such safety devices
manufactured and maintained in accordance with IS:5903; Cylinders
containing poisonous gases shall not be provided with any safety
device.
Rule 6 Marking on cylinders: Every gas cylinder shall be clearly and
permanently marked by stamping, engraving or similar processes
Rule 8 Identification colours: IS:4379 for industrial cylinders and IS:3933
for medical cylinders.
Rule 9 Labelling of cylinders
Rule 10 Restriction on delivery or dispatch of cylinder: No one can deliver or

132
 transfer the cylinders without license.
Rule 14 Prohibition of smoking, fires, lights and dangerous substances
Rule 18 Handling and use: Conveyors, trolleys and cradles of adequate
strength shall, as far as possible, be used when moving the cylinders.
The cylinders shall be handled carefully and not be subjected to any
undue shock. Sliding, dropping or playing with cylinders is prohibited.
Rule 20 Loading, unloading and transport of cylinders or cascade:
Transported as proper manner listed in Schedule VI of the Rule.
Rule 21 Storage of cylinders: Cylinders shall be stored in a cool, dry, well
ventilated place under cover, away from boilers, open flames, steam
pipes or any potential sources of heat and shall be easily accessible.
Rule 22. Electrical installations near cylinders
Rule 24. Cylinder subjected to the action of fire
Rules 29 For importing gas cylinders the owner should have necessary
(3) infrastructure, handling transportation and storage facility including
emergency action plan and qualified and trained technical
manpower.
(Rule 35) The procedures and testing shall ensure that cylinders, which fail to
Schedule meet the requirements and intent of these rules, are not returned into
IV normal service.
Rule 67 Notice of accidents: To be given to CCE by fax, email followed by a
letter, district authority and officer-in-charge of the nearest police
station by quickest mode of communication.
Rule 67 Licensee shall be given the notice of an accident to–
the Chief Controller or Controller by fax or e-mail followed by a letter
within twenty-four hours of occurrence the District Authority; and
officer-in-charge of the nearest police station by the quickest means.
Rule 68 Inquiry of accident shall be conducted by concerned authorities

Guidance to check compliance :

1) What are the various gas cylinders used in the plant?

2) Are valid licenses available for storing all these cylinders?
3) Are the cylinders stored and segregated as per their compatibility?
4) What are the measures taken for combating any emergency in the cylinders storage area?
5) Whether integrity test certificates are obtained from the suppliers of the cylinders?
6) Are the cylinders chained and secured properly along with the valve caps and proper
identification colour code?
7) Are the cylinders protected from heat or sun and rain?
8) Whether monitors for detection of leakage of flammable / toxic gas installed?

g) LABELLING AND COLOUR CODING

Introduction:

The colour(s) and type of the labels identify the type of hazard, which helps the employee identify the
level of severity. Appropriate labels and warnings on chemical containers in the workplace are required.
Each container of hazardous chemicals leaving a workplace must be labelled, tagged, or marked. While
there are many organizations and agencies that assign safety colours different meanings, a lot of them
have significant overlap. This is done intentionally to help ensure standards apply across as wide a range
of situations as possible.

133
Legal Requirements:
The appropriate sections and rules with provisions for labelling and colour coding are listed below:
Sr. Legislation Section/sub- Provisions
No. section /
Rule/sub-
rule/Regulati
on
1. Model Rules, Rule 82 C- The occupier of every factory carrying on hazardous process
DGFASLI Collection, should arrange to obtain or develop information in respect of
development every hazardous substance in the form of Material Safety Data
and Sheet as prescribed.
dissemination Further every container of hazardous substance should be
of information clearly marked or labelled with certain information for
identification.
2. The Rule 17 Collect, develop and disseminate information on Hazardous
Manufacture, Chemicals: Occupier should obtain or develop information in the
Storage and form of a MSDS sheet given in Schedule – 9 to the Rules in
Import of respect of all the hazardous chemicals he handles. All the
Hazardous containers of hazardous chemicals should be labelled/ marked
chemicals to identify their contents and given full data on their properties.
rules, 1989
(Amended
2000 )
3. The Gas Rule 9 Labelling of cylinders
Cylinder
Rules, 2016
4. The MV Rules 129 Provide Class Labels and Tachograph: Display a distinct class
(Central) labels and provide a tachograph (an instrument to record the
Rules, 1989 lapse of running time of the motor vehicle; time speed
maintained, acceleration and deceleration.
(Now days people are using GPS systems)
Rules,-130, Requirement of Hazard Class Labels: Describes position of
134, 137 displaying the labels
5. Hazardous Rule 18 Transportation of Hazardous and Other Wastes –
and Other • The occupier to provide the transporter the relevant
Wastes information regarding the hazardous nature of the wastes
(Management and measures to be taken in case of an emergency and label
and the hazardous and other wastes containers.
Transboundar • The responsibility of safe transport shall be either of the
y Movement) sender or the receiver whosoever arranges the transport and
Rules, 2016 has the necessary authorisation for transport from the
concerned State Pollution Control Board. This responsibility
should be clearly indicated in the manifest.

Other provisions regarding interstate transportation are provided

in the Rule.
Chapter V The occupier should provide the transporter with the relevant
Packaging, information in Form 9, regarding the hazardous nature of the
Labelling and wastes and measures to be taken in case of an emergency and
Transport of should label the hazardous and other wastes containers as per
hazardous and Form 8.
other waste.

Rule 17
Rule 18 (2)

134
 Sr. Legislation Section/sub- Provisions
No. section /
Rule/sub-
rule/Regulati
on
5. Model Rules, Rule 82 C- The occupier of every factory carrying on hazardous process
DGFASLI Collection, should arrange to obtain or develop information in respect of
development every hazardous substance in the form of Material Safety Data
and Sheet as prescribed.
dissemination Further every container of hazardous substance should be
of information clearly marked or labelled with certain information for
identification.

Guidance to check compliance:

1) Are all the containers, vessels and storage tanks labelled for its content and capacity?
2) Whether the pipelines are colour coded as per IS 2379?
3) Is any plant specific colour code followed?
4) Whether the colour codes are displayed conspicuously in the working areas?

h) HAZARDOUS WASTE TREATMENT AND DISPOSAL

Introduction:
In every industrial activity there is a generation of material/substance which may not have any use for that
industry. This material/substance is termed as waste. When such waste has potential to cause harm to
the health of workers and general environment, it is termed as “Hazardous Waste”.

Hazardous Waste is required to be handled with due precautions and disposed off in a safe manner with
environmentally sound management. While storing different hazardous waste at one place, the critical
characteristic to be considered is compatibility of these wastes.

Background:

Important terms related to management of hazardous waste are defined in Hazardous and Other wastes
(Management and Transboundary Movement) Rules, 2016.

1. “hazardous waste” means any waste which by reason of characteristics such as physical, chemical,
biological, reactive, toxic, flammable, explosive or corrosive, causes danger or is likely to cause
danger to health or environment, whether alone or in contact with other wastes or substances, and
shall include
(i) waste specified under column (3) of Schedule I;
(ii) waste having equal to or more than the concentration limits specified for the constituents in
class A and class B of Schedule II or any of the characteristics as specified in class C of Schedule II;
and
(iii) wastes specified in Part A of Schedule III in respect of import or export of such wastes or the
wastes not specified in Part A but exhibit hazardous characteristics specified in Part C of Schedule
III;

2. “disposal ” means any operation which does not lead to reuse, recycling, recovery, utilisation
including co-processing and includes physio-chemical treatment, biological treatment, incineration and
disposal in secured landfill;

135
3. “environmentally sound management of hazardous and other wastes” means taking all steps
required to ensure that the hazardous and other wastes are managed in a manner which shall
protect health and the environment against the adverse effects which may result from such waste;

4. “occupier” in relation to any factory or premises, means a person who has, control over the affairs of
the factory or the premises and includes in relation to any hazardous and other wastes, the person in
possession of the hazardous or other waste;

5. “manifest” means transporting document prepared and signed by the sender authorised in
accordance with the provisions of these rules;

Each of Seven copies of the manifest is to be utilized in the following manner.

Copy number with Purpose
colour code
(1) (2)
Copy 1 (White) To be forwarded by the sender to the State Pollution Control Board after
signing all the seven copies.
Copy 2 (Yellow) To be retained by the sender after taking signature on it from the transporter
and the rest of the five signed copies to be carried by the transporter.
Copy 3 (Pink) To be retained by the receiver (actual user or treatment storage and disposal
facility operator) after receiving the waste and the remaining four copies are
to be duly signed by the receiver.
Copy 4 (Orange) To be handed over to the transporter by the receiver after accepting waste.
Copy 5 (Green) To be sent by the receiver to the State Pollution Control Board.
Copy 6 (Blue) To be sent by the receiver to the sender.
Copy 7 (Grey) To be sent by the receiver to the State Pollution Control Board of the sender
in case the sender is in another State.

For the management of hazardous and other wastes, an occupier is required to follow the
following steps, namely: -
• prevention;
• minimization;
• reuse,
• recycling;
• recovery, utilisation including co-processing;
• safe disposal
• contain contaminants and prevent accidents and limit their consequences on human
beings and the environment
• provide persons working in the site with appropriate training, equipment and the
information necessary to ensure their safety.

Legal Requirements:

Sr. Statute Section/sub- Provisions

No. section /
rule/sub-rule
1. The Factories Sec.12 (1) Effective arrangements for the treatment of wastes and
Act 1948 Disposal of effluents rendering them innocuous and for their disposal.
wastes and
effluents

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Sr. Statute Section/sub- Provisions
No. section /
rule/sub-rule
2. The Model Rule 22 The arrangements for treatment of wastes and effluents shall
Factories be in accordance with Water(Prevention & Control of Pollution)
Rules Act, 1974 and Air(Prevention & Control of Pollution) Act,1981
and other appropriate authorities
3. The Rule 22 Approval of the arrangements made for disposal to be obtained
Maharashtra Disposal of from the local authority/ State pollution control board
Factories trade waste
Rules, 1963 and effluents
4. The Section 7 Person carrying industry, operation or process is not allowed to
Environment discharge or emit environmental pollutants in excess of the
Protection prescribed standard.
Act,1986
5. The Rule 14 Every person having authorization for handling hazardous
Environment waste is required to submit Environmental Statement for the
Rules, 1986 financial year ending 31st March by 30th September every year.
6. The Water Section 24 Waste material and hazardous waste material have to be
(Prevention Prohibition on disposed-off with consent from state pollution control board.
and Control of use of stream Pollution of stream, well and land with waste material is not
Pollution) Act or well for allowed.
1974 and disposal of Consent to establish, consent operate for liquid waste and
Rules polluting matter authorization for hazardous waste to be obtained from state
Section 25 pollution control board.
7. The Air Section 21 Consent to establish, consent to operate to be obtained from
(Prevention state pollution control board.
and Control of
Pollution) Act
1981 and
Rules
8. The Rule 4 Occupier is responsible for
Hazardous Responsibilities i) safe and environmentally sound management of waste
and Other of the occupier while following hierarchy of waste management, in the
wastes for order of Prevention, minimization, reuse, recycling,
(Management management of recovery, utilization including co-processing and safe
and hazardous and disposal through actual user/authorized disposal facility.
Transboundary other wastes. ii) Ensuring safe transportation of hazardous and other
Movement) waste through authorized transporter.
Rules,2016 iii) Giving specific information about the waste to the
operator of Treatment, Storage and Disposal Facility
(TSDF) facility for safe storage and disposal.
iv) Containing contaminants and preventing accidents and
limit their consequences on human beings and the
environment.
v) Providing to persons working on-site appropriate training,
equipment’s and information to ensure their safety.

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Rule 6 Grant of application in Form 1 to the State Pollution Control Board and
Authorization obtain an authorisation from the State Pollution Control Board.
for managing Every occupier of the facility who is engaged in handling,
hazardous and generation, collection, storage, packaging, transportation, use,
other waste. treatment, processing, recycling, recovery, pre-processing, co-
processing, utilisation, offering for sale, transfer or disposal of
the hazardous and other wastes is required to make an
application in Form 1 to the State Pollution Control Board and
obtain an authorization an application for renewal of
authorisation may be made three months before the expiry of
such authorisation:
Rule 6 (5) Every occupier has to obtain authorization and maintain a
Grant of record of hazardous and other wastes managed by him in
Authorization Form 3 and prepare and submit to the State Pollution Control
for managing Board, an annual return containing the details specified in
hazardous and Form 4 on or before the 30th day of June following the financial
other waste. year to which that return relates.
Rule 8 Storage The occupier can store hazardous and other wastes for a
of hazardous period up to ninety days from the date of generation. This
and other period may be extended up to 180 days by state pollution
wastes control board for small generators up to 10 tonnes., for actual
users and disposal facility, for occupiers in the states where
disposal facility is not available, for developmental work..
Chapter V The occupier should provide the transporter with the relevant
Packaging, information in Form 9, regarding the hazardous nature of the
Labelling and wastes and measures to be taken in case of an emergency and
Transport of should label the hazardous and other wastes containers as per
hazardous and Form 8.
other waste.
Rule 17
Rule 18 (2)
Rule 18(3) In case of transportation of hazardous and other waste for final
disposal to a facility existing in a State other than the State
where the waste is generated, the sender has to obtain ‘No
Objection Certificate’ from the State Pollution Control Board of
both the States.
Rule 18(4) In case of transportation of hazardous and other waste for
recycling or utilisation including co-processing, the sender has
to intimate both the State Pollution Control Boards before
handing over the waste to the transporter
Rule 18(5) In case of transit of hazardous and other waste for recycling,
utilisation including co-processing or disposal through a State
other than the States of origin and destination, the sender has
to give prior intimation to the concerned State Pollution Control
Board of the States of transit before handing over the wastes to
the transporter.
Rule 19 The sender of the waste has to prepare seven copies of the
manifest in Form 10 comprising of colour code indicated and
all seven copies have to be signed by the sender:
Rule 22 Where an accident occurs at the facility of the occupier
Accident handling hazardous or other wastes and operator of the
Reporting disposal facility or during transportation, the occupier or the
operator or the transporter has to immediately intimate the
State Pollution Control Board through telephone, e-mail about
the accident and subsequently send a report in Form 11.

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Sr. Statute Section/sub- Provisions
No. section /
rule/sub-rule
9. The Building Employer has to ensure debris is handled and disposed of by a
and Other Rule 52 method which does not cause danger to the safety of a person,
Construction Disposal of debris is kept moist to bring down dust level, debris is not
Workers Debris thrown from height .
(Regulation of On completion of work, left over material and debris is disposed
Employment of as soon as possible to avoid hazard to traffic and public.
and Conditions
of Service)
Central Rules,
1998

Guidance to check compliance:

1) Are valid statutory permissions (State Pollution Control Board Consent, Authorization) obtained
for the waste?
2) Are various types of wastes identified?
3) Are various wastes stored considering their compatibility?
4) Are the quantities of waste generated less than those specified in the Hazardous and Other
wastes (Management and Transboundary Movement) Rules,2016
5) Are the identified wastes disposed in safe modes?
6) Is air/water/land pollution prevented during handling, storage, transportation and disposal of
waste?
7) Whether the solid waste like combustibles, plastic, metals etc. segregated?
8) Check information filled in manifest document with reference to hazardous waste sent for
reuse/recycling/recovery or disposal.
9) Check record of Hazardous waste storage at site.
10) Verify recorded types and quantities of waste in the Environment Statement submitted to state
pollution control

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 A-4 FIRE AND EXPLOSION HAZARD

a) Organizational setup for fire fighting

b) Built in safety in civil design and construction

c) Built in Safety in Electric Circuits and Equipment

d) Explosive substances

e) Fire safety in handling flammable and explosive materials

f) Fire detection and alarm system

g) Passive and active fire protection system

h) Fixed fire extinguishing system

i) Portable Fire Extinguishing System

j) Firefighting equipment and facilities

k) Fire drill

l) Firefighting training

m) Static electricity and lightning

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a) ORGANIZATIONAL SETUP FOR FIRE FIGHTING
i) As such three no statutory requirement in any of act for requirement of Fire officer or an fire
organization(fire crew and fire squad ) in line with that of safety officer , yet in few state factory rules , it is
stated that man in charge of fire service must be well trained in fire fighting and there need trained
persons in shifts , e.g. MP factory rules rule.

MP factory Rules prescribed under sub-section (1) of Factory Act Section 38 rule72. Fire Protection. Sub
rule (12) a) Personnel in charge of equipment and for fire fighting, fire drills, etc. - shall be a trained
responsible person. (b) Sufficient number of persons shall be trained in the proper handling of firefighting
equipment .c)This is intended to ensure that adequate number of persons are available for firefighting
both by means of first-aid fire fighting, equipment and others. (d) of sub-rule sufficient number of persons
shall be trained in driving these vehicles to ensure that trained persons are available for driving them
wherever the need arises.

In Oil industry which follows Oil industry safety directors Standards it requirement under OISD STD . 116
to have full-fledged Fire Protection / Fighting organization manned by personnel having suitable
professional qualification & training

NBC codes chapter 4 related fires have been adopted by many state governments and rules are also
made and enforced, in these rules requirements of fire officer and trained staff is insisted for certain
types of occupancies ,for example Maharashtra Fire prevention and life safety measures Act 2006 and
rules 2009 which states as follows

A qualified fire officer and trained staff shall be appointed for the following buildings/industries
a) All high rise buildings above 30 m. in height where covered area of one floor exceeds 1000 sq m.
except apartments / group housing.
b) All hotels, identified under classification three star and above category by Tourism Department and
all hotels above 15 m. in height with 150 beds capacity or more without star category.
c) All hospital building of 15 m. and above or having number of beds exceeding 100.
d) Underground shopping complex where covered area exceeds 1000 sq m.
e) All high hazard industries.

Manufacturing ,storage and imports of hazardous chemical rules 1989 , which applicable all MAH
industries while for compliance insists that Safety reports has filled and submitted to concern authorities
in item 10, details of (a) fire brigade, (b) alarm systems, (c) emergency plan containing system of
organization used to fight the emergency, the alarm and the communication rules guidelines for fighting
the emergency, information about hazardous chemicals, examples of possible accident sequences is
asked for.

ii) Fire Communication: Communication plays an important part in any emergency , it very much
essential to have systems in place for fast effective communication in event fire emergency ,
generally recommended communication modes are ;

➢ Dedicated telephone
➢ Manual call points
➢ VHF systems
➢ Public address system
➢ Siren
➢ Alarms etc.

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iii) Standing fire orders ; it is very much essential to have standing order SOP for initialing prompt
action at initial stage of fire or emergency by each individual . Each organization must develop the
same and display it at various locations.

iv) Fire safety Inspection Fire prevention and safety equipment are a vital factor in fire inspections.
Fire extinguishers, fire alarms, smoke detectors, fire sprinkler systems all play a vital role in fire
prevention. It is important therefore to ensure that all equipment is in working order and in
compliance with fire safety codes, hence checking all these is part of fire safety inspection . Also
inspection should ensures that there are no obstructions to people exiting the building in case of a
fire emergency. This includes pathways, exits, aisles, and walkways.

Fire inspection should also cover fire prevention measures are adhere to all fire hazards in the
complex

vi) Emergency handling procedures ;Manufacturing ,storage and imports of hazardous chemical
rules 1989 , which applicable all MAH industries while for compliance insists that, schedule 11 , on
site emergency plans must be prepared and details to be submitted in which following information is
asked related to fire services

10. Details regarding: (i) Warning, alarm and safety and security systems.
11. Details of communication facilities available during emergency and those required for an off-site
emergency
12.Details of fire fighting and other facilities available and those required for an off-site emergency.

As per Factory act section 41 E Emergency Standards need to prepared by industries and rules
for same need to be prepared by state Government . e.g. Maharashtra factory rule 73-H. Special
Safety Precautions for certain highly hazardous Chemical Process - In respect of any factory engaged
in carrying out any hazardous chemical processes required to have Emergency plan and Emergency
Instructions - Simple and special instructions shall be framed to ensure that effective measures will be
carried out in cases of emergency, to deal with possible escapes of inflammable explosive, toxic or
deleterious gases, vapors, liquid or dusts. All concerned workers shall be suitably trained and fully
instructed in the prompt action to be taken in such emergencies and also in the general hazards
encountered in this process.

vi) Fire reporting & Investigation ;as per norms all fires are to be reported to management . Major fire
is considered as dangerous occurrence as per Factory act section 88 and states factory rules( e.g.
Maharashtra factory rule 115[(c) Explosion, fire, bursting out, leakage or escape of any molten metal,
hot liquor, or gas causing bodily injury to any person or damage to any part or portion of the factory in
which persons are employed or damage to any plant, machinery or material)must be reported to
factory inspector with in Form 24-A within 12 hours

vii)Personal Protective Equipment is designed to protect firefighters from serious injuries or illnesses
resulting from contact with chemical, radiological, physical, electrical, mechanical or other hazards. It
covers a variety of devices and garments such as respirators, turnout gear, gloves, blankets and gas
masks following are few PPE every fire men should have
➢ fire helmets
➢ safety boots
➢ fire proximity suits
➢ self contain breathing Apparatus(SCBA)
➢ Nomex uniform
➢ a helmet with face shield and flame retardant insulated gloves etc.

b) BUILT IN SAFETY IN CIVIL DESIGN AND CONSTRUCTION

i) Means of escapes ii) Emergency exits ; In factory act section 38. Clear reference is made
related to means of escape i.e. .In every factory,1) all practicable measures shall be taken to

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 prevent outbreak of fire and its spread, both internally and externally, and to provide and maintain-
-(a) safe means of escape for all persons in the event of a fire, and (2) Effective measures shall
be taken to ensure that in every factory all the workers are familiar with the means of escape in
case of fire and have been adequately trained in the routine to be followed in such cases

The every State Government’s factory rules have many provision about the exits and escape
routes few key points from the same are given below. may make rules, in respect of any factory
or class or description of factories, requiring the ensures to be adopted to give effect to the
provisions Fire exits
• An exit may be a doorway, corridor, passageway to an external stairway or to a veranda or to an
internal stairway segregated from the rest of building by fire resisting walls which shall provide
continuous and protected means of egress to the exterior of a building or to an exterior open
space. An exit may also include a horizontal exit leading to an adjoining building at the same
level. Lifts, escalators and revolving doors shall not be considered as exits for the purpose of this
sub-rule.
• The exits shall be clearly visible and suitably illuminated with suitable arrangement, whatever
artificial lighting is to be adopted for this purpose, to maintain the required illumination in case of
failure of the normal source of electric supply.
• The exits shall be marked in a language understood by the majority of the workers.
• Fire resisting doors or roller shutters shall be provided at appropriate places along the escape
routes to prevent spread of fire and smoke, particularly at the entrance of lifts or stairs where
funnel or flue effect may be created inducing an upward spread of fire.
• All exits shall provide continuous means of egress to the exterior of a building or to an exterior
open space leading to a street.
• Exits shall be so located that the travel distance to reach at least one of them on the floor shall
not exceed 30 meters.
• In case of those factories where high hazard materials are stored or used, the travel distance to
the exit shall not exceed 22.5 metres and there shall be at least two ways of escape from every
room,
• Wherever more than on exit is required for any room, space or floor, exits shall be placed as
remote from each other as possible and shall be arranged to provide direct access in separate
directions from any point in the area served.
• The unit of exit width used to measure capacity of any exit shall be 50 cm. A clear width of 25 cm.
shall be counted as an additional half unit. Clear width of less than 25 cm. shall not be counted
for exit width.
• Occupants per unit width shall be 50 for stairs and 75 for doors.
• There shall not be less than two exits serving every floor area above and below the ground floor,
and at least one of them shall be an internal enclosed stairway.
• Every storage area shall have access to at least one means of exit, which can be readily opened.
• No exit doorway shall be less than 100-cm. in width. Doorways shall be not less than 200 cm. in
height.
• Exit doorways shall open outwards, that is, away from the room but shall not obstruct the travel
along any exit..
• An exit door shall not open immediately upon a flight of stairs. A landing at least 1.5 m x 1.5 m in
size shall be provided in the stairway at each doorway. The level of landing shall be the same as
that of the floor, which it serves.
• The exit doorways shall be openable from the side, which they serve without the use of a key.
• Exit corridors and passageways shall be of a width not less than the aggregate required width of
exit doorways leading from there in the direction of travel to the exterior.
• Where stairways discharge through corridors and passageways, the height of the corridors and
passageways shall not be less than 2.4 meters.
• The minimum width of an internal staircase shall be 100 cm.
• The minimum width of treads without nosing shall be 25 cm. for an internal staircase. The treads
shall be constructed and maintained in a manner to prevent slipping.

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 • The maximum height of a riser shall be 19 cm. and the number of risers shall be limited to 12 per
flight.
• Handrails shall be provided with a minimum height of 100 cm. and shall be firmly supported.
• The refuge area shall be provided with exits adequate to meet the requirements of this sub-rule.
At least one of the exits shall lead directly to the exterior or street.
• Doors in horizontal exits shall be openable at all times.
• Ramps with a slope of not more than 1 in 10 be substituted for the requirements of staircase. For
all slopes exceeding 1 in 10 and wherever the use is such as to involve danger of slipping, the
ramp shall be surfaced with non-slipping material.
• In any building nor provided with automatic fire alarm a manual fire alarm system shall be
provided if the total capacity of the building is over 500 persons, or if more than 25 persons are
employed above or below the ground floor, except that no buildings where the entire area is
undivided and all parts thereof are clearly visible to all occupants.

iii) Emergency power supply; An emergency power system is an independent source of electrical
power that supports important electrical systems on loss of normal power supply. A standby power
system may include a standby generator, batteries and other apparatus. As per NBC code following
facilities must be provided with emergency power supply
➢ Staircase ,emergency escape routes
➢ Fire pumps
➢ Fire Lifts
➢ Lifesaving equipment supply
➢ Critical area lights
Note: these emergency systems must be properly identified and must be kept in good operating
conditions .

iv) Fire and Smoke Detectors; Detectors must always installed at the highest point of the ceiling and
minimum coverage indicated by manufacture shall be considered.
➢ 35 to 40 sq.m per detector for general application
➢ 20 to 25 sq.m per detector for main control room, electronic cubicle room, computer room,
etc., in view of high valve concentration
The exact requirement shall calculated based on relevant IS/NFPA standard Inspection & testing of
detectors must be done as per OEM requirements. Or as per IS: 2189:2008 i.e. Initial Installation Tests
and Maintenance Schedules as follows
➢ Daily by User : Panel indications / faults
➢ Weekly: Operate one device. (complete all zones in 13 weeks), battery checks.
➢ Yearly: operation of at least 20% devices in year.

v) Manual Call points Commercial and Industrial Fire Alarm Systems installed will have Call Point units
as part of the system. These units are often the most visual indication of a fire alarm system and are
instantly recognizable.

Most call points are operated by breaking a frangible glass element which operates a micro-switch inside
the call point (although some modern call points do now have plastic resettable elements). There are a
variety of different call point manufacturers and types of call points, however within a single building it is
good practice to use call points similar in appearance to avoid confusion.

Points are available for Conventional / Non-addressable Fire Alarm Systems, There are also specialist
call points available for different applications such as weatherproof / waterproof call points and call points
operated by a keyswitch instead of an element.

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Where to Position Call Points?
• BS5839 recommends that call points should be located on all final exits, all storey exits i.e.
entrances to stairwells and also consideration should be taken to locating call point units near
to any high risks or special hazards (e.g. in Kitchens or Spray Booths etc.).
• Call points should be distributed in a building so that no one need travel any more than 45
meters to reach their nearest call point. For high risk areas and special hazards as
mentioned above a person should have to travel no more than 25 meters to reach their
nearest manual call point taking into account fixtures and fittings.
• In food preparation areas it is advisable to install call points with a plastic element rather than
the glass element as the possibility of broken glass in these areas must be avoided.
• The mounting height of call points should be 1.4 metres +/-0.2m above the floor level and call
points should project by 15mm from the wall (i.e. not completely flush), this allows the call
point to be seen from the side.

vi. Fire Hydrants

• Fire hydrants shall be provided in the network to ensure protection to all the facilities.
• Each hydrant shall have two outlets inclined towards the ground. The outlets shall be of
female instantaneous type having a standard size of 63 mm conforming to Indian Standards.
• Hydrants shall be located keeping in view the fire hazards at different sections of the
premises to be protected and to give most effective service. At least one hydrant post shall
be provided for every 30 M of external wall measurement or perimeter of unit battery limit in
case of high hazard areas.
• Hydrants protecting utilities and miscellaneous buildings in high hazard areas may be spaced
at 45 M intervals. The horizontal range and coverage of hydrants with hose connections shall
not be considered more than 45 M.
• The hydrants shall be located at a minimum distance of 15 M from the periphery of storage
tank or hazardous equipment under protection. For process plants location of hydrants shall
be decided based on coverage of all areas. In the case of buildings, this distance shall not be
less than 5 M and more than 15 M from the face of building
• Provision of hydrants within buildings shall be in accordance with Standard IS Standard-
3844. Hydrants / Monitors shall be located along road side beams for easy accessibility as far
as possible.
• Double headed hydrants with two separate landing valves on 4" stand post shall be used. All
hydrant outlets shall be situated at a workable height of about 1.2 meter above ground level.
• Hydrants / Monitors shall be preferably located with branch connections and not directly over
main header for easy accessibility.
• IS codes 13039 of 1991, IS 3844 -1985 and IS 2189 can further referred for installation and
maintenance of hydrant system.

vii) Ventilation ;
• Ventilation is a necessary part of any industrial facility that will produce harmful air pollutants in a
confined space where employees work. It not only cleans the air employees will breathe, it also
allows for better temperature control and reduces the risk of fire in the facility
• Ventilation is necessary in buildings to remove 'stale' air and replace it with 'fresh' air. This
helps to: Moderate internal temperatures. Reduce the accumulation of moisture, odours and other
gases that can build up during occupied periods
• There are three types of ventilations a)natural ventilation occurring .b) wind driven ventilation,
pressure-driven flows, and c)stack ventilation.
• Mechanical ventilation can be further categorized as one of four types: exhaust, supply,
balanced, and heat-recovery.
• As thump rules
• Chemical plants must, gas cylinder storage area must be well ventilated
• Control rooms, substation mast have positive pressure if located in hazardous area and must
have 5-6 air changes per hours.

145
viii) Separations distances between combustible / flammable materials and other
Material to restrict the fire growth must be maintained .In Factory rules for example rule 70 of
Maharashtra factory rule it is sated that
(a) all processes, storages, equipment’s, plants etc. involving serious exposing and flash fire hazard
shall be located in segregated buildings where the equipment shall be so arranged that only a
minimum number of employees are exposed to such hazards at any one time;
(b) All industrial processes involving serious fire hazard should be located in buildings or work places
separated from one another by walls of fire resistant construction;
(c) ventilation ducts, pneumatic conveyors and similar equipment involving a serious fire risk should
be provided with flame arresting or automatic fire extinguishing appliances, or fire resisting
dampers, electrically inter-locked with heat sensitive/smoke detractors and the air-conditioning
plant system;
(d) In all work places having serious fire or flash fire hazards, passages between machines,
installations or piles of material should be at least 90 c.m. wide. For storage piles, the clearance
between the ceiling and the top of the pile should not be less than 2 meters.

ix) Access routes for firefighting operations; Factory rules many states have spelled out rules for
this for example rule 70 (2)of Maharashtra factory rule it is sated that
(a) Building and plants shall be so laid out and roads, passageways etc. so maintained as to permit
unobstructed access for fire fighting.
(b) Doors and window opening shall be located in suitable positions on all external walls of the
building to provide easy access to the entire area within the building for fire fighting.

Oil industry safety stander insist for Alternative access shall be provided for each facility so that it
can be approached for fire fighting in the event of blockage on one route. Also insists Road widths,
gradient and turning radii at road junctions shall be designed to facilitate movement of the largest
firefighting vehicle in the event of emergency.

As per NBC code all around the building a free space of 6 meter must be kept for fire truck and
ambulance movement. The building must be also have approachable roads for fire truck
movements.

It also referred in NBC that any change made in the building should not interfere with fire
suppression ,fire detection system and fire rated walls

c) BUILT IN SAFETY IN ELECTRIC CIRCUITS AND EQUIPMENT

i) Electrical equipment in farmable atmospheres
• In an industrial plant such as a petroleum refinery or a chemical process plant, or storage where
quantities of flammable liquids and gases are handled, there is an inherent risk of leaks, fire and
explosion the law and specific regulations necessitate the restriction and even elimination of
sources of ignition. Electricity being one major source of Ignition Petroleum and gas cylinder rules
calls for such Hazardous area . In India, the standard IS-5572: 2009 deals with the hazardous
area classification (HAC) for flammable gases and vapours’ per Code area are classified as
follows
• Zone 0 : Area where Flammable gas or vapour concentration is present all the time or most of
the time such as Vapour space above: closed process vessels, storage tanks closed containers,
etc.
• Zone 1 flammable gas or vapour present, or expected to be present for long periods of time,
under normal operating conditions. As a guide, this can be defined as 10–1,000 hours/year or
0.1–10% of the time. These areas (Zone 1) are where special or classified electrical equipment
must be used for e.g. explosion proof equipment
• Zone 2 In this zone the gas, vapour or mist would only be present under abnormal conditions
(most often leaks under abnormal conditions). As a general guide, unwanted substances should
only be present under 10 hours/year or 0–0.1% of the time.

146
 • An important consideration for selection of electrical equipment for use in a hazardous area is its
temperature classification. Never allow the surface temperature of the electrical equipment to rise
beyond the auto ignition temperature of the gas or vapour that it process or handled nearby .

It important for auditor to make sure such classification of hazardous area is done at location and
proper electrical equipment is used.
ii) Lighting arrestors Factory rules many states have spelled out rules for this for example rule 70
(3)of Maharashtra factory rule it is sated that , Protection from lightning shall be provided for-

(a) Building in which explosives or highly flammable substances are manufactured, used, handled or
stored;
(b) Storage tanks containing oils, paints or other flammable liquids;
(c) Grain elevators;
(d) Buildings, tall chimneys or stacks where flammable gases, fumes, dust or lint are likely to be
present; and
(e) Sub-station buildings and outdoor transformers and switch yards.

These requirements are also spelt out in the CEA regulations for and switch yards and Transformers. The
IS code 2309 1989 can be referred for details of design and protection requirements.

iii) Electrical equipment grounding and bonding ;

One of the most important reasons for grounding electrical currents is that it protects your appliances,
your home , Industry and everyone in it from surges in electricity.

In electrical engineering, ground or earth is the reference point in an electrical circuit from which
voltages are measured, a common return path for electric current, or a direct physical connection to
the earth.

A rule-of-thumb used by many in the industry is that Neutral to ground voltage of 2V or less at the
receptacle is okay, while a few volts or more indicates overloading; 5V is seen as the upper limit.

CEA regulation of 2010 (safety ) regulation 41, connection with earth , and regulation 42 earth leak
protection devices and regulation 48 high voltage equipment earthing give legal requirements about
earth connection. .

STATIC ELECTRICITY
Some common sources of static electricity which are experienced in industry are as follows:
• Pulverized materials passing through chutes or pneumatic conveyors,
• Steam or air/gas flowing from any opening in a pipe or hose, when steam is wet or the air or gas
stream contains particulate matter, e.g. steaming of hydrocarbon tanks while cleaning or use of
steam educators for tank degassing/ ventilations & use of steam/air lances.
• Non-conductive power transmission belts or conveyor belts in motion.
• Moving vehicles.
• Motion of all sorts that involve changes in relative position of contacting surfaces, usually of
dissimilar liquids or solids, e.g. Loose wooden /metallic pieces/ projections in tanks /pipes /
vessels, etc.
• Hydrocarbon flow through microfilters made of paper/felt elements.
• Hydrocarbon liquids flowing at high velocities in pipes/nozzles/fittings, etc.
• Spraying/splashing and misting, such as Free fall of liquid droplets through vapor spaces. ,
Splash loading of hydrocarbon liquids.
• Agitation/mixing & blending including mechanical mixing/agitation with air /steam/gas/ jet nozzles.

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To ensure the static charge so developed does not result in fire following two basic requirement must be
met.

BONDING : Sparking between two conducting bodies can be prevented by an electrical bond attached to
both bodies. This bond prevents a difference in potential across the gap because it provides a conductive
path through which the static charges can recombine. No charge, therefore, can accumulate & no spark
can occur.

GROUNDING :The earth may be used as part of the grounding system. Where the only gaps over which
hazardous static sparks can occur are between an insulated object and grounded object, such as
between electrically insulated vessels and grounded piping, the electrical insulation may be by passed by
rounding the vessel. This will prevent the accumulation of static charge on the vessel

d) EXPLOSIVE SUBSTANCES

An Explosive Act regulate the manufacture, possession, use, sale, transport, import and export of
Explosives. The act underwent revision in year 1983 .This covers

 The Static and Mobile Pressure Vessels, SMPV (unfired) Rules, 1981
 The Gas Cylinder Rules 1981/ 2004
 Indian explosive rules1981/2008
 Recently the Ammonium Nitrate chemical has come under Explosive Act and Ammonium
nitrates rules 2011 are farmed .As per that rule Any storage exceeding five kg need license and
Storage shed needed to be constriction IS 2309 , storage tank requirements and distance are
specified in the rules .
 Indian Explosive rules underwent major revision in year 2008 and it now covers following ,
Plastic explosives mines/rock blasting explosives , crackers, etc., any storage of these types
explosive more than 15 kgs requires license from CCOE Nagpur . Sound emitting fireworks.—
Fireworks with sound level not exceeding 125 dB or 145dB (C) pk at 4 meters distance from the
point of bursting. Shell of diameter exceeding 25 mm needs CCOE clearance
 All explosives are governed under explosive rules the silent points rules given below to ensure
compliances

THE EXPLOSIVES RULES, 2008 – AN OVERVIEW

The Explosive Rules, 1983 have been completely revised and new Explosives Rules, 2008 have come
into force vide Govt. of India, Ministry of Commerce and Industry, DIPP Notification No. GSR 907(E)
dated 29/12/2008. The Explosives Rules, 1983 have been modified taking into consideration modern
technology, harmonization of international practices/regulations and enhancement of safety and security
aspects. The highlights of the Explosives Rules, 2008 with respect to changes made in the Rules, 1983
are provided ensuing paragraphs.

Assimilate changes in Technology adopted in mining & manufacturing of explosives.

There have been many changes due to technological advancement in manufacture and application of
explosives. Deployment of mechanized mining for higher productivity has resulted in more use of bulk
explosives (site mixed explosives & bulk loading into deep bore holes in open cast mining with the help of
Bulk Mixed Delivery Vehicle) instead of traditional cartridge explosives.

Harmony in current international practices/UN Regulation

Due to Globalizations of trades and India being a signatory to WTO agreement, certain provisions have
been incorporated to bring the Indian explosives regulations in line with International/United Nations
Regulations, viz

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 • Provisions of UN Classification, UN No. and UN Regulation have been incorporated within the
Rules [Rule 2(58, 59 & 60)].
• Explosives have been grouped depending upon their compatibility for the purpose of packaging
for transport, import and export as per UN Classification code of hazardous goods. (Part-3 of
Schedule-I) & Part-2 of Schedule-II)
• Provision has been made for testing of the packaging for explosives as per UN classification
recommendation on transport of dangerous goods and also as per International Maritime
Dangerous Goods (IMDG) Code. (Item No.D-19 of Part-2 of Schedule-IV)

Delegation and enhancement of the licensing power to District Authorities to facilitate small users
• To mitigate the hardships of small users of explosives for their own use in quarries, road
construction, etc., District Authorities being easily accessible, have been authorized to grant licence
for possession and use up to 25 Kg of Class 1 or Class 2 explosives, 1500 Nos. of Detonators and
1500 meters Detonating Fuse or Safety Fuse. [Article.3(a) of Part I of Schedule IV] as against 5 Kg
explosives, 100 nos. Detonators and 200 Meter Safety Fuse by the District Authorities in the Rules,
1983.
• In the Rules, 2008 the District Authorities have been authorized to grant display licenses to mitigate
the hardships of such organizers (Article 6 of Part I of Schedule IV). In the Rule, 1983 the Circle
offices of PESO issues licence for display of fireworks in Form-29.
• Again to facilitate organizers of temple festival, District Authorities have been authorized to grant
licence for possession of 15 Kg gunpowder for manufacture of Adirvettus (Kadina) (Article 2 of Part I
of Schedule IV).

Simplification of procedure for grant of licence

• Provision of single application form for Export/Import of the Explosives (Rule 45 & 46, Application AE-
8).
• Documents required for obtaining approval and licence for different activities have been given in
tabular form (Rule 113). Thus relevant information is available at a glance. In the Rules, 1983 the
documents required for each type of license were given in different Rules.
• Number of stages in licensing procedure has been reduced i.e. 1st stage – the applicant has to take
approval of plans (Rule 101); 2nd stage – after completion of construction the applicant has to apply
for licence (Rule 105).
• The applicant can directly obtain NOC from the District Authority (instead of referring for NOC by
Chief Controller/Controller of Explosives as per current Rules), thus eliminating delay and saving
considerable time (Rules 102 & 103).

Facilitate the users to commission the facilities before endorsement of licence

• In the Rules, 1983 the licence come into force only after the inspection of Premises by the PESO
officer and its endorsement. This may cause delay in some case due to pre-occupation of inspecting
officer. In the Rules, 2008 the licence will come into force provisionally, with effect from its grant and
the user can commission the premises for possession, sale, use etc. of explosives – Rule 107 (3).

Longer validity of licence granted/renewed

• In the Rules, 1983 the licence for manufacture is granted/ renewed for a maximum period of 2 years.
In the Rules, 2008 it is for 5 years and for magazines for 10 years. (Rule 106).
• Late fee for renewal of application received within the validity of licence removed. (In the Rules, 1983
the late fee was payable if application is not received on or before 30 days of expiry of licence) (Rule
112(4)&(5)).
• Provision made for renewal of licence when application received after expiry up to three months with
late fee equal to half of annual licence fee. (In the Rules, 1983 licence can be renewed only if
application received within one month after expiry, that too with late fee equal to annual licence fee)
(Rule 112(6)).

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Transfer of licence
• There is no provision of transfer of licence in the Rules, 1983. As a result in the event of death of the
licensee or change of the management, fresh licence is to be granted after once again following all
the formalities for obtaining NOC from the District Authorities. To facilitate the heir of the licensee or
new management to continue their business, provision of transfer of licence has been incorporated in
the Rules, 2008 as user friendly measure (Rule 108).

Transparency & Clarity for user Industries and Regulating Authorities

• Several new specifications for different process sheds of Fireworks Manufacturing Units, BMD
vehicles, tractor compressors, etc. with sketches have been incorporated for guidance, transparency
and clarity to user industry and public (Schedule VII).
• Separation distances in between various process sheds of fireworks manufacturing units, maximum
allowed explosives limit and man limit in each shed have been incorporated for providing clarity/
guidance for planning fireworks industry as well as enhancing safety standard (Schedule VIII, Tables
4,5,6 & 7).

Enhancement of safety
• Provision for Safety Management System as per International norms for High Explosives Factories
made (Rules 26&27).
• Provision for employment of Competent Persons for supervision of Explosives Manufacturing made
(Rule 11).
• Procedures for granting recognition to Competent Persons (including foreman and short firer) made
along with specific formats of certificate for each activities. (Sub Rules (5) & (6) of Rule 107).

Enhancement of security & accountability

• Provision made for pasting photograph of licensee on the licence as per directives of Ministry of
Home Affairs (MHA), Govt. of India.
• Forms of various returns of explosives revised & upgraded.
• Accountability in transaction of explosives provided (Rule 77). The excerpts are below:
- Licence to transport explosives in road van (Form LE-7 bear the photograph of the licensee or
occupier.
- Indent Form RE-11 duly signed by the licensee or his authorized representative is mandatory
before dispatch of explosives.
- Photograph and specimen signature of the licensee or occupiers (consignee) is mandatory and
shall with the supplier of the explosives (consignor).
- Photograph, specimen signature the licensee’s authorized representative duly attested by the
licensee or occupier shall be filed with the supplier of the licensee.
- The supplier of the explosives shall verify the photograph and signature before effecting the
delivery.
- The authorized representative shall represent only one licensee.
• No person shall deliver or dispatch any explosives to any person other than the holder of a licence
and of kind and quantities authorized – Rule 4.
• Rule 47 – Every consignment of explosives transported under licence shall be accompanied by a
pass issued by the consignor in Form RE-12 giving details i.e., kind and qualities of explosives
dispatched, explosives van registration and licence no., giving the reference of Indent Form RE-11.
Such pass shall be attached to the weigh bill, invoice or dispatch note.
Copy of every pass in Form RE-12 shall be sent by the consignor to –
• the licensing authority who issued the licence of the consignor;

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• the Controller and the District Superintendent of Police of both jurisdictions i.e. sending and receiving
places.
• Rule 50 – The following documents shall always be available in the explosives van during transport of
explosives.
• copy of indent in form RE-11 under Part 5 of Schedule V, issued by the consignee.
• Copy of transport pass in form RE-12 under Part 5 of Schedule V issued by the consignor.
• copy of road van licence.
• Original copy of bill of explosives being transported.
• The documents mentioned above shall be produced by demand of authority empowered under Rule
128 during inspection.
• The licensee of road van shall maintain record of transaction of explosives in Form RE-6.
• The licensee of road van, compressor- mounted truck or tractor, as the case may be, should engage
only such drivers or cleaners, whose antecedents are verified by the local police. A list of such
drivers or cleaners along with all personal particulars should be made available to the local police in
advance to carry out the verification. Re-verification of such staff should be carried out at regular
intervals, preferably once in a year. The provision has been added in the Rule with the
recommendation of MHA – Rule 61 (3).
• Transport of the explosives is restricted to the period between sunrise and sunset.
• The driver or operator of a vehicle carrying or containing an explosive shall not stop unnecessarily or
for a longer than is reasonably required and shall avoid stops or places where public safety is in
danger – Rule 67(4).
• In case, where a van transporting explosives is required to be parked over night due to the reasons
beyond the control of licensee or the driver, the nearest police station shall be informed the location of
the temporary parking of the van.
• A road van while transporting explosives shall always be attended to by two armed guards at the
expense of the licensee. If the consignment of explosives is likely to pass through sensitive
areas notified by MHA, it should be escorted by armed police escort or guard, provided by the
District Police Administration – Rule 67(7). The provision has been added in the Rule with the
recommendation of MHA.
• Rule 128 – empowers District Authority and Police officials of the rank of Sub-inspector and above to
inspect, examine, search, seize, detain explosives van to ascertain the authenticity of the explosives
being transported or otherwise.

e) FIRE SAFETY IN HANDLING FLAMMABLE AND EXPLOSIVE MATERIALS

i) Emergency Procedures While handling chemicals adequate safety measures should be taken to
control hazards and prevent accidents. An accident involving a hazardous chemical has a potential to
cause serious injury, death or damage beyond the immediate vicinity of the accident site.

The Flixborough explosion in 1974 in the UK and the Bhopal MIC gas disaster in 1984 in India are the two
glaring examples of major chemical accidents. The Shri Ram Food & Fertilisers incident involving release
of Oleum in 1985 in Delhi; major fires in some Indian refineries in 1988, 1990 and 1997; the explosion in
the Maharashtra Gas Cracker Complex, Nagothane, Maharashtra in 1990; fire at ONGC Platform,
Bombay- High in July 2005 etc. are a few more examples of major accidents giving rise to emergencies.

The imperatives of preparedness to minimise adverse effects due to any accidents occurring in
manufacture, storage and transport of chemicals is well recognised. An emergency preparedness plan is
essential to negate such an eventuality of a major chemical emergency. In order to be in a state of
readiness to face adverse effects of chemical emergency, an emergency preparedness plan has to be
prepared both by the Occupier of the Industrial Activity and the District Emergency Authority. Such an
emergency plan for an installation is called the on-site emergency plan. These plans are to be
designed to provide for measures to contain an accident, minimize effects due to fire, explosion, release
of toxic gases, spillages of hazardous chemicals in storage, processing and transportation.

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Statutory Provisions

The Factories Act, 1948 and the Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989
and the Chemical Accidents (Emergency Planning, Preparedness and Response) Rules, 1966 notified
under the Environment (Protection) Act, 1986 are the important legislations containing statutory
requirements putting Responsibility for the preparation of emergency plans.
Plan should be based on risk analysis study and it should address all types of accidents that are possible
at that site –many locations plans do not address natural disasters . It also necessary display immediate
action to be taken when emergency such as fire, leakages , spillages occurs so that initiate actions can
expedite put the plan in action at short notice

ii) Facility is provided for safe drainage of combustible or flammable liquids

Blow down as defined in this document is a liquid stream containing water, oil, chemicals or a
combination of two or more of these which are required to be drained from various process equipment in
the hydrocarbon industry under different operating situations like start up, shutdown, normal operation or
emergencies. such facilities must exist in plant During start up of operation, it is required to drain or
vent/bleed hydrocarbon pumps occasionally.. If not handled properly, venting and draining of pumps
handling hot products can lead to hazardous conditions due to auto ignition.Vent and drains of each hot
pump should be provided with small sample cooler (located adjacent to pup at operating elevation) so
that the product is cooled Draining and venting of pumps handling LPG and other cryogenic products
should also be done very carefully. The products coming out of these pumps would flash immediately
giving large quantities of vapors and also create low temperature in the vent and drain piping. Such
pumps should be drained/vented to flare or to a closed vent header if there is no flare in the facility.

Storage tanks highly flammable liquids under inert atmosphere.; Fixed roof may be of cone type or dome
shaped be pressurized (to a few inches of water) type with breather valves. Alternatively, tanks may be
provided with fuel gas or inert gas blanketing to prevent oxygen/moisture ingress.. Where tanks are
blanketed, breathing-in will be from the blanketing gas system. Necessary control valve shall be provided
for supply of blanketing gas at constant pressure. The tank shall be provided with a safety valve by way of
lift disc/diaphragm or any other suitable device. Gauge hatch and other manholes shall be of gas tight
construction. For designing atmospheric/low pressure tanks, API 650 or API 620 may be followed based
on the type of the tank.

flame arrestors for tanks; A Flame Arrester also spelled arrestor is a device which allows gas to pass
through it but stops a flame in order to prevent a larger fire or explosion. Flame arrestors are installed
below pipe vents to prevent a flame front from moving backwards into the pipes and vessels below the
vent tip (this backward movement can occur when the mixture is in the flammable range but the velocity
at the open end exceeds the flame propagation velocity). Flame arrestors are reported to be provided on
tanks with atmospheric vents on materials with a flash point of 0-10 provision of Flame arrestor on tank is
not statutory requirement .

PPE for handling Flammable materials :

Whenever flammable or combustible liquids are used and stored at a worksite, everyone onsite must be
provided with personal protective equipment appropriate to the job they do and how much exposure they
have to the chemicals. Deciding which PPE to use at your worksite will begin with the Material Safety
Data Sheets (MSDSs) for each of the flammable liquids. An MSDS contains a section which details the
type of PPE required when handling the flammable substance. This information will form the basis of your
risk assessment which will consider the way the flammable liquids are being used at your workplace.

Workers should wear eye protection when handling flammable liquids. Of course the type of eye
protection worn will depend on the toxicity of the chemical (is it corrosive or carcinogenic?) as well as the
way it is being handled (is the dispensing or refueling station fully contained or is there a risk of the fuel
splashing onto the face or eyes?).

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Eye protection can include safety glasses, goggles, and face shields and you should make sure the units
are chemical resistant and fitted to each worker individually. When goggles or eye guards don’t fit
correctly they could distract a worker filling a container with petrol, causing them to lose focus and make a
dangerous error.
Protective clothing Wearing protective clothing like overalls is often specified on the Material Safety Data
Sheets (MSDSs) for various fuels, solvents and flammable liquids. Again research the clothing well to
make sure it’s compatible with the chemicals being used.

Breathing Apparatus; when breathing apparatus is required at a worksite, make sure that respirators
having appropriate filters, and any self-contained breathing apparatus complies with. Always check the
MSDS thoroughly and consult your chemical supplier when breathing apparatus is required.

f) FIRE DETECTION AND ALARM SYSTEM

Fire Detection and Alarm System has always been a key factor of safety, security and protection of life
and property.

Life and property are exposed to constantly changing threats and hazards. We should decide the right
solutions, employing innovative technology and well thought out protection concepts. Deciding on which
protection measures and how many of them should be implemented requires great skill on the part of the
fire protection engineer, both in evaluating the protection needs and prescribing adequate protection
measures.

The basic objective of effective fire protection measures is to protect human lives, material assets and the
environment from dangers and the effects of fire. Only by employing a series of different protection
measures is it possible to reduce the fire danger to such an extent that the required level of safety is
achieved. Fire detection and alarm is an important part of active fire protection system as it precedes fire
extinguishment or other fire damage control systems.

Personnel protection is normally governed by laws and ordinances. Asset protection is usually governed
by insurance companies which publish corresponding guidelines and regulations.

The laws and regulations will have in all cases precedence over the national standards and
recommendations of agencies like insurance companies and must be conscientiously taken into
consideration when planning a fire detection system. In cases where no laws or ordinances exist, then a
fire detection system should be planned in accordance with sound fire detection and protection
engineering practice.

Detection systems

Various types of detection systems are employed in high hazard industries in critical areas as follows:
• Smoke detector - lionization, photo-electric types
• Heat detectors - fixed temperature, rate of rise, sprinklers, etc.
• Flame detectors - infra red, ultra violet, spark types

We like discuss in detail two most common smoke detectors used detect fire in commercial building
houses sub stations malls etc.

There are two main types of smoke detectors: ionization detectors and photoelectric detectors. A smoke
alarm uses one or both methods, sometimes plus a heat detector, to warn of a fire. The devices may be
powered by a 9-volt battery, lithium battery, or 120-volt house wiring.

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Ionization Detectors

An ionization smoke alarm uses a small amount of radioactive material to ionize air in the sensing
chamber. As a result, the air chamber becomes conductive permitting current to flow between two
charged electrodes. When products of combustion enter the chamber, the conductivity of the chamber air
decreases. When this reduction in conductivity is reduced to a predetermined level, the alarm is set off.
Most smoke alarms in use are of this type.
Ionization detectors have an ionization chamber and a source of ionizing radiation. The source of ionizing
radiation is a minute quantity of americium-241 (perhaps 1/5000th of a gram), which is a source of alpha
particles (helium nuclei). The ionization chamber consists of two plates separated by about a centimetre.
The battery applies a voltage to the plates, charging one plate positive and the other plate negative.
Alpha particles constantly released by the americium knock electrons off of the atoms in the air, ionizing
the oxygen and nitrogen atoms in the chamber. The positively-charged oxygen and nitrogen atoms are
attracted to the negative plate and the electrons are attracted to the positive plate, generating a small,
continuous electric current. When smoke enters the ionization chamber, the smoke particles attach to the
ions and neutralize them, so they do not reach the plate. The drop in current between the plates triggers
the alarm.

Ionization models are best suited for rooms that contain highly combustible materials that can create
flaming fires. These types of materials include flammable liquids, newspapers, and paint cleaning
solutions.

Photoelectric Detectors

A photoelectric type smoke alarm consists of a light emitting diode and a light sensitive sensor in the
sensing chamber. The presence of suspended products of combustion in the chamber scatters the light
beam. This scattered light is detected and sets off the alarm.

Details :

In one type of photoelectric device, smoke can block a light beam. In this case, the reduction in light
reaching a photocell sets off the alarm. In the most common type of photoelectric unit, however, light is
scattered by smoke particles onto a photocell, initiating an alarm. In this type of detector there is a
T-shaped chamber with a light-emitting diode (LED) that shoots a beam of light across the horizontal bar
of the T. A photocell, positioned at the bottom of the vertical base of the T, generates a current when it is
exposed to light. Under smoke-free conditions, the light beam crosses the top of the T in an uninterrupted
straight line, not striking the photocell positioned at a right angle below the beam. When smoke is
present, the light is scattered by smoke particles, and some of the light is directed down the vertical part
of the T to strike the photocell. When sufficient light hits the cell, the current triggers the alarm.

Photoelectric models are best suited for living rooms, bedrooms and kitchens. This is because these
rooms often contain large pieces of furniture, such as sofas, chairs, mattresses, counter tops, etc. which
will burn slowly and create more smouldering smoke than flames.

Which Method is Better?

Both ionization and photoelectric detectors are effective smoke sensors. Both types of smoke detectors
must pass the same test to be certified as UL smoke detectors. Ionization detectors respond more quickly
to flaming fires with smaller combustion particles; photoelectric detectors respond more quickly to
smouldering fires. In either type of detector, steam or high humidity can lead to condensation on the
circuit board and sensor, causing the alarm to sound. Ionization detectors are less expensive than
photoelectric detectors, but some users purposely disable them because they are more likely to sound an
alarm from normal cooking due to their sensitivity to minute smoke particles. However, ionization
detectors have a degree of built-in security not inherent to photoelectric detectors. When the battery starts
to fail in an ionization detector, the ion current falls and the alarm sounds, warning that it is time to change
the battery before the detector becomes ineffective. Back-up batteries may be used for photoelectric

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detectors. “It's impossible to say which one is better , photoelectric smoke alarms may respond slightly
faster to smouldering fires, while ionization alarms respond slightly faster to flaming fires

Inspection and testing to be done as follows

 OEM requirements.
 IS:2189:2008
➢ Initial Installation Tests
➢ Maintenance Schedules
➢ Daily by User : Panel indications / faults
➢ Weekly : Operate one device. (complete all zones in 13 weeks), battery checks.
➢ Yearly : operation of at least 20% devices in year.

g) PASSIVE AND ACTIVE FIRE PROTECTION SYSTEM

i) Passive Fire Protection ;Passive Fire Protections contain an effect or reduce the impact of an
occurrence, instead of trying to tackle the cause or prevent the occurrence by:-
• Delaying the growth of the fire.
• Delaying the collapse of the building structure.
• Use of fire rated partitions / doors and other material to prevent the fire and smoke from moving
from one compartment to another

Application for Passive Fire Protection are in following areas :

• Structural fire protection
• Safe escape routes / safe removal for occupants.
• Compartmentation and containment of fire spread
• Life safety of fire service personnel.

Types of Passive fire protection

• Fire Proofing of structural members
• Fire Separation Walls in concealed space/Electrical Substation/ transformer yard/bays/ cable
galleries.
• Fire Seals in underground sewer system / Flare Knock out Drums
• Pressurization of Enclosure
• Fire retardant coatings and tapes for cables
• Flame proof and flame resistant electrical enclosure.
• Insulation of hot surfaces
• Fire doors
• Fire retardant paints
• Spark Arresters

ii) The Fire dampers can be consider as one of passive fire protection as it prevent the spread
of fire through heating, ventilation, and AC ducts, which helps to stop a fire from spreading throughout
the rest of the building . They also help to prevent smoke from traveling through the building's ductwork in
the event of a fire. A fire damper closes once the duct temperature reaches a high enough level to melt
a fusible link. Provision of same is highlighted in NBC codes. Factory rules many states have spelled out
rules for this for example rule 70 of Maharashtra factory rule it is sated that , 1) for Process, equipment,
plant etc. involving serious exposing and serious fire hazards:- (c) ventilation ducts, pneumatic conveyors
and similar equipment involving a serious fire risk should be provided with flame arresting or automatic
fire extinguishing appliances, or fire resisting dampers, electrically inter-locked with heat sensitive/smoke
detractors and the air-conditioning plant system;

Active Fire Protection Systems Which includes manual or automatic fire detection and fire
suppression, for example sprinkler , deluge wall , inter gas flooding systems etc

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FIXED WATER SPRAY SYSTEM It is a fixed pipe system connected to a reliable source of water supply
and equipped with water spray nozzles for specific water discharge and distribution over the surface of
area to be protected. The piping system is connected to the hydrant system water supply through an
automatically or manually actuated valve which initiates the flow of water.
Fixed water spray system should be provided in high hazard areas where immediate application of water
is required, for example as per Oil industry norms
• Class 'A' Petroleum storage in above ground tanks shall have fixed water spray system, whether
floating roof or fixed roof.
• Class 'B' Petroleum storage tanks - Floating roof tanks of diameter larger than
30 M. and - Fixed roof tanks of diameter larger than 20 M.
• Un-insulated vessels having capacity larger than 50 m3 and containing class A or B flammable
liquid.
• Hydrocarbon Vessels inaccessible to fire tender/ mobile equipment, fire hydrants
• Pumps handling petroleum products class 'A' under pipe racks.
• Pumps handling products above auto-ignition temperature under pipe racks
• Air fin coolers in hydrocarbon service located above pipe racks / elevated location.
• Water spray rings for columns of height more than 45 M should be provided
• Oil loading/unloading Tank Truck &Tank Wagon Gantries shall be provided with water spray
and/or foam system.
• Automatic water spray system for pressurized storage of hydrocarbons such as LPG, Propane,
Hydrogen etc.
• As Per CEA Regulation 44(2)(ix) all transformers having oil more than 2000 liters must be
provided fixed water spray system.
• Also water spray system are provided in electrical cable gallery ,

FIXED WATER SPRINKLER SYSTEM

Fixed water sprinkler system is a fixed pipe tailor made system to which sprinklers with fusible bulbs are
attached. Each sprinkler riser/system includes a controlling valve and a device for actuating an alarm for
the operation of the system. The system is usually activated by heat from a fire and discharges water
over the fire area automatically.

Sprinkler systems are used for fire extinguishment when the hazards located inside buildings. Some of
the examples being:
a) Car parking in basement
b) Building/sheds storing combustible and flammable materials.
c) office building

Note :IS 15105 code gives details on fixed auto sprinkler system for all types of occupancies auditors
must refer this code.

Inspection and Maintenance of Fire Protection System .

Maintaining reliability throughout the entire life cycle of a fire alarm system involves three distinct and
equally important tasks which must be performed on a periodic basis: (1.) visual inspections, (2.)
functional testing and (3.) maintenance activities. Many overlook the need to visually inspect the fire
system and concentrate only on the functional testing of the components. However, each of these tasks
are necessary and contribute to the assurance of a fire system that is ready to perform in the case of a
fire. Periodic Visual Inspections

A periodic inspection is a visual examination of the equipment to verify that nothing has changed from the
initial design and installation that would affect its performance. Those charged with performing an
inspection should be looking for a number of conditions which might affect the system’s ability to perform
when called upon. A proper visual inspection should consider whether building modifications or

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occupancy changes would have an impact. A fire alarm strobe light designed and located to disperse
light throughout an entire room may now be ineffective due to a reconfigured floor plan. Another important
consideration is a change in environmental conditions. Increased cooling systems to support greater
heat loads might be producing airflow rates impacting the need to adjust the design spacing of the ceiling
smoke detectors. Building owners should also ensure that a visual inspection of the equipment includes
identification of changes such as physical obstructions, device orientation, physical damage, degree
of cleanliness and any other obvious problem that may not be indicated by the control panel
automatically through electrical supervision. A minimum standard for these periodic visual inspections can
be should be made.

Periodic Testing

Periodic testing is intended to validate the functionality of the fire protection system. Tests are performed
by operating each component of the system to assure it performs as required in the case of an actual
emergency event. A simple example of this sort of testing is to pull the lever of each Manual Fire Alarm
Pull Station to ensure it performs as intended and initiates the required alarm condition. A proper testing
program should also include testing the operation of all Emergency Control Functions in the system such
as elevator recall or HVAC shutdown. NFPA 72, the National Fire Alarm and Signalling Code (2010
Edition), requires these functions to be tested at the same frequency as the device which initiates the
action. For instance, if corridor smoke detectors activate the closure of fire doors, then this function must
be tested annually to match the testing requirement of the smoke detector. Beyond just a simple
functional test, the test method for many components may also involve the use of calibrated test
equipment. One example of this is a duct smoke detector used to control the spread of harmful smoke. A
proper test of this device not only must verify smoke will initiate an alarm, but also that the airstream of
the ductwork is effectively being sampled. So in addition to the functional smoke entry test for the smoke
detector, a anemometer is used to measure the airflow from the sampling tube. This measurement is then
compared to the acceptable range published in the manufacturer’s instructions to determine if the device
is performing as designed. A minimum standard for these periodic tests can be found in Table
14.4.5 Testing Frequencies and Table 14.4.2.2 Test Methods of the National Fire Alarm and Signalling
Code (NFPA 72).

Maintenance

Maintenance is the work necessary to keep the fire system operating properly. One form of maintenance
is simply a response to a failure identified by a visual inspection or a test of the equipment. Service
personnel should notify the system owner immediately whenever deficiencies are found during routine
inspection and testing procedures. Considering the fact that life safety and/or mission continuity may be
at risk, repairs should be made as soon as feasibly possible by qualified personnel. Whenever repairs
are not made immediately, a temporary alternative means of protection should be put in place until the
fire system is returned to an acceptable level of readiness. Another important form of maintenance is of a
preventative nature. Many components in a fire protection system will require preventative maintenance
at a prescribed frequency. These maintenance activities address components that degrade over time,
have a finite lifespan or require periodic resetting or calibration. For example, most fire alarm systems
utilize lead-acid type batteries as a secondary (backup) power supply. Although NFPA codes require
routine testing to verify voltage levels are at an acceptable level, a preventative maintenance requirement
exists requiring their replacement at 5 years from the date of manufacture. Another important preventative
maintenance task involves regular cleaning of smoke detectors. Typically the detector manufacturer’s
published instructions will provide both the recommended frequency and method for cleaning, but
consideration should be given to adjusting these based on the environment where they are located.

Following are Indian standers can be referred for Inspection and maintenance basic firefighting
equipment.
• IS 2189: Selection, Installation and Maintenance of Automatic Fire-Detection and Alarm System--
Code of Practice
• IS 2190 -2010 selection, installation and maintenance of first-aid fire extinguishers
• IS 15301: 2003 FIRE PUMP-inspection & Maintenance

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 • IS 13039: 1991 external hydrant systems inspection & Maintenance
• IS 3844: 1989 code of practice for installation and maintenance of internal fire hydrant & hose
reels
• IS 15105 Design and Installation of Fixed Automatic Sprinkler Fire Extinguishing Systems - Code
of Practice
• OISD -STD-142 Inspection of Firefighting Equipment and system

h ) FIXED FIRE EXTINGUISHING SYSTEM

Fire water Storage

Fire water shall be stored in any easily accessible surface or underground lined reservoir or above ground
tanks of steel concrete or masonry. Fire water supply shall be preferably from fresh water source such as
river, tube well or lake. Where fresh water source is not easily available, fire water supply may be sea
water or other acceptable source. The installation shall have facilities for receiving and diverting all the
water coming to the installation to fire water storage tanks in case of an emergency.

Fire Water Pumps

Fire water pumps shall be installed to meet the design fire water flow rate and head. A minimum of 50%
standby pump(s) (minimum one no.) of the same type and capacity as the main pumps shall be provided.
The fire water pump(s) including the standby pump(s) shall be of diesel engine driven type. Where
electric supply is reliable 50% of the pumps may be electric driven. The diesel engines shall be quick
starting type with the help of push buttons located on or near the pumps or located at a remote location.
Each engine shall have an independent fuel tank adequately sized for 6 hours continuous running of the
pump.

Fire water pumps & storage shall be located at 30 metres (minimum) away from equipment or where
hydrocarbons are handled or stored. Fire water pumps shall be exclusively used for fire fighting purpose
only. The fire water network shall be kept pressurized by a static tank or jockey pump(s). Where jockey
pumps are used, the capacity of pump shall be sufficient to maintain the system pressure in the event of
leakages from valves etc. The power supply to the fire pump(s) shall be independent of all other supplies
within the premises. In other words even when the power supply to the entire premises is switched off,
the supply to the fire pump(s) and other essential equipment shall remain uninterrupted.
➢ Hydrant system
➢ Sprinkler system
Fire Hydrants
A well designed and well laid hydrant service is the backbone of the entire fire fighting equipment as it
fights fires of serious proportions in all classes of risks and continues to be in full operation even if part(s)
of affected buildings and/or structures have collapsed, and also keeps cool all adjoining properties,
thereby minimising the exposure hazards.

The fire water pressure system shall be designed for a minimum residual pressure of 7 kg/cm2g at the
hydraulically remotest point of application at the designed flow rate at that point.

Model rule 68.13

Provision of Automatic sprinklers & fire hydrants shall be in addition to first aid fire fighting

TAC

Hydrants for the protection of combustible/flammable liquid storage tanks (table 1) & bullets, sphere (table
2) located beyond 15 m, but within 35 m of tank shell

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(Table 1)
Dia. of Flammable Storage TANK No. Of Hydrants
Tanks up to 10 m dia. 1 double headed or 2 single headed hydrants.
Tanks above 10 m but up to 20 m dia. 2 double headed or 4 single headed hydrants.
Tanks above 20 m dia. 3 double headed or 6 single headed hydrants.

(Table 2)
WATER CAPACITY NO. OF HYDRANTS
3 3 single hydrants (or 1 single + 2 double headed hydrants)
Up to 50 m
3 3 1 monitor + 2 single (or 1 double headed hydrants)
Above 50 m but up to 150 m
3 2 monitors + 4 single hydrants (or 2 double headed hydrants)
Above 150 m

➢ Fire hydrants shall be provided in the network to ensure protection to all the facilities. The fire water
network shall be laid in closed loops as far as possible to ensure multi-directional flow in the system
➢ Each hydrant shall have two outlets inclined towards the ground. The outlets shall be of female
instantaneous type having a standard size of 63 mm conforming to Indian Standards.
➢ Hydrants shall be located keeping in view the fire hazards at different sections of the premises to be
protected and to give most effective service. At least one hydrant post shall be provided for every 30 M
of external wall measurement or perimeter of unit battery limit in case of high hazard areas.
➢ Hydrants protecting utilities and miscellaneous buildings in high hazard areas may be spaced at 45 M
intervals. The horizontal range and coverage of hydrants with hose connections shall not be
considered more than 45 M.
➢ The hydrants shall be located at a minimum distance of 15 M from the periphery of storage tank or
hazardous equipment under protection. Hydrants and monitors shall not be installed inside the dyed
areas. For process plants location of hydrants shall be decided based on coverage of all areas. In the
case of buildings, this distance shall not be less than 5 M and more than 15 M from the face of building
➢ Provision of hydrants within buildings shall be in accordance with Standard IS Standard-3844.
Hydrants / Monitors shall be located along road side beams for easy accessibility as far as possible.
➢ Double headed hydrants with two separate landing valves on 4" stand post shall be used. All hydrant
outlets shall be situated at a workable height of about 1.2 meter above ground level.
➢ Hydrants / Monitors shall be preferably located with branch connections and not directly over main
header for easy accessibility.
➢ IS codes 13039 of 1991, IS 3844 -1985 and IS 2189 can further referred for installation and
maintenance of hydrant system.

FIXED WATER SPRAY SYSTEM

It is a fixed pipe system connected to a reliable source of water supply and equipped with water spray
nozzles for specific water discharge and distribution over the surface of area to be protected. The piping
system is connected to the hydrant system water supply through an automatically or manually actuated
valve which initiates the flow of water.

Fixed water spray system should be provided in high hazard areas where immediate application of water
is required, for example as per Oil industry norms

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➢ Class ‘A’ Petroleum storage in above ground tanks shall have fixed water spray system, whether
floating roof or fixed roof. Class 'B' Petroleum storage tanks - Floating roof tanks of diameter larger
than 30 M. and - Fixed roof tanks of diameter larger than 20 M.
➢ Un-insulated vessels having capacity larger than 50 m3 and containing class A or B flammable liquid.
➢ Hydrocarbon Vessels inaccessible to fire tender/ mobile equipment, fire hydrants
➢ Pumps handling petroleum products class 'A' under pipe racks.
➢ Pumps handling products above auto-ignition temperature under pipe racks
➢ Air fin coolers in hydrocarbon service located above pipe racks / elevated location.
➢ Water spray rings for columns of height more than 45 M should be provided
➢ Oil loading/unloading Tank Truck &Tank Wagon Gantries shall be provided with water spray and/or
foam system.
➢ Automatic water spray system for pressurized storage of hydrocarbons such as LPG, Propane,
Hydrogen etc.
➢ As Per CEA Regulation 44(2)(ix) all transformers having oil more than 2000 litres must be provided
fixed water spray system.
➢ Also water spray system are provided in electrical cable gallery ,

Fixed Water Sprinkler System

Fixed water sprinkler system is a fixed pipe tailor made system to which sprinklers with fusible bulbs are
attached. Each sprinkler riser/system includes a controlling valve and a device for actuating an alarm for
the operation of the system. The system is usually activated by heat from a fire and discharges water
over the fire area automatically.

Sprinkler systems are used for fire extinguishment when the hazards located inside buildings. Some of
the examples being:

a) Car parking in basement

b) Building/sheds storing combustible and flammable materials.
c) Office building

Note: IS 15105 code gives details on fixed auto sprinkler system for all types of occupancies auditors
must refer this code.

Inspection and Maintenance

Following are Indian standers can be referred for Inspection and maintenance basic firefighting
equipment.

• IS 15301: 2003 FIRE PUMP-inspection & Maintenance

• IS 13039: 1991 external hydrant systems inspection & Maintenance
• IS 3844: 1989 code of practice for installation and maintenance of internal fire hydrant & hose reels
• IS 15105 Design and Installation of Fixed Automatic Sprinkler Fire Extinguishing Systems - Code of
Practice
• OISD -STD-142 Inspection of Firefighting Equipment and system

Good practices
• Display of fire pump auto logic
• easily accessible & no obstruction for it’s approach
• Physical Condition of hydrant network
• Display of hydrant network layout
• Installation of emergency PPE and nozzles at critical areas
• Availability of adequate first aid fire fighters at all shifts & display of names with contact details

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Questions
a. What are the sources of firewater and whether they are dedicated to the fire extinguishing
system?
b. Whether the capacity of dedicated water reservoir is adequate to supply to hydrants for minimum
2 h?
c. Whether un-interrupted power supply is provided to the firewater pumps?
d. Whether the extinguishing medium selected is appropriate to the class of fire (water, gaseous,
foam, dry powder)?
e. Whether fire hydrants layout is available?
f. Whether additional (over minimum requirement) fire hoses, nozzles are available?
g. Whether the hydrants lines are kept pressurized?
h. Whether regular inspection / maintenance / testing of fixed fire extinguishing systems carried out
and records maintained?

i ) PORTABLE FIRE EXTINGUISHING SYSTEM

Portable extinguishers are the first aid fire fighting equipment as first line of defence and control the fire at
early stage. IS 2190 -2010 selection, installation and maintenance of first-aid fire extinguishers should be
referred for installation of Portable extinguishers at company premises. It shall be located at convenient
locations and shall at all times be readily accessible and clearly visible. The maximum running distance to
locate an extinguisher shall not exceed 15 metres. It shall be placed as near as possible to exits or
staircase landings. Wherever possible, advantage shall be taken of normal routes of escape by placing
PFEs in positions where they can readily be seen by persons following the natural impulse to get out of
danger.

Spare charges to the extent of 10 % of the total number of extinguishers installed, with a minimum of two
shall always be kept in stock for each type of extinguisher and be readily available.

Good practices
• Display of inspection date, hydro test date, due date, id no.
• easily accessible & no obstruction for it’s approach
• Physical Condition of FE
• Display of PASS system (GP)
• Training records of fire fighting
• Checking-Awareness of First aid fire fighter
• Availability of adequate first aid fire fighters at all shifts & display of names with contact details

SCHEDULE FOR HYDRAULIC PRESSURE TESTING OF FIRE EXTINGUISHERS as per IS 2190 -

2010 selection, installation and maintenance of first-aid fire extinguishers

TYPE OF TEST INTERVAL PRESSURE PRESSURE

EXTINGUISHER (Years) (Kg/cm2) MAINTAINED FOR
(min)

Water-CO2 3 yrs 17.5 2.5

Water Stored Pressure 2 yrs 25 2.5

DCP 3 yrs 25 2.5

Mechanical Foam 3 yrs 17.5 2.5

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Sr Type of Extinguisher Thorough Maintenance Recharging Hydro Life
Inspection Interval yr Test span
Interval yr
Yr
1 Water type (gas cartridge)
5
(IS 940)

2 Water type (stored

pressure) (IS 6234)
2

3 Water type (gas cartridge)

(IS 13385) 5

4 Mech. foam type (gas

cartridge) (IS 10204) 5

5 Mech. foam type (stored 3

pressure) (IS 15397) Cl. 12.2.1
2 10
& 12.2.2
(g)
6 Mech. foam type (gas
cartridge) (IS 13386)
Monthly Cl.
Quarterly 5
11.11
(Cl. 11.13
and
Including
7 Mech. foam type (gas annually Cl.
Annex C)
cartridge) 135 ltr (IS 11.14)
14951) 2

8 Dry powder (stored

pressure) (IS l3849)

9 Carbon dioxide IS 2878

5 5 15
10 Clean agent (IS 15683)

11 Dry powder (gas 5

cartridge)(IS 3 10
2171/10658/11833)
3

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Questions
1) Whether suitable type and numbers of fire extinguishers provided?
2) Whether the fire extinguishers are located at conspicuous position and easily accessible?
Are they fully charged and tagged?
3) Whether fire extinguishers periodically inspected, tested, refilled and records maintained?
4) Whether defective / unchecked fire extinguishers present at site?
5) Whether additional fire extinguishers are available?

j) FIREFIGHTING EQUIPMENT AND FACILITIES

Hose Pipes and Nozzles

Sufficient length of hose, subject to a minimum of two lengths of 15 M each with couplings attached,
shall be provided for use in case of each hydrant point on risers. In addition, one nozzle of 20 mm size
fitted to a branch pipe shall also be provided. To avoid water damage, it is advisable to have reinforced
rubber-lined hoses for use with internal hydrants. (IS-636)

The number of hose pipes provided near external yard hydrants shall be such that no part of the floor is
more than 15 M from a hose nozzle when the hose is fully extended and connected to hydrant landing
valve.

Hoses, nozzles and branch pipes shall be kept adjacent to the hydrant outlet, in wall boxes or recesses
in the walls specially designed to blend architecturally with the buildings, if so desired.

The number of hoses stored in an oil installation shall be 30% of the number of hydrant outlets. The
minimum No. of hoses stored, however, shall not be less than 10. The hose station shall be located at
convenient and easily accessible location in the oil installation.

Fire hoses shall be tested once in 6 months to a minimum water pressure of 7 kg/cm 2 g.

Mobile firefighting equipment

Mobile firefighting equipment include foam tenders, water tenders, DCP tender a jeep with trailer etc.
Fixed foam system/Semi-Fixed system with foam tender shall be provided on Petroleum tanks (Floating
roof or fixed roof) exceeding 18 metres. dia. storing Class 'A' or Class 'B' products

COMMUNICATION SYSTEM
Adequate communication system like telephone/Public Address System/Paging System/ intrinsically
safe Walkie-talkie system should be considered at oil stations. Fire sirens should be tested once a
week. SCBA, fire suit and other emergency rescue kits should be provided at critical areas like cable
gallery, electrical MCC rooms, toxic and flammable chemicals bulk storages etc.

As per CEAR Reg-27

2 or more gas masks shall be provided in generating station with capacity of 5MW & transformation
capacity of 5 MVA & above for use in the event of fire or smoke

The fire protection equipment should be kept in good operating conditions at all the time and the fire
fighting system should be periodically tested for proper functioning and logged for record and corrective

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actions. Inspection of firefighting equipment should be done in accordance with OISD-standard-142 on
'Inspection of Fire Fighting Equipment and System'.

Good practices
➢ Emergency rescue kit installations at critical areas
➢ SCBA training and competitions for quick response in case of emergency
➢ Display Layout and numbering of emergency firefighting equipment

Questions
a) Whether fire tenders (water / foam) are available?
b) Whether the fire-fighting system and equipment approved, tested and maintained as per relevant
standard?
c) Whether the SCBA / fire suit provided to fire fighting team for immediate action?
d) What is system for maintenance / recharge of SCBA?
e) Is proper access available for fire fighting equipment?
f) Whether fire hose cabinets are in good condition, easily visible, and accessible?
g) What is the communication facility at fire station? Is it adequate?

k) FIRE DRILL

Practice drills should be arranged once in three months (each time in different units) to familiarize those
concerned with the actions expected of them, and at the same time testing the equipment available in
each unit. Fire explosion safety of the plant and extensions should preferably be checked every six
months in oil installations. There shall be regular mock fire drills, once a month. The record of such
drills shall be maintained.

As per NBC Code Part IV Fire drill - at least once in every 3 months for existing bldg. during the first
2 yrs. Thereafter at least once in every 6 months.

Mutual-aid scheme should be done with nearby industry to provide and get help in case of any
emergency.

Good practices

➢ All types of emergencies should be conducted as per on site emergency plan

➢ Drills should be conducted on holidays, night shifts to check the actual response

Questions

a. Whether mock fire drills are conducted? What is the frequency of drills?
b. Whether fire drills are also performed in night shift
c. Whether feedback of fire drill is documented?
d. What is the system of mutual-aid scheme?

l) Fire fighting training

Education and training of all employees is a first step in engaging them in discharging their OSH
responsibilities effectively. The statutes also require occupiers, employers to provide and make
adequate arrangements for training of all workers. Such trainings are to be imparted on regular basis
either in-house or can be arranged outside.

164
 The management should identify the training needs for fire staff. Programmes should be designed on
the principles of theoretical and practical inputs. The impact of training should also be assessed.
Schedule of training programmes should be prepared on annual/quarterly basis. Proper records of all
training programmes conducted in-house as well as list of personnel under-gone training out-side
should be maintained.

Questions

a. Whether there is a system of providing firefighting training to plant personnel?

b. What is the frequency and duration of such training? Whether training records are maintained?
c. Whether fire squads are identified for different areas for first-aid fire fighting and rescue, and
suitably trained?
d. Are all personnel conversant with the fire prevention and protection measures?
e. Whether the fire staff are sent for refresher / advanced training courses?

m) STATIC ELECTRICITY AND LIGHTNING ARRESTOR

Static Electricity is generated when two dissimilar materials are rubbed together and then separated
from each other. Static electricity occurs commonly in industry and in daily life and can be a source of
danger as well as discomfort or inconvenience. Sparks and arcs which result from switches, starters,
relays & similar devices have been rendered harmless by explosion-proof installations. However,
there exists an ever present fire hazard in the processing industries from ignition which may arise
from static sparks.

The principal methods used in industry to prevent the build-up of static electric charges to dangerous
levels are:
➢ Bonding and earthing of stationary conductive equipment;
➢ Increasing the conductance of floors, footwear, wheels and tyres;
➢ Increasing the conductivity of non-conductors by incorporating conductive additives, surface layers
and films, and by humidification of the atmosphere;
➢ Increasing the conductivity of the atmosphere by ionizing the air.

Electrical equipment grounding and bonding;

• One of the most important reasons for grounding electrical currents is that it protects your
appliances, your home , Industry and everyone in it from surges in electricity
• In electrical engineering, ground or earth is the reference point in an electrical circuit from which
voltages are measured, a common return path for electric current, or a direct
physical connection to the earth
• A rule-of-thumb used by many in the industry is that Neutral to ground voltage of 2V or less at
the receptacle is okay, while a few volts or more indicates overloading; 5V is seen as the upper
limit.
• CEA regulation of 2010 (safety) regulation 41, connection with earth , and regulation 42 earth
leak protection devices and regulation 48 high voltage equipment earthing give legal
requirements about earth connection. .

Some common sources of static electricity which are experienced in industry are as follows:

➢ Pulverized materials passing through chutes or pneumatic conveyors,

➢ Steam or air/gas flowing from any opening in a pipe or hose, when steam is wet or the air or gas
stream contains particulate matter, e.g. steaming of hydrocarbon tanks while cleaning or use of
steam educators for tank degassing/ ventilations & use of steam/air lances.
➢ Non-conductive power transmission belts or conveyor belts in motion.
➢ Moving vehicles.

165
 ➢ Motion of all sorts that involve changes in relative position of contacting surfaces, usually of
dissimilar liquids or solids, e.g. Loose wooden /metallic pieces/ projections in tanks /pipes /
vessels, etc.
➢ Hydrocarbon flow through microfilters made of paper/felt elements.
➢ Hydrocarbon liquids flowing at high velocities in pipes/nozzles/fittings, etc.
➢ Spraying/splashing and misting, such as Free fall of liquid droplets through vapor spaces. ,
Splash loading of hydrocarbon liquids.
➢ Agitation/mixing & blending including mechanical mixing/agitation with air /steam/gas/ jet nozzles.

To ensure the static charge so developed does not result in fire following two basic requirements
must be met

• BONDING: Sparking between two conducting bodies can be prevented by an electrical bond
attached to both bodies. This bond prevents a difference in potential across the gap because it
provides a conductive path through which the static charges can recombine. No charge, therefore,
can accumulate & no spark can occur.

• GROUNDING: The earth may be used as part of the grounding system. Where the only gaps over
which hazardous static sparks can occur are between an insulated object and grounded object, such
as between electrically insulated vessels and grounded piping, the electrical insulation may be by
passed by rounding the vessel. This will prevent the accumulation of static charge on the vessel

Lighting arrestors Rule 70 (3) of the Maharashtra factories rules, Protection from lightning shall be
provided for-
(a) Building in which explosives or highly flammable substances are manufactured, used, handled or
stored;
(b) Storage tanks containing oils, paints or other flammable liquids;
(c) Grain elevators;
(d) Buildings, tall chimneys or stacks where flammable gases, fumes, dust or lint are likely to be
present; and
(e) Sub-station buildings and outdoor transformers and switch yards.

• These requirements are also mention in the CEA regulations 2010 for and switch yards and
Transformers. The IS code 2309 1989 can be referred for details of design and protection
requirements.

Good practices

➢ An Earthing Relay along with suitable earthing clamps to ground the vehicle.
➢ Insulating material between lightning arrestor strip and structure

Questions

a. Whether all vessels and pipes are provided with suitable bonding and grounding?
b. Whether arrangement has been made for grounding the tanker containing flammable liquid during
loading / unloading?
c. Whether spark resistant tools are provided?
d. Whether lightning protection is provided and is adequate?
e. Whether antistatic clothing, hand gloves and footwear are provided?

166
REFERENCES

• The Factories Act 1948

• IS 14489
• Model Rules under The Factories Act, 1948
• The Building and Other Construction Workers‘ (Regulation of Employment and Conditions of
Service) Central Rules, 1998
• The Manufacture, Storage and Import of Hazardous Chemical Rules, 1989
• The Maharashtra Factories Rules, 1963
• The CEA Regulations 2010
• The Petroleum Rule
• The Gas Cylinder Rules, 2016
• National Building Code 2016

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A-5. INDUSTRIAL HYGIENE / OCCUPATIONAL HEALTH

a) Vibration, heat stress, Non-ionizing radiations, ventilation, illumination and noise

b) Work place monitoring for hazardous chemicals

c) First aid facilities and occupational health center (OHC)

d) Periodic medical examination

e) Personal protective equipment and emergency equipment

f) Occupational disease

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a) VIBRATION, HEAT STRESS, NON-IONIZING RADIATIONS, VENTILATION,
ILLUMINATION AND NOISE

1) INDUSTRIAL VENTILATION
Introduction:
It is well known that ventilation has profound influence on the maintenance of body temperature and
consequently on the health and well-being of the industrial worker. Ventilation is important for the control
of dust, fumes, gases, aerosols, climate and thermal comfort factors.

The Factories Act, 1948 stipulates that effective and suitable provision should be made in every factory
for securing and maintaining, in every work room, adequate ventilation by circulation of fresh air, and
such a temperature as will secure the workers therein a reasonable degree of comfort and prevent injury
to health.

Background:

Due to industrial processes / operations; heat, toxic / inflammable fumes, dust etc. are liberated. This
causes discomfort to the worker and affects his health and work environment. Exposure to different types
of dust can result in fibrosis of the lung, allergic reactions and asthma attacks. Various vapours, gases
and aerosols have the ability to cause respiratory and skin damage. Extremes of heat can reduce
concentration and motivation and cause a number of heat-related illnesses. Extremes of heat can also
reduce tolerance to chemical and noise exposure, and increase the risk of heart attacks. Thus
maintaining adequate ventilation at workplace is of utmost importance.

Ventilation has to perform following four functions to prevent injury to the health of worker–
1. Supply sufficient quantity of fresh air
2. Distribute the air adequately throughout the work room
3. Maintain reasonable condition of comfort for the workers
4. Remove contaminants like dust, vapours, gases(toxic/flammable), aerosols etc. from the work
environment

This can be achieved by providing natural ventilation or mechanical ventilation depending upon the
situation on the shop-floor.

Terminology:

Air Change per hour - The volume of outside air allowed into a room in one hour compared with the
volume of the room.

Contaminants - Dusts, fumes, gases, mists, vapours and such other substances present in air are likely to
be injurious or offensive to the occupants.

Dry Bulb Temperature — The temperature of the air read on a thermometer, placed in such a way as to
avoid errors due to radiation

General Ventilation — Supply of outside air either by positive ventilation or by infiltration into the building.

Local Exhaust Ventilation — Ventilation effected by exhaust of air through an exhaust appliance, such as
hood with or without fan located as closely as possible to the point at which contaminants are released so
as to capture effectively the contaminants and convey them through ducts to a safe point of discharge

169
Mechanical Ventilation — Supply of outside air either by positive ventilation or by infiltration by reduction
of pressure inside due to exhaust of air, or by a combination of positive ventilation and exhaust of air.

Natural Ventilation — Supply of outside air into a building through window or other openings due to wind
outside and convection effects arising from temperature or vapour pressure differences (or both) between
inside and outside of the building.

Positive Ventilation — The supply of outside air by means of a mechanical device, such as a fan

Threshold Limit Values (TLV) — Refers to air-borne concentration of contaminant and represent
conditions, under which it is believed that nearly all occupants may be repeatedly exposed, day after day,
without adverse effect.

Ventilation — Supply of outside air into, or the removal of inside air from an enclosed space.

Wet Bulb Temperature — The steady temperature finally given by a thermometer having its bulb covered
with gauze or muslin moistened with distilled water and placed in an air stream of not less than 4.5 m/s,

Legal Requirements:

Sr. Statute Section/ Sub Provision

No. Section/ Rule/ Sub
Rule
1 Section 13: (1) In every factory effective and suitable
provision shall be made for securing and
maintaining in every workroom--
(a) adequate ventilation by the circulation of
fresh air, and
(b) such a temperature which will secure
workers in reasonable conditions of
comfort and prevent injury to health;-
and in particular,-
(i) walls and roofs shall be of such
material and so designed that
such temperature shall not be
exceeded but kept as low as
practicable;
(ii) where the nature of the work
carried on in the factory involves,
or is likely to involve, the
production of excessively high
temperatures, such adequate
measures as are practicable shall
be taken to protect the workers.
Section 14: (Dust (1) In every factory in which, by reason of the
and fume) manufacturing process carried on, there is
given off any dust or fume or other impurity of
such a nature and to such an extent as is
likely to be injurious or offensive to the
workers employed therein, or any dust in
substantial quantities, effective measures
shall be taken to prevent its inhalation and
accumulation in any workroom, and if any
exhaust appliance is necessary for this

170
 purpose, it shall be applied as near as
possible to the point of origin of the dust,
fume or other impurity, and such point shall
be enclosed so far as possible.

(2) In any factory no stationary internal

combustion engine shall be operated unless
the exhaust is conducted into the open air,
and no other internal combustion engine shall
be operated in any room unless effective
measures have been taken to prevent such
accumulation of fumes there-from as are
likely to be injurious to workers employed in
the room.
Section 36 1) No person shall be allowed to enter any
(Precautions against chamber, tank, vat, pit, pipe, flue or other
dangerous fumes, confined space in factory in which any gas,
gases, etc) fume, vapour or dust is likely to be present
to such an extent as to involve risk to
persons being overcome thereby, unless it
is provided with a manhole of adequate
size or other effective means of egress.

2) No person shall be allowed to enter any

confined space until all practicable
measures have been taken to remove any
gas, fume, vapour or dust, which may be
present so as to bring its level within the
permissible limits and to prevent any
ingress of such gas, fume, vapour or dust
and unless- a certificate in writing has been
given by a competent person, based on a
test carried out by himself that the space is
reasonably free from dangerous gas, fume,
vapour or dust.
Section Where in any factory any manufacturing process
37 (Explosive or produces dust, gas, fume or vapour of such
inflammable dust, character and to such extent as to be likely to
gas, etc.) explode on ignition, all practicable measures shall
be taken to prevent any such explosion by
removal or prevention of the accumulation of
such dust, gas, fume or vapour.
Section 41-F The maximum permissible threshold limits of
(Permissible limits exposure of chemical and toxic substances in
of exposure of manufacturing processes (whether hazardous or
chemical and toxic otherwise) in any factory shall be of the value
substances) indicated in the 2nd Schedule of FA 1948.

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Sr. Statute Section/ Sub Provision
No. Section/ Rule/
Sub Rule
2 The Model Rules Rule 1) In any factory the maximum wet-
under the Factories 23 (Ventilation bulb temperature of air in a workroom at a height
Act 1948 and of 1.5 meters above the floor level shall
[The Model Rules temperature) not exceed 30° C and adequate air movement
have been framed by of at least 30 metre/minute shall be provided
DGFASLI 2) the amount of ventilating openings in a
(Directorate General, workroom below the eaves shall, except where
Factory Advisory mechanical means of ventilation, be of an
Service and Labour aggregate area of not less than 15% of the
Institute, an attached floor area and so located as to afford a
Office of Ministry of continued supply of fresh air
Labour and
Employment, The amount of fresh air supplied by mechanical means
Government of India) of ventilation an hour shall be equivalent to at least 6
for the guidance of times the cubic capacity of the workroom and shall be
the State distributed evenly throughout the workroom without
Governments to form dead air-pockets or undue draughts caused by high
State Factories inlet velocities.
Rules. Based on
these model rules,
various states have
prepared their State
Factories Rules and
hence the state
factory rules of the
states have similar
provision, however
the rule number may
be different.]
3 The Building and Sect 40 (2.g) the precautions to be taken to prevent inhalation of
Other Construction )Power of dust, fumes, gases or vapours during any grinding,
Workers Act, 1996 appropriate cleaning, spraying or manipulation of any material &
Government to steps to be taken to secure & maintain adequate
make rules for ventilation of every working place or confined place.
the safety and
health of
building
workers):
4 The BOCW Central Rule 153 The employer shall ensure at a construction site of a
Rules (Ventilation): building or other construction work that all work areas
in a free air tunnel are provided with ventilation system
as approved by the Director General & the fresh air
supplied in such tunnel is not less than 6 m3 / min for
each building worker employed underground in such
tunnel and the free-air-flow movement inside such
tunnel is not less than 9 m/min

Rule 63 (a.vi) The employer shall ensure at a construction site of a

(Operator’s cab building or other construction work that the operator of
or cabin): every lifting machine in outdoor service is provided with
a cab or cabin which is adequately ventilated.

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As per maintenance part :

1. All ventilating equipment shall be checked periodically and bearings of various moving parts
lubricated. The equipment shall also be tested for air delivery. Such tests shall be made at least once
in a year.
2. The surfaces of any cooling or heating units and air cleaning devices (including filters) shall be
inspected at frequent intervals for corrosion and dirt and when corrosion occurs the corroded parts
shall be carefully cleaned and protected with anti-corrosion paint or other suitable medium. Cleaning
of filters and heat transfer units shall be carried put regularly to promote their efficient use.

Guidance to check compliance:

1) Whether any ventilation study has been carried out in last 2 years?
2) Whether natural ventilation is adequate or not?
3) Whether dust/fumes/hot air is generated in the process?
4) Is there any exhaust ventilation system in any section of the plant?
5) Is periodic/preventive maintenance of ventilation system carried out and record is
maintained?
6) Does any ventilation system re-circulate the exhausted air in work areas?
7) Is the work environment assessed and monitored for chemical and physical hazards?
8) Whether PPEs are provided to workers exposed to dust/fumes and gases?

Documents to be checked:

1. Copy of the ventilation study report – its findings & action taken on the report.
2. Periodic/preventive maintenance schedule and maintenance records of ventilation system.
3. Periodic monitoring records/ Continuous monitoring records of chemical concentration in the work
environment.

Reference :

1. IS 3103:1975 – Code of Practice for Industrial Ventilation

2) HEAT STRESS

The heat stress on the human body result from two types of heat load – (i) External Heat (Environmental
Heat) and (ii) Internal Body Heat (Metabolic Heat).

The environmental heat load results basically from three mechanisms : conduction, convection, and
radiation. Besides, the human body generates heat due to intracellular oxidative processes (metabolism),
the metabolic heat, M, which is a combination heat generated by the basal metabolism and that resulting
from physical activity. In order that the body maintains “internal thermal balance”, the metabolic heat load
must be dissipated and this can achieved through conduction, convection and radiation (depending on
environmental conditions, the body may gain or loss heat through these mechanisms). In addition, heat
can also be lost by the body through another mechanism – the evaporative cooling (E), which the cooling
effect of the evaporation of perspiration from the skin (the evaporation of one litre of sweat removes 580
kcal heat from body to the surrounding environmental).

Heat Balance

Heat exchange between the human body and its environment follow certain physical laws and can be
expressed by mathematical equation, popularly known as the heat balance equation which can be
represented as follows:

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M±C±R–E=±S

Where M = the heat of metabolism depending on the amount of physical activity involved in the task.
C = Convective heat gain or loss
R = Radiant heat gain or loss
Both C & R depend on the climatic conditions of work environment.
E = Evaporative heat loss, it partly depends on the rate of sweating and partly on climatic conditions of
work environment, especially the humidity and vapour pressure on the surface of the skin. Sweat
produced on to the surface of the skin gets evaporated when the vapour pressure on the skin is higher
than that of the surroundings. Providing relief to the individuals. Air movement enhances evaporative heat
loss.

S = Amount of heat gain or loss by the body. When there is heat balance, there is no storage of heat (S =
O and accordingly equation may be represented as:

M ± C ± R – E = O (or M ± C ± R = E)

This would mean that heat generated internally, as well as heat received from the external environment
through convection and radiation could be dissipated solely by evaporation of sweat. Obviously the sweat
production should be much increased and this situation would place a definite strain on the human body.
Factors responsible for Heat Balance: Climatic and non-Climatic

Climatic Factors: Environmental factors determine as to how, and as to what extent, the metabolic heat
can be lost to the outside environment or as to how and as to what extend the body will gain heat from
the environment around, since:

C – depends on ambient air temperature and movement of air.

R – depends on the mean radiant temperature of hot equipment or process heat
E – depends on ambient air temperature, humidity and air movement

The thermal environment (climatic factors), therefore comprises the four climatic parameters: (i) air
temperature, (ii) air humidity, (iii) air movement, (iv) radiant heat.

The above parameters need to be measured simultaneously and at the same spot considering the
locations of the workers’ exposure.

Non-climatic factors: In addition to the climatic factors as stated above there are also other factors
(Non-climatic) to reckon with (i) the “rate of work”, (ii) whether or not an individual is acclimatised, (iii) the
“amount and type of clothing work”, (iv) “physical fitness level of the individual workers” (v) “age”, (vi)
“sex”, etc. which are likely to modify the level of discomfort or distress, and consequently the “heat strain”
developed among the individuals exposed to such environment.

Guidance to check compliance:

1) Are there sources from equipment increasing the heat load in work places?
2) Whether evaluation of heat stress is carried out?
3) Whether natural ventilation is adequate to minimize the heat stress in work environment?
4) Are resources available to deal with very hot or very cold conditions (drinking water, lined gloves,
insulated boots)?
5) Do workers know the symptoms of heat cramps /heatstroke or frost bite / hypothermia?
6) Are the personal protective equipment suitable for reducing the effects of heat stress available?

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3.) NON-IONIZING RADIATION

Non-ionizing radiation is described as a series of energy waves composed of oscillating electric and
magnetic fields traveling at the speed of light means in a simple word Non-ionizing radiation is a type of
low-energy radiation that does not have enough energy to remove an electron (negative particle) from an
atom or molecule.. Non-ionizing radiation includes the spectrum of ultraviolet (UV), visible light, infrared
(IR), microwave (MW), radio frequency (RF), and extremely low frequency (ELF). Lasers commonly
operate in the UV, visible, and IR frequencies. Non-ionizing radiation is found in a wide range of
occupational settings and can pose a considerable health risk to potentially exposed workers if not
properly controlled.

Ultra-Violet Radiation

Ultra Violet Radiation affects the skin causing burn, skin cancer and conjunctivitis. In welders it may
cause “Arc eye”

Infra-Red Radiations

Eye suffers more damaging effects due to this. They may cause fatigue and headache and cataract Glass
blowers cataract is the commonest example.

Microwaves Radiation

Cornea and lens of eye are the most vulnerable structures because of the lack of heat dissipating blood
vessels. Cataract and skin burns are similar to the infra-red radiation. The frequency of more than 30
mega Hertz is dangerous.

Laser beams
A laser beam is a beam light energy of one length and uniform phase in which waves trouble together in
step and in rhythm. Its application in cutting and welding operations, in photography and in medical use
for photo coagulation of retina is well known. Organ affected is mostly they eye.

Guidance to check compliance:

• Does the work involve likely exposure to non-ionising radiations (ultraviolet, infrared,
radiofrequency, microwaves, lasers, etc.)
• Whether risk assessment has been done for all work areas involving presence of non-ionising
radiations?
• Are the work areas displayed with relevant safety signs?
• Are the employees aware about the hazards of non-ionising radiations?
• Does written procedures exists for working in non-ionising radiations?
• Is the work environment monitored periodically for physical hazards and control measures
initiated whenever deviation from permissible values is observed?
• Whether suitable personal protective equipment are provided to workers exposed to non-ionising
radiations?

4.) Industrial Lighting and Illumination

Introduction:

Health and safety legislation has always placed an absolute or strict duty on employers to ensure that all
parts of a workplace, both internally and externally, are adequately illuminated. This has entailed the
provision of both ambient or background lighting to maintain safe working areas and specific lighting at

175
machinery and workstations where a higher level of lighting may be required because of the operational
requirements and the hazards arising from work activities.

Lighting levels need to be appropriate to the task and must comply with Indian Standard IS 6665:1972
“Code of Practice of Industrial Lighting”.

Background:

Most factories have a combination of natural and artificial lighting. However, little attention is paid to the
type of work – it is as though all work in the factory requires the same degree of lighting. From the
workers’ perspective, poor lighting at work can lead to eye‐strain, fatigue, headaches, stress and
accidents. Low levels of lighting can also cause depression. On the other hand, too much light can also
cause safety and health problems such as “glare” headaches and stress. Both can lead to mistakes at
work, poor quality and low productivity. Various studies suggest that good lighting at the workplace pays
dividends in terms of improved productivity and a reduction in errors.

Legal Requirements:
Sr. Statute Section/ Sub Provision
No. Section/ Rule/
Sub Rule
1 The Factories Section 17 (1) In every part of a factory where workers are working or
Act 1948 (Illumination) passing there shall be provided and maintained
sufficient and suitable lighting, natural or artificial, or
both.
(2) In every factory all glazed windows and skylights used
for the lighting of the workrooms shall be kept clean on
both the inner and outer surfaces and, so far as
compliance with the provisions of any rules made under
sub-section (3) of section 13 will allow, free from
obstruction.
(3) In every factory effective provision shall, so far as is
practicable, be made for the prevention of-
(a) glare, either directly from a source of light or by
reflection from a smooth or polished surface;
(b) the formation of shadows to such an extent as to cause
eye-strain or the risk of accident to any worker.
2 Model Rules Rule 35 The general illumination over interior parts of factory where
under the (Lighting of persons actually being working shall be not less than 65 lux
Factories Act interior parts) measures in the horizontal plane at a level of 90
1948 centimetres above the floor.
[The Model
Rules have The illumination over all other interior parts of the factory
been framed by over which persons employed shall, when and where a
DGFASLI person is passing, be not less than 5 lux at floor level.
(Directorate Rule 36 Where any source of artificial light in
General, Factory (Prevention the factory is less than 4.9 meters above floor level, no part
Advisory Service of glare) of the light source or of the lighting fitting having a
and Labour brightness greater than 1.55 candles per cm2 (4.87
Institute, an lamberts) shall be visible to persons whilst normally
attached Office employed within 30 meters of the source, except where the
of Ministry of angle of elevation from the eye to the
Labour and source or part of the fitting as the case may be, exceeds 20
Employment, degrees.
Government of
India) for the Any local light, that is to say an artificial light shall be

176
 guidance of the provided a suitable shade of opaque material to
State prevent glare or with other
Governments to effective means by which the light source is completely
form State screened from the eyes of every person employed at
Factories Rules. a normal working place, or shall be so placed that no such
Based on these person is exposed to glare there from.
model rules, Rule 65 Effective screens or suitable goggles shall be
various states (Protection of provided for the protection of persons
have prepared eyes) employed in or in the immediate vicinity of the following
their State processes :-
Factories Rules
and hence the The processes specified in Schedule II annexed to this rule
state factory (mentioned as follows), being processes, which involve risk
rules of the of injury to eyes by reason of exposure to excessive light or
states have infrared or ultra-violet radiations.
similar provision, 1. Welding or cutting of metals by means of an electrical,
however the rule oxy- acetylene or similar process.
number may be 2. All work on furnaces where there is risk of exposure to
different.] excessive light or infrared radiations.
3. Process such as rolling, casting or forging of metals
where there is risk of exposure to excessive light or
infrared radiations.
4. Any other process wherein there is a risk of injury to
eyes from exposure to excessive light or
infrared or ultraviolet radiations.
3 The Building Sect 40 (2.f) the adequate & suitable lighting of every workplace and
And Other Power of approach thereto, of every place where raising or lowering
Construction appropriate operations with the use of hoists, lifting appliances or lifting
Workers’ Government to gears are in progress & of all openings dangerous to
(Regulation Of make rules for building workers employed.
Employment & the safety and
Conditions Of health of
Service) Act, building
1996, workers:
4 The Building Rule 50 The employer shall ensure that illumination sufficient for
And Other Illumination of maintaining safe working conditions at a site of a building or
Construction passageways, other construction work is provided where building workers
Workers’ etc: are required to work or pass and for passageways,
(Regulation Of stairways and landing, such illumination is not less than that
Employment & provided in the relevant national standards.
Conditions Of Rule 124 Every employer shall ensure at a construction site of a
Service) Central (1 & 2) building or other construction that all workplaces where
Rules, 1998 Illumination: excavation or tunnelling works are carried out shall be
adequately illuminated in accordance with the relevant
national standards. Provide for emergency generators on
construction site to ensure adequate illumination at all
workplaces where excavation or tunnelling work is being
carried out, in case of power failure

Guidance to check compliance:

1) Is there good general illumination (with no glare) throughout the factory?
2) Is there regular cleaning and maintenance of lights and windows?
3) Where necessary, are windows or skylights whitewashed or shaded to avoid glare?
4) Is there local lighting for close work to reduce eye strain and fatigue?
5) Are "flickering" fluorescent tubes replaced as soon as possible?

177
 6) Are the walls and ceilings painted in light colours and kept clean?
7) Is there adequate emergency lighting in all areas?
8) Are outside areas satisfactorily lit for work and access during hours of darkness, for security as well as
safety?
9) Whether illumination study has been carried out for the assessment of illumination level in the last two
years?
10) Is there any system of periodical cleaning and replacing the light fittings/ lamps in order to ensure that
they give the intended illumination levels?
11) Are the workers subject to periodic optometry tests and records maintained?
12) Are emergency lighting available at First aid centre

Documents to be checked:
1. Illumination survey report.
2. Lights, windows, Skylights etc., cleaning & Maintenance records.
3. Optometry test records of workers.

5.) INDUSTRIAL NOISE

Introduction:

The noise from whatever source it comes from is undoubtedly, physiologically as well as psychologically
harmful. Noise at work can interfere with communications and make warnings harder to hear. It can also
reduce people’s awareness of their surroundings. These issues can lead to safety risks – putting people
at risk of injury. Excessive exposure to loud noise can irreversibly damage the ear, resulting in noise-
induced hearing loss. ‘Nuisance’ noise can be annoying and distracting and result in reduced job
performance and satisfaction. Noise may also be unsafe if it impairs communication in the work
environment, such as by overpowering auditory alarms.

Background:

The Factories Act 1948, model rules made under the Factories Act and The Noise Pollution (Regulation
And Control) Rules, 2000 (Under The Environment (Protection) Act, 1986) require employer to eliminate
or reduce risks to health and safety from noise at work.

Depending on the level of risk, the employer should:

• take action to reduce the noise exposure; and also
• provide employees with personal hearing protection.

Other duties under the Regulations include the need to:

• make sure the legal limits on noise exposure are not exceeded;
• maintain and ensure the use of equipment provided to control noise risks
• provide employees with information, instruction and training; and
• carry out health surveillance (monitor workers’ hearing ability).

Effect of Noise on Man

• Permanent loss hearing
• Temporary loss of hearing
• Heart diseases
• Increase in blood pressure
• Affects liver, kidney, central nervous system
• Aggravâtes insomnia, peptic ulcer, asthme and eczéma
• Reduces body’s résistance to diseases
• Increases distress, fear, anger, alarm, fatigue etc.

178
 • Causes higher rates of errors and accidents
• Causes annoyance to neighbours
• Leads to violent behaviour
• Stimulates the agitating attitude of workers
• Causes emotional breakdown
• Increases consumption of alcohol, drugs, etc.

The harmful effect of noise depends on:

• Individual susceptibility
• Noise intensity
• Total length of exposure
• Length of exposure at one time
• Whether nose is continuous or interrupted.

Prior to placement on an individual to any noisy environment, tests should be carried out to find whether
the individual has any hearing impairment.

Legal Requirements :

Statute Section/ Sub Provision

Section/
Rule/ Sub
Rule
The Factories Act Section 89: (1) Where any worker in a factory contacts any disease
1948 (Notice of specified in the third schedule, the manager of the factory
THE THIRD certain shall send a notice thereof to such authorities, and in such
SCHEDULE diseases) form and within such time, as may be prescribed.
(under the (2) If any medical officer attends on a person who is, or has
Factories Act) been employed in the factory and who is or is believed by
gives a list of the medical practitioner to be suffering from any disease
Notifiable specified in the third schedule, the medical practitioner
Diseases which shall without delay send a report in writing to the office of
includes Noise the Chief Inspector stating.
induced hearing
loss (exposure to Section 90: (1) The State Government may, if it considers it expedient so
high noise levels) (Power to to do, appoint a competent person to inquire in to any case
as one of the direct enquiry where a disease specified in the third schedule has been
notifiable into cases of or is suspected to have been contracted in a
diseases. accident or factory,………………
diseases)

The Model Rules under the Factories Act 1948: [The Model Rules have been framed by DGFASLI
(Directorate General, Factory Advisory Service and Labour Institute, an attached Office of Ministry of
Labour and Employment, Government of India) for the guidance of the State Governments to form State
Factories Rules. Based on these model rules, various states have prepared their State Factories Rules and
hence the state factory rules of the states have similar provision, however the rule number may be
different.]

Schedule XXIV (Operation involving high noise levels): “High noise level” means noise level measured
on A-weighted scale is 90dB or above.

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 TABLE 1: Permissible Exposure in cases of TABLE 2: Permissible Exposure Levels of
continuous Noise Impulsive or Impact Noise
Total time of exposure (continuous Sound Permitted no. of Peak sound pressure
or a no. of short term exposures) pressure level impulses or impact level in dB
per day, in hours. in dBA per day
8 90 100 140
6 92 315 135
4 95 1000 130
3 97 3160 125
2 100 10000 120
1.5 102
1 105
3/4 107
1/2 110
1/4 115
No exposure in excess of 115 dBA is to be permitted. No exposure in excess of 140 dB peak sound
pressure level is permitted
• When the daily noise exposure is composed of two or more periods of noise exposure at different levels
their combined effect should be considered, rather than the individual effect of each. The mixed exposure
should be considered to exceed the limit value if the
sum of the fractions C1 + C2 +…….Cn exceeds unity,-
T1 T2 Tn
Where the C1, C2, etc. indicate the total time of actual exposure at a specified noise level and T1, T2, etc.
denote the time of exposure permissible at that level. Noise exposure of less than 90 dBA may be ignored
in the above calculation.

• If it is not possible to reduce the noise exposure to the levels specified in Tables by reasonably practicable
engineering control or administrative measures, the noise exposure shall be reduced to the greater extent
feasible by such control measures, and each worker so exposed shall be provided with suitable protectors
(such as ear plug, earmuffs) so as to reduce the exposure to noise to the levels specified in above tables.

• In all cases where the prevailing sound levels exceeds for permissible levels specified in tables there shall
be administered and effective hearing conservation programme which shall include among other hearing
conservation measures, pre-employment and periodical auditory surveys conducted on workers exposed to
noise exceeding the permissible levels, and rehabilitation of such workers either by reducing the exposure
to the noise levels or by transferring them to place where noise levels are relatively less or by any other
suitable means.

• Every worker employed in high level noise areas shall be subjected to an auditory examination by a
Certifying Surgeon within 14 days or his 1st employment & thereafter, shall be re-examined at least once in
every 12 months. Such initial & periodical examinations shall include tests which the Certifying Surgeon
may consider appropriate, & shall include determination of auditory thresholds for pure tones of 125, 250,
500, 1,000, 2,000, 4,000 & 8,000 cycles per second.

• At every area which is high noise level area, display warning sign board indicating “high noise area and Use
Ear protection”. (section 7A.2.c of FA1948 & section 41B.1 of FA1948).

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 The Building and Other Construction Workers‘ (Regulation of Employment and Conditions of
Service) Central Rules, 1998

Rule 34 Excessive noise, vibration, etc: An employer shall ensure at a construction site of a building or
other construction work that adequate measures are taken to protect building workers against the harmful
effects of excessive noise or vibration at such construction site and the noise level in no case exceeds the
limits laid down in Schedule VI annexed to these rules.

Schedule II Notifiable Occupational Diseases In Building And Other Construction Work [Rule 230
(A)]: As per this schedule, Noise induced hearing loss (sr .no. 13) is notifiable disease

The Noise Pollution (Regulation & Control) Rules, 2000

• As per rule 3 (1), 4 (1) & 8 of The Noise Pollution (Regulation & Control) Rules, 2000 (notified under The
Environment (Protection) Act, 1986), following ambient air quality standards (mentioned in SCHEDULE) in
respect of noise shall be maintained.

Area Category of Area / Zone Limits in dB(A) Leq*

Code Day Time Night Time
(A) Industrial area 75 70
(B) Commercial area 65 55
(C) Residential area 55 45
(D) Silence Zone 50 40

Guidance to check compliance:

1) Whether any noise study has been conducted in the last two years?
2) Are there any machines/processes generating high-noise?
3) Whether high level noise areas have been identified and listed?
4) Whether engineering and administrative controls have been implemented to reduce noise exposure
below the permissible limits?
5) Whether the workers are made aware of the ill effects of high noise?
6) Whether ear muffs/plugs are provided and used?
7) Whether any notice indicating “High Level Noise Area-Wear Ear Protectors” is displayed in high noise
work areas?
8) Whether annual (once in 12 months) audiometric test has been conducted especially for workers working
in high noise level? Whether their records are available?

Documents to be checked:
1. Noise survey report.
2. Audiometric test records.
3. Training record.

6) VIBRATION

Introduction :
Vibration is a mechanical phenomenon whereby oscillations occur about an equilibrium point. The word
comes from Latin vibrationem ("shaking, brandishing"). Vibration can cause problems to the human body,
machines and structures as well as producing high noise levels. Vibration can manifest itself as a particle
displacement, velocity or acceleration. It is more commonly defined as acceleration and may be
measured using an accelerometer. There are many types of accelerometer and associated
instrumentation available which can give an analogue or digital readout or can be fed into a computerised
analysis system. As with sound, the vibration component would be measured at particular frequencies or
over a band of frequencies.

181
Effect of Vibration on the human body

Generally, it is the lower frequency vibrations that give rise to physical discomfort. Low frequency
vibration (3-6 Hz) can cause the diaphragm in the chest region to vibrate in sympathy giving rise to a
feeling of nausea. This resonance phenomenon is often noticeable near to large slow speed diesel
engines and occasionally ventilation systems. A similar resonance affecting the head, neck and shoulders
is noticeable in the 20-30 Hz frequency region while the eyeball has a resonant frequency in the 60-90
Hz.

The use of vibratory hand tools, such as chipping hammers and drills which operate at higher
frequencies, can cause ‘Vibration Induced White Finger’ (VWF). The vibration causes the blood vessels
to contract and restrict the blood supply to the fingers creating an effect similar to the fingers being cold.
Currently there are a number of cases where employees have instituted legal proceedings for VWF.

The effects of vibration on the human body will be dependent on the frequency, amplitude and exposure
period and hence it is difficult to generalise on what they will be. However, it is worthwhile remembering
that in addition to the physiological effects vibration can also have psychological effects such as loss of
concentration.

Protection of Persons from Vibrations

Where the source of the vibration cannot be removed, protection from whole body vibrations can be
provided by placing the persons in a vibration isolated environment. This may be achieved by mounting a
control room on vibration isolators in such area as the steel industry, or simply having isolated seating
such as on agricultural machinery.

For segmental such as VWF consideration should be given to alternative methods of doing the job such
as different tools.

To prevent this disease and related ill-effect automation and remote control system should be introduced.
The environmental permissible value of vibration should be maintained and medical control like pre-
employment and periodic examination should be carried out.

Machinery Vibration

For machines that vibrate badly, apart from the increased power used and damage to the machine and its
supporting structure, the vibrations can travel through the structure of the building and be radiated as
noise at distant points (structure-borne noise).

Where the balance of the moving parts of a machine cannot be improved vibration transmission can be
reduced by a number of methods of which the most commonly used are:

1. Mount the machine on vibration isolators or dampers.

2. Install the machine on an inertia block with a damping sandwich between it and the building
foundations.

The method chosen will depend on the size and weight of the machine to be treated, the frequency of
vibration to be controlled and the degree of isolation required. Whichever form of vibration isolation is
selected, care should be taken to ensure that the effect is not nullified by ‘bridges’. For example, isolation
of a reciprocating compressor set would be drastically reduced by right piping connecting it to its air
receiver or distribution pipework, or by conduiting the cables to the motor. In severe cases rigid piping
would fracture in a very short time.

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Legal Requirements:

Statute Section/ Sub Provision

Section/ Rule/
Sub Rule
The Building And Rule 34 The employer shall ensure that adequate measures are taken to
Other Excessive noise, protect building workers against the harmful effects of excessive
Construction vibration, etc. noise or vibration at such construction site
Workers’ Rule 49 The employer shall ensure that no wall, chimney or other
(Regulation Of Stability of structure or part of a structure is left unguarded in such condition
Employment & structures that it may fall, collapse or weaken due to wind pressure vibration
Conditions Of at a site of a building or other construction work.
Service) Central Rule 63 (a) The employer shall ensure at a construction site of a building or
Rules, 1998 Operator’s cab other construction work that the operator of every lifting machine
or cabin in outdoor service is provided with a cab or cabin which has a
protection from vibration
Rule 103 The employer shall ensure at a construction site of a building or
Vibrators other construction work that—
(a) a building worker, who is in good physical condition, operates
vibrators used in concreting work;
(b) all practical measures are taken to reduce the amount of
vibration transmitted to the operators working in concreting work;

Guidance to check compliance:

1) Are there equipment which contributes excess level of vibrations and whether they are identified?
2) Whether any vibration study has been carried out?
3) Are the measures taken to combat vibration to acceptable levels?
4) What is the frequency for measurements of vibration?
5) Are the records of measurements and maintenance of equipment / system maintained?

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b) WORK ENVIRONMENT MONITORING FOR HAZARDOUS CHEMICALS
Introduction:
The prevalence of toxic airborne contamination in the work room air is one of the major contributing
factors to occupational health hazards. Although all chemicals substances are toxic at some
concentration, there exists exposure limit for all substances for which no injurious effect will be visible
either immediately in the short term or with sufficiently prolonged exposure. This concentration is termed
as Threshold Limiting Value (TLV), Recommended Exposure Limits (REL) for the substance present in
work room air. This value is taken as guideline to control the exposure to toxic airborne substances
encountered in an industrial environment.

The Factories Act has prescribed the permissible levels (TLVs) of certain chemical substances in work
environment in the Second Schedule. It should be ensured that the concentration of these chemicals
never exceeds beyond this permissible value in the work environment. Thus it is important to measure
and monitor the concentration of these chemical substances in the work environment regularly.

Background: Threshold Limit Values refer to airborne concentrations (typically for inhalation or skin
exposure) of chemical substances and represent conditions under which it is believed that nearly all
workers may be repeatedly exposed, day after day, over a working lifetime, without adverse health
effects. Its units are in parts per million (ppm) for gases and in milligrams per cubic meter (mg/m³)
for particulates such as dust, smoke and mist. The Second schedule* of Factory act 1948 gives a list of
116 number of substances with permissible level of certain chemical substances in work environment.
(* for details please refer The Factories Act, 1948)

Categorization of TLVs:

a) Threshold limit value –Time weighted average (TLV- TWA)

It is the average concentration for normal 8 hours work day to which nearly all worker may be
repeatedly exposed without adverse effect.

b) Threshold limit value –Short term exposure limit (TLV- STEL)

It is an allowable average exposure over a short period of time, typically 15 minutes continuously
without suffering from 1) irritation 2) Chronic or irreversible change, 3) Narcosis and should not
be exceeded more than four times in a day as long as the time weighted average is not
exceeded. If the predetermined limit has been exceeded, the worker must remove him- or herself
from the hazard for at least one hour between exposures.

184
 c) Threshold limit value - Ceiling (TLV –C)
The concentration that should not be exceeded even instantaneously.

Legal Requirements:
Sr. No. Statute Section/ Sub Provision
Section/ Rule/
Sub Rule
1 The Section. 41F: The maximum permissible threshold limits of exposure of
Factories (Permissible chemicals and toxic substances in manufacturing
Act 1948 limits of processes (whether hazardous or otherwise) in any
exposure of factory shall be of the value indicated in the Second
chemicals and Schedule.
toxic
substances)
Section 36: Person shall not be allowed to enter in any confined
(Precaution spaces where any gas, fume, vapour or dust is likely to be
against present involving risk of person being overcome.
dangerous fume Practicable measure must be carried out for removal of
and gases) any gas, fume, vapor or dust which may be present so as
to bring its level within the permissible limit and precaution
must be taken to prevent the ingress of above materials.
Section 14: (Dust Provision of exhaust application must be made in every
and Fume) factory where manufacturing process produce dust and
fumes.
2 The Model Rule 68: Effective steps shall be taken for removal or prevention of
Rules under Accumulation of the accumulation in the air of flammable dust, gas, fume
the flammable dust, or vapour to an extent, which is likely to be dangerous.
Factories gas, fume or
Act 1948 vapour in air or No waste material of a flammable nature shall be
flammable waste permitted to accumulate on the floors and shall be
material on the removed at least once in a day or shift, and more often,
floors: when possible. Such materials shall be placed in suitable
metal containers with covers wherever possible.
Rule75(33), (34): Employer should ensure that –
Entry into • effective steps have been taken to prevent any
confined spaces ingress of dangerous fumes.
likely to contain • any sludge or other deposit liable to give off
dangerous dangerous fumes has been removed and the
fumes: space contains no other material liable to give off
dangerous fumes; and
• the space has been adequately ventilated and
tested for dangerous fumes and has a supply of
air adequate for respiration.
No person shall enter or remain in any confined space in
a vessel, being a confined space in which there is reason
to apprehend that the proportion of oxygen in the air is so
low as to involve risk of persons being overcome.

185
Sr. Statute Section/ Sub Provision
No. Section/ Rule/
Sub Rule
3 The Rule 40: when an internal combustion engine exhausts into a confined
BOCW Dangerous and space or excavation or tunnel or any other workplace where
Central harmful neither natural ventilation nor artificial ventilation system is
Rule 1998 environment: adequate to keep the carbon monoxide content of the
atmosphere below fifty parts per million, adequate and suitable
measures are taken at such workplace in order to avoid
exposure of building workers to health hazards.

No building worker is allowed to enter any confined space or

tank or trench or excavation wherein there is given off any
dust, fumes or other impurities of such nature and to such
extent as is likely to be injurious or offensive to the building
worker or in which explosives, poisonous, noxious or gaseous
material or other harmful articles have been carried or stored
or in which dry ice has been used as a refrigerant, or which
has been fumigated or in which there is a possibility of oxygen
deficiency, unless all practical steps have been taken to
remove such dust, fumes, or other impurities and dangers
which may be present and to prevent any further ingress
thereof, and such work place or tank or trench or excavation is
certified by the responsible person to be safe and fit for the
entry of such building workers.
4 The Rule 43: Dust, An employer shall prevent concentration of dust, gases or
BOCW gases, fumes etc.: fumes by providing suitable means to control their
Central concentration within the permissible limit so that they may not
Rule 1998 cause injury or pose health hazard to a building worker at a
building or other construction work.
Rule 52: Disposal Debris is kept sufficiently moist to bring down the dust within
of debris: the permissible limit.

Guidance to check compliance:

1) Is there any process in industry where dust and fumes are evolved?
2) Whether the dust, fumes, smoke aerosols & Mist are monitored as per statute and records
maintained?
3) What procedure adopted to remove dust and fumes from source?
4) What type of detectors (portable/ fix) used for monitoring concentration of hazardous
chemicals?
5) Whether Portable of fix gas detection system calibrated?
6) Is any alarm system installed for any leakage of hazardous chemicals?
7) Is there any written down procedure for carrying out work in confined space where the
dangerous fume or gas exists?
8) Emergency PPE like SCBA, Airline respirator etc available?
9) Is the permit to work system strictly followed for entering in confined space?

Documents to be checked:
1. Hazardous Chemicals Monitoring Records.
2. Detectors or sample check points list.
3. Procedure of monitoring – frequency, responsibility, action taken on reports.
4. Calibration records.
5. Recording of the chemical concentration (including oxygen level) on the work permit form for
confined space entry.

186
C ) FIRST AID FACILITIES & OCCUPATIONAL HEALTH CENTER
Introduction:

As per the Factories Act, 1948 the employer has a legal duty to provide adequate facilities for the safety,
health and welfare of employees at work. There are specific provisions in the Act with respect to the
requirement of first-aid appliances and occupational health centre.

Background:

First Aid is the immediate and temporary care given to a person in case of injury or sudden illness. The
purpose of first aid is to apply the most suited treatment in the circumstances to preserve life, assist
recovery, prevent aggravation, and minimize complications at later time with the help of such material as
may be available until medical aid is available.

Occupational health centre is required for providing immediate treatment to cases of accidental exposure
to hazardous substances and emergency cases under supervision of trained personnel.

Legal Requirements:
Sr. Statute Section/ Sub Provision
No. Section
Rule/ Sub
Rule
1 The Sec.45: (First 1. There shall, in every factory, be provided and maintained so as to
Factories Aid be readily accessible during all working hours first-aid boxes or
Act, 1948 Appliances) cupboards equipped with the prescribed contents, and the number
of such boxes or cupboards to be provided and maintained shall
not be less than one for every one hundred and fifty workers
ordinarily employed at any one time in the factory.
2. Nothing except the prescribed contents shall be kept in a first-aid
box or cupboard.
3. Each first-aid box or cupboard shall be kept in the charge of a
separate responsible person, who holds a certificate in first-aid
treatment recognized by the State Government and who shall
always be readily available during the working hours of the factory.
In every factory wherein more than five hundred workers are ordinarily
employed there shall be provided and maintained an ambulance room
of the prescribed size, containing the prescribed equipment and in the
charge of such medical and nursing staff as may be prescribed and
those facilities shall always be made readily available during the
working hours of the factory.
2 The Rule 82 (O): In respect of any factory carrying on 'Hazardous Process' there shall
Model (Occupationa be provided and maintained in good order an Occupational Health
Rules l Health Centre with the services and facilities as per scale laid down
under the Centre) hereunder:-
Factories (a) For factories employing up to 50 workers,-
Act ,1948 ii. The services of Factory Medical Officer on retainer ship basis,
in his clinic to be notified by the occupier. He will carry out the
pre-employment and periodical medical examination as
stipulated in rule 82- N and render medical assistance during
any emergency;
iii. A minimum of 5 persons trained in first-aid procedures
amongst whom at least one shall always be available during
the working period;
iv. A fully equipped first-aid box

187
Sr. Statute Section/ Sub Provision
No. Section/
Rule/ Sub
Rule
2 The Rule 82 (O): (b) For factories employing 51 to 200 workers,-
Model (Occupationa i. An Occupational Health Centre having a room with a minimum
Rules l Health floor area of 15 sq.m. with floors and walls made of smooth
under the Centre) and impervious surface and with adequate illumination and
Factories ventilation as well as equipment as per the schedule annexed
Act ,1948 to this rule;
continued ii. A part-time Factory Medical Officer shall be in over-all charge
of the Centre who shall visit the factory at least twice in a week
and whose services shall be readily available during medical
emergencies;
iii. One qualified and trained dresser-cum-compounder on duty
throughout the working period;
iv. A fully equipped First-aid box in all the departments,

(c) For factories employing above 200 workers,-

i. One full-time Factory Medical Officer for factories employing
up to 500 workers and one more medical officer for every
additional 1,000 workers or part thereof;
ii. An Occupational Health Centre having at least 2 rooms each
with a minimum floor area of 15 sq. m. with floors and walls
made of smooth and impervious surface and adequate
illumination and ventilation as well as equipment’s as per the
schedule annexed to this rule;
iii. There shall be one nurse, one dresser-cum-compounder and
one sweeper-cum-ward boy throughout the working period;
iv. The Occupational Health Centre shall be suitably equipped to
manage medical emergencies.

The Factory Medical Officer required to be appointed under sub-rule

(1) shall have qualifications included in Schedule to the Indian Medical
Degrees Act of 1916 or in the Schedules to the Indian Medical Council
Act, 1956 and possess a Certificate of Training in Industrial Health of
minimum three months duration recognized by the State Government.

Provided that,-
i. A person possessing a Diploma in Industrial Health or equivalent
shall not be required to possess the Certificate of training as
aforesaid;
ii. The Chief Inspector may, subject to such conditions as he may
specify, grant exemption from requirement of this sub-rule, if in
his opinion a suitable person possessing the necessary
qualification is not available for appointment;
iii. In case of a person who has been working as a Factory Medical
Officer for a period of not less than 3 years on the date of
commencement of this rule, the Chief Inspector may, subject to
the condition that the said person shall obtain the aforesaid
certificate of training within a period of three years, relax the
qualification.

The Syllabus of the Course leading to the above Certificate, and the
organizations conducting the course shall be approved by the DG
FASLI or the State Government in accordance with the guidelines

188
 issued by DG FASLI.

Within one month of the appointment of a Factory Medical Officer, the

occupier of the factory shall furnish to the Chief Inspector the following
particulars, namely:-
a) Name and address of the Factory Medical Officer,
b) Qualifications,
c) Experience, if any, and
d) The sub-rule under which appointed.
3 The Section 36 : First Aid- Every employer shall provide in all the places where building
BOCW or other construction work is carried on such first aid facilities as may
Act, 1996 be prescribed

4 The Rule 225 : the employer shall ensure at a construction site of a building or other
BOCW Occupational construction work involving hazardous processes specified under
Central Health Schedule IX to these rules that
Rules, Center: (a) an OHC , mobile or static, is provided and maintained in good
1998 order at such site
(b) Services and facilities as per the scale laid down in Schedule X
(c) a construction medical officer appointed at an OHC possesses the
qualification as laid down in Schedule XI, annexed to these rules
Schedule IX:
Hazardous Process: * Roof work *Steel erection * Work under and
over water *Demolition *Work in confined space

d) PERIODIC MEDICAL EXAMINATION PREVENTION OF OCCUPATIONAL

DISEASES INCLUDING
Introduction:
An occupational disease is any chronic ailment that occurs as a result of work or occupational activity.
These are caused because of prolonged exposure to harmful substances or physical conditions or
inappropriate postures and habits at work. Occupational diseases often develop over many months or
years, depending on the intensity and circumstances of exposure. The Third Schedule to The Factories
Act 1948 (FA) lists 29 notifiable diseases. Detecting a disease in its early stage is important because one
can get treatment and stop further exposures to the harmful substance. Thus periodic medical
examination of the workers engaged in the jobs that may lead to their exposure to harmful
substances/postures/conditions is of utmost importance.

Background:
An occupational disease can be caused by work exposures to irritants like dust, fibres, fumes, chemicals.
Persons working around these substances could be at risk for developing an occupational disease.
Occupational diseases can take years to develop, often producing few or no symptoms until the disease
has progressed to a serious or fatal stage. Fortunately, the more you know about the types of exposures
that cause occupational diseases, the earlier you can spot the signs and get treatment. Not everyone who
is exposed to harmful substances will develop an occupational disease though. Only those who are
particularly sensitive to these materials will end up developing diseases from exposure. In fact, there are
hundreds of workplace exposures that can cause occupational diseases. Certain substances that are
commonly known to cause occupational diseases include:

• Dusts. Dust is a common cause of workplace disease, including coal dust, silica dust (found in
rocks such as quartz), crop dust (especially hay crops and cotton crops), and wood dust.
• Fumes. Workers who are exposed to fumes are at risk of developing occupational diseases,
including fumes from chemicals, fuels, welding tools, etc.

189
 • Fibres. Certain fibres also put workers at risk, including asbestos, cotton and flock (used for
carpeting, blankets, and other similar items).

With most occupational diseases, it is crucial to reduce or stop the exposure to the harmful substance.
This may mean that you have to leave your job. Or, you might be able to continue working by wearing
protective gear, such as masks, respirators, and gloves.

Legal Requirements:

Sr. Statute Section/ Sub Provision

No. Section/ Rule/
Sub Rule
1 The Section 14: In every factory in which, by reason of the manufacturing process
Factories (Dust and carried on, there is given off any dust or fume or other impurity of
Act 1948 fume): such a nature and to such an extent as is likely to be injurious or
offensive to the workers employed therein, or any dust in
substantial quantities, effective measures shall be taken to
prevent its inhalation and accumulation.
Section 41-C Every occupier of a factory involving any hazardous process shall
(Specific –
responsibility of (a) Maintain accurate and up-to-date health records or medical
the occupier in records of the workers in the factory who are exposed to any
relation to toxic chemicals or other harmful substances used in the
hazardous factory.
processes) (b) Appoint persons who possess qualifications and experience
in handling hazardous substances and are competent to
supervise such handling within the factory and to provide at
the working place all necessary facilities for protecting the
workers
(c) Provide for medical examination of every worker-
• Before such worker is assigned to a job involving the
working with a hazardous substance, and
• while continuing in such job, and after he has ceased to
work in such job, a interval not exceeding twelve month.

[“hazardous process’ means any process or activity in relation

to an industry specified to the First Schedule where, unless
special care is taken, raw materials used therein or the
intermediates or finished products, by-products, wastes or
effluents thereof would –
(i) Cause material impairment to the health of the persons
engaged in or connected therewith, or
(ii) Result in the pollution of general environment.]
Section 89: Where any worker in a factory contacts any disease specified in
(Notice of the third schedule, the manager of the factory shall send a
certain notice thereof to such authorities, and in such form and within
diseases) such time, as may be prescribed.

If any medical officer attends on a person who is, or has been

employed in the factory and who is or is believed by the medical
practitioner to be suffering from any disease specified in the third
schedule, the medical practitioner shall without delay send a
report in writing to the office of the Chief Inspector.
THE THIRD SCHEDULE: List of Notifiable Diseases

190
Sr. Statute Section/ Sub Provision
No. Section/ Rule/
Sub Rule
2 The Model Rule 82 (N): 1) Workers employed in a 'hazardous process' should be
Rules Medical medically examined by Factory Medical officer (FMO)
under the Examination
Factories (Rules framed ➢ once before employment to determine physical fitness of
Act 1948 under section the person to do the particular job
41-B, 41-C and ➢ once in a period of 6 months, to determine the health
112 specific fitness of all the workers in respect of occupational
responsibility of health hazards to which they are exposed, and in cases
occupier with where in the opinion of the Factory Medical Officer it is
relation to necessary to do so at a shorter interval in respect of any
hazardous worker.
processes) ➢ the details of pre-employment pre-employment and
periodical medical examinations carried out as aforesaid
shall be recorded in the Health Register in the prescribed
Form.

2. No person shall be employed for the first time without a

certificate of fitness in Form 33 granted by the Factory Medical
Officer. If FMO declares a person is unfit for being employed
in any process covered under sub Rule (1), such a person
shall have a right to appeal to the Inspector who shall refer the
matter to Certifying Surgeon whose opinion shall be final in
this regard. If the Inspector is also a Certifying Surgeon, he
may dispose of the application himself.
Rule 82 (N): 2) Any findings of the FMO revealing any abnormality or
Medical unsuitability of any person employed in the process shall
Examination immediately be reported to the Certifying Surgeon who shall in
(Rules framed turn, examine the concern person and communicate the
under section findings to the occupier within 30 days. If the certifying
41-B, 41-C and Surgeon is of the opinion that the worker is so examined is
112 specific required to be taken away from the process for health
responsibility of protection, he will direct the occupier accordingly, who shall
occupier with not employ the said worker in the same process. However, the
relation to worker so taken away shall be provided with alternate
hazardous placement unless he is in the opinion of the Certifying
processes) Surgeon, fully incapacitated in which case the worker affected
shall be suitably rehabilitated.
3)A certifying surgeon on his own motion or on reference from
an Inspector may conduct medical examination of a worker to
ascertain suitability of his employment in an hazardous
process or for ascertain his health status. The opinion of
certifying surgeon in such a case shall be final. The fee
required for this medical examination shall be paid by the
occupier.
4) The worker taken away from employment in any process
under sub rule (2) may be employed in the same process only
after obtaining the fitness certificate from the certifying surgeon
and after making entries to that effect in the Health Register.
5) The worker required undergoing medical examinations under
these rules and any medical survey conducted by or on behalf
of the Central or the State shall not refuse to undergo such
medical examination.

191
2 The Model Rule 94: 1) Annual medical examination for fitness of each member of
Rules Annual medical canteen staff who handles foodstuffs shall be carried out by
under the examination of the Factory Medical Officer(FMO) or the Certifying Surgeon,
Factories canteen staff which should include the following:-
Act 1948 a) Routing blood examination
continued b) Routing and bacteriological testing, of feces and urine for
germs of dysentery and typhoid fever; and any other
examination including chest X- ray that may be considered
necessary by the FMO or Certifying Surgeon.
2) Any person who in the opinion of the FMO or Certifying
Surgeon is unstable for employment on account of possible
risk to the health of others, shall not be employed as
canteen staff.

Special Provision for Pre-employment and Periodic

Medical Examination of workers involved in Dangerous
operations are given in Annexure 4

The Radiation (1) Every employer shall provide the services of a physician with
protection appropriate qualifications to undertake occupational health
Rules, 2004, surveillance of classified workers.
Rule 25: Health (2) Every worker, initially on employment, and classified worker,
surveillance of thereafter at least once in three years as long as the individual is
workers employed, shall be subjected to the following - (a) general
medical examination as specified by order by the competent
authority; and (b) health surveillance to decide on the fitness of
each worker for the intended task;
(3) The health surveillance shall include - (a) special tests or
medical examinations as specified by order by the competent
authority, for workers who have received dose in excess of
regulatory constraints; and (b) counselling of pregnant workers
[Rule 18. Classified worker: The employer shall designate
as classified workers, those of his employees, who are likely
to receive an effective dose in excess of three tenths of the
average annual dose limits notified by the competent
authority and shall forthwith inform those employees that they
have been so designated.]

3 The Rule 152: The employer shall ensure at a construction site of a building or
BOCW, Permissible other construction work that -
Central limit of (a) The working environment in a tunnel or a shaft in which
Rules, 1998 exposure of building workers are employed does not contain any of
chemicals the hazardous substances in concentrations beyond the
permissible limits as laid down in Schedule XII annexed
to these rules.
It is also required to maintain the records of the test carried out in
this regard.
Rule 223: The employer shall ensure at a construction site of a building or
Medical other construction work that -
examination of (b) (i) A Building worker who is employed for a work involving
building such risk or hazards, inherent in such work as the Director
workers, etc. General considers appropriate for the periodical medical
examination of such worker, is medically examined at such
intervals as the Director General may direct from time to
time.

192
 (ii) Every operator of a crane, which or other lifting appliance,
transport equipment or vehicle, is medically examined
before employing such operator and again periodically, at
such intervals as the Director General may direct from
time to time.
(iii) the medical examination referred to in sub-clause (i) and
sub-clause (ii) is in accordance with Schedule VII,
annexed to these rules and is conducted by such medical
officers or at such hospitals as are approved by the
Central Govt. for the purpose from time to time.
(iv) in case of building worker who is exposed to special
occupations health hazard owing to job or work assigned
to such worker, the periodical medical examination
referred to in sub clause (i) or sub clause (ii) includes
such special investigation as may be deemed necessary
by the construction medical officer examining such
building worker for the diagnosis of occupational disease.
(d) The record of the medical examination of every building
worker employed is maintained in a register in Form XII
annexed to these rules.

Guidance to check compliance:

1) Whether adequate measures have been taken to prevent exposure of workers to hazardous
chemicals?
2) Whether pre-employment medical check-up data available?
3) Whether the periodical medical examination of employees, required under statute is carried
out?
4) During the medical check-up, is any person found having occupational diseases mentioned
in 3rd schedule of The Factories Act, 1948?
5) Whether the medical practitioner informed the Chief Inspector of Factories about the
occurrence of the occupational disease?
6) Whether it is ensured that contractors employee are medically examined during pre-
employment as well as during the course of employment?
7) During the periodical medical examination of the workers, are they examined as per the
hazardous process in which they work? (First schedule of The Factories Act, 1948)
8) Are the records of all such examination maintained?
9) Whether eye vision test for crane operators has been conducted as per statues?

Documents to be checked:
1) Pre-employment and periodic medical check-up records of regular and contract employees.
2) Records of analysis of the medical reports to identify the action to be taken in doubtful cases .

193
 Annexure 1

Special Provision for Pre-employment and Periodic Medical Examination of workers

involved in Dangerous Operations:

Sr Industry type Workers employed in Pre-employment Periodical

(dangerous examination examination
operations)
1 Electrolytic plating or electrolytic chrome process Examined by the By Medical Inspector of
oxidation of metal Medical Inspector Factories or Certifying
articles by use of an of Factories or Surgeon at intervals of
electrolyte containing Certifying not more than 6 months
chromic acid or other Surgeon within
chromium 30 days of his
compounds. first employment
2 Manufacture and lead process Examined by the Examined by the
repair of electric Certifying Certifying Surgeon
accumulators Surgeon within 7 once in every calendar
days preceding month
or following the
date of his first
employment
3 Glass Manufactures • mixing of raw materials to Examined by the Examined by the
form a "bath"; Certifying Certifying Surgeon
• The dry grinding, glazing Surgeon within 7 once in every calendar
and polishing of glass or days preceding month
any article of glass; or following the
• processes in which date of his first
hydrofluoric acid fumes or employment
ammoniacal vapours are
given off;
• processes in the making
of furnace moulds or
"pots" including the
grinding or crushing of
used "pots";
• processes involving the
use of a dry lead
compound.
4 Manufacture and All process Examined by a Examined by the
treatment of lead & Certifying Certifying Surgeon at
certain compounds of Surgeon within intervals of not more
lead 14 days of his than 3 months
first employment
5 Cleaning or in blasting or assisting at Medically by the Certifying
smoothening, blasting or in any blasting examined by the Surgeon at intervals of
roughening, etc. of chamber or in the cleaning Medical Inspector 12 months
articles by a jet of of any blasting apparatus or of Factories /
sand, metal shot or any blasting enclosure or Certifying
grit or other abrasive any apparatus or ventilating Surgeon 30 days
propelled by a blast of plant connected therewith of his first
compressed air or or be employed on employment
steam Blasting maintenance or repair work
Regulations at such apparatus,
enclosure or plant

194
Sr Industry type Workers employed in Pre-employment Periodical
(dangerous examination examination
operations)
6 Liming and tanning of all persons - inspection of the hands
raw hides and skins of all persons coming
and processes into contact with
incidental thereto chrome solutions to be
made twice a week by
responsible person
7 Manufacture of employed in a chrome Medical practitioner /
chromic acid or process - FMO examine & treat
manufacture or all workers, for chrome
recovery of the ulcerations &
bichromate of sodium, occupational diseases,
potassium or on the premises at least
ammonium thrice a week +
examined by the
Certifying Surgeon
once in every calendar
month + a person
trained in First Aid who
shall inspect daily the
hands & feet of all
persons employed
8 Manufacture or Involved in manufacturing Examined by by the appointed doctor
manipulation of Nitro process using appropriate at intervals of not more
or Amino compounds tests, and found than 3 months +
fit for the said examined by the
process by the Certifying Surgeon at
appointed doctor intervals of not more
+ by a Certifying than 12 months
Surgeon within
30 days of his
first employment
9 Manufacturing of manufacturing processes Certifying by the Certifying
bangles & other Surgeon within 7 Surgeon at least once
articles from days preceding during each calendar
cinematograph film & his first month
toxic and inflammable employment
solvents.
10 Processes involving in a fume process - Examined by the
manufacture, use or Factory Medical Officer
evolution of carbon once in every 6 months
disulphide & hydrogen and by the Certifying
sulphide Surgeon once in every
12 months

195
Sr Industry type Workers employed in Pre-employment Periodical
(dangerous examination examination
operations)
11 Manufacture & manufacturing process Examined by the by the Certifying
manipulation of Certifying Surgeon at least
dangerous Surgeon within 7 once in every 3
pesticides days preceding calendar months +
his first medical practitioner /
employment FMO should examine
&, if necessary, treat
on the premises of
the factory all
workers who handle
dangerous pesticides
for effects of
excessive absorption
at least once a week
12 Handling & • breaking, crushing, Examined by the Medically examined
processing of disintegrating, opening, Medical Inspector by the Medical
Asbestos, grinding, mixing or sieving of of Factories / Inspector of Factories
Manufacture of asbestos & any other Certifying / Certifying Surgeon
any Article of processes involving handling Surgeon + at intervals of 12
Asbestos & any & manipulation of asbestos radiologically months
other process of incidental thereto; examined by the
manufacture or • manufacture of asbestos qualified
otherwise in which textiles including preparatory radiologist and
Asbestos is used & finishing processes; the standard
in any form. • making of insulation slabs or size-X-ray plate
sections, composed wholly shall be
or partly of asbestos & submitted to the
processes Medical Inspector
• incidental thereto; of Factories
• making or repairing of Certifying
insulating mattresses, Surgeon for
composed wholly or partly of medical
asbestos, & processes examination
incidental thereto;
• manufacture of asbestos
cardboard & paper;
• manufacture of asbestos
cement goods;
• application of asbestos by
spray method;
• sawing, grinding, turning,
abrading & polishing in dry
state of articles composed
wholly or partly of asbestos;
▪ cleaning of any room,
vessel, chamber, figure of
appliance for the collection
of asbestos dust; &
• processes in which asbestos
dust is given off into the
work of environment

196
Sr Industry type Workers employed in Pre-employment Periodical
(dangerous examination examination
operations)
13 Manufacture or manganese process Medically Medically examined by
Manipulation of examined by Medical Inspector of
Manganese & its Medical Inspector Factories / Certifying
Compounds of Factories / Surgeon at intervals of
Certifying not more than 6 months
Surgeon within
14 days of his
first employment
14 Benzene in processes involving use of a thorough pre- Medical examination
benzene or substances employment including blood test and
containing benzene medical other biological tests at
examination intervals of every 6
including a blood months by the factory
test for fitness for medical officer with the
employment by a assistance of a
Medical Inspector laboratory
of Factories /
Certifying
Surgeon
15 Manufacture or All processes Examined Examined (include
Manipulation of (include exfoliative cytology of
Carcinogenic Dye exfoliative the urine) by a Medical
Intermediates. cytology of the Inspector of Factories
urine) by a or Certifying Surgeon at
Medical Inspector least once in every 6
of Factories or a calendar months
Certifying
Surgeon within
14 days of his
first employment
16 Operations areas where the noise Auditory Examination by a
Involving High exceeds the maximum examination by a Certifying Surgeon at
Noise Levels permissible exposure levels Certifying least once in every 12
equal or more than 90dB, A- Surgeon within months
weighted scale 14 days or his
first employment
17 Handling & by a qualified medical
Processing of practitioner having
Cotton adequate experience in
treatment of person
affected by lung
ailments at least once
in a period of 6 months
(include lung function
test, immunoglobulin
test & any other test or
tests which may be
found necessary to
detect the cases of
above referred disease)

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Sr Industry type Workers employed in Pre-employment Periodical
(dangerous examination examination
operations)
18 Operations in Every worker employed in a Examined Examined by a
Foundries foundry (include Certifying Surgeon at
pulmonary least once in every
function tests and twelve months + chest
chest X-ray) by a X-ray which will be
Certifying once in 3 years
Surgeon within
15 days of his
first employment
19 Manipulation of manipulation of stone Examined Examined by a
stone or Any Other (crushing, breaking, (include Certifying Surgeon at
Material chipping, dressing, grinding, pulmonary least once in every
Containing Free sieving, mixing, grading or function tests and twelve months + chest
Sillica handling of stone or all other chest X-ray) by a X-ray which will be
material containing free Certifying once in 3 years
silica or any other operation Surgeon within
involving such stone or 15 days of his
material) or any other first employment
material containing free
silica is carried on (means a
stone or any other solid
material containing not less
than 5% by weight of free
silica)

e) PERSONAL PROTECTIVE EQUIPMENT AND EMERGENCY EQUIPMENT

Introduction:

PPE is equipment that will protect the user against health or safety risks at work. It is an important means
of preventing work injuries. PPEs will only be effective if they are of proper type and are used properly.
Thus, careful selection, maintenance and regular and realistic training to employees is needed. Hence,
as an auditor these aspects should be carefully reviewed during the audit. Many times workers do not
adhere to personal protective equipment (PPE) requirements because they feel it is a nuisance to wear or
slows them down during a task. During the audit random check through field visits to some shop-floor
areas should be undertaken to determine the extent of use of the PPEs by the employees. PPE should
only be relied upon as a last line of defense in places where it is not practicable to control the hazards at
source.

Background:
Making the workplace safe includes providing instructions, procedures, training and supervision to
encourage people to work safely and responsibly. Even where engineering controls and safe systems of
work have been applied, some hazards might remain and PPE is ultimately used to minimize the risk of
injury.

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Categories/types of PPEs:

Depending upon the nature of the hazard, the PPE is broadly divided into the following two categories:
* Respiratory: those used for protection from harm due to inhalation of contaminated air.
* Non Respiratory: those used for protection against injury from outside the body i.e. for protecting the
head, eye, face, hand ,a arm, foot, leg and other body parts.

Respiratory Personal Protective Equipment

The worker is exposed to different hazards in the industry such as Oxygen deficient work environment,
Gas or vapour Contaminants, Air borne particulate matter (Dusts, Fumes, Smokes, Mists, and Fogs),
Mixture of gases, vapours and particulate matter, etc. During plant breakdown or sometimes, repairs and
maintenance, the level of air contaminants may even exceed the Permissible Limit of Exposure and the
working conditions may essentially demand for providing Respiratory Protection devices to the workers.

Types of Respiratory Protective Equipment

The Respiratory Personal Protective Equipment can be broadly divided into two groups: 1. Air Supplying
Respirators (Breathing Apparatus) 2. Air Purifying Respirators

Non Respiratory Personal Protective Equipment

Non-respiratory Personal Protective Equipment for various parts of the body can be divided into five
broad groups.

1. Head Protection. 2. Ear & Eye Protection. 3. Hand & Arm Protection.
4. Body Protection. 5. Foot & Leg Protection.

Legal Requirements:
Employers have duties concerning the provision and use of personal protective equipment (PPE) by the
employees at work. Given below are certain statutory provisions under various safety laws/rules
/regulations with respective PPEs:

Sl. PPE Protection Legal requirements

no against
1 Head Impact from The Factories Act, 1948: Though there is no direct provision
Protection: falling or flying under the Factories Act / Rules, The general provisions given
Industrial objects, risk of at the bottom of the table calls for providing head protection to
safety head bumping, employees wherever required.
helmets, caps, hair getting
and tangled in BOCW Act 1996
firefighters' machinery,
helmets chemical drips Section 46 : Head protection and other protective apparel:
or splash, Every building worker required to pass through or work within
climate or the areas at building or other construction work where there is
temperature hazard of his being struck by falling objects or materials shall
be provided with safety helmets of type and tested in
accordance with the national standards.

Central Electricity Authority (CEA) Regulation 2010

Rule no 19 : Handling of Electric Supply Line and
apparatus: Every person who is working on an electric supply
line or apparatus or both shall be provided with tools and
devices such as gloves, rubber shoes, safety belts, helmets,
line testers, hand lines and the like for protecting him from
mechanical and electrical injury.

199
Sl. PPE Protection Legal requirements
No. against
2. Hearing Noise – a The Factories Act, 1948
Protection : combination of Noise induced hearing loss is listed as one of the Occupational
Earplugs, sound level Notifiable Diseases under the Third Schedule of the Factories Act.
earmuffs and duration of
exposure, very
high-level
sounds are a
hazard even
with short
duration

3 Eye and Face Chemical or The Factories Act, 1948

Protection: metal splash, Section 35 : Protection of eyes: Effective screens or suitable
Safety dust, goggles shall be provided for protection of persons employed on
spectacles, projectiles, gas such manufacturing processes which may involve risk of injury to
goggles, and vapour, eyes from flying particles or by exposure to excessive light.
face radiation The BOCW Act 1996
screens/face Section 45: Eye Protection: Suitable personal protective equipment
shields, visors for the protection of eyes shall be provided for worker engaged in
operations like welding, cutting, chipping, grinding or similar
operations which may cause hazard to his eyes at a building or other
construction work.
4 Hand & Skin Abrasion, The Factories Act, 1948
protection: temperature Though there is no direct provision under the Factories Act / Rules,
Gloves, extremes, cuts The general provisions given at the bottom of the table calls for
gloves with a and punctures, providing hand and skin protection to employees wherever required.
cuff, gauntlets impact,
and sleeving chemicals, The BOCW Act 1996
that covers electric shock, Section 46 : Head protection and other protective apparel
part or all of radiation, Every building worker required to use or handle alkalis, acid or other
the arm vibration, etc. similar corrosive substances, handling sharp objects or materials
which may cause hand injury, shall be provided with suitable hand-
gloves.

Section 47: Electrical hazards

Building workers using jack hammers, crow bars or other hand tools
which may come in contact with a live electrical line, shall be
provided with insulated protective gloves.

CEA Regulation 2010

Rule no 19 : Handling of Electric Supply Line and apparatus
[ Refer provision given above under head protection]
5 Body Heat, chemical The Factories Act, 1948
Protection: or metal Section 13 : Ventilation and temperature
Conventional splash, spray Where the nature of the work carried on in the factory involves, or is
or disposable from pressure likely to involve, the production of excessively high temperatures,
overalls, leaks or spray such adequate measures as are practicable shall be taken to protect
boiler suits, guns, the workers.
aprons, contaminated
chemical suits dust, impact or The BOCW Act 1996
penetration, Section 46: Head protection and other protective apparel Every
excessive wear building worker required to work in rain or in similar wet condition at
or building or other construction work, shall be provided with waterproof
entanglement coat with hat by the employer.
of own clothing

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Sl. PPE Protection Legal requirements
No. against
6 Feet and legs Wet, hot The Factories Act, 1948
protection: and cold Though there is no direct provision under the Factories Act /
Safety boots conditions, Rules, The general provisions given at the bottom of the table
and shoes with electrostatic calls for providing feet and leg protection to employees wherever
protective build-up, required.
toecaps and slipping,
penetration- cuts and The BOCW Act 1996
resistant, and punctures, Section 46 : Head protection and other protective apparel
specific falling Every building worker required to work in water or in wet concrete
footwear, eg objects, or in other similar work at a building or other construction work,
foundry boots heavy shall be provided with suitable waterproof boots.
loads, metal
and Section 47: Electrical hazards
chemical Building workers using jack hammers, crow bars or other hand
splash tools which may come in contact with a live electrical line, shall be
provide with footwear.

The CEA Regulations, 2010

Rule no 19 : Handling of Electric Supply Line and apparatus
[ Refer provision given above under head protection]
7 Fall Falling from The Factories Act, 1948
Protection: height. Though there is no direct provision under the Factories Act /
safety Rules, The general provisions given at the bottom of the table
harnesses calls for providing fall protection equipment to employees
wherever required.

The BOCW Act

Section 178 : Safety belt and its use:
Whenever worker has to work at height standards employer shall
ensure safety of workers by providing safety belt, lifelines and
devices for the attachment of such lifelines conform to the
relevant national standard and such above protective equipment’s
supervised by responsible person for their fitness.
8 Respiratory Oxygen- The Factories Act, 1948
Protection: deficient Section 14 : Dust and fume
filtering atmosphere Effective measures shall be taken to prevent its inhalation and
facepieces, s, dusts, accumulation in any workroom protection of workers from dust
(half and full gases and and fumes.
dust masks) vapours
fresh-air hose, Section 36 : Precautions against dangerous fumes, gases,
compressed etc.
airline and self- No person shall be required or allowed to enter any confined
contained space until all practicable measures such as, person wearing
breathing suitable breathing apparatus and a belt securely attached to a
apparatus rope the free end of which is held by a person outside the
confined space.

Though there is no direct requirement under the Acts/Rules for provision of some PPEs, the auditor
should bear in mind that the following general provision under the Factories Act 1948 calls for providing
necessary PPEs to protect the employees:

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The Factories Act, 1948:

Section 7A: General duties of the occupier

• the arrangements in the factory for ensuring safety and absence of risks to health in connection
with the use, handling, storage and transport of articles and substances;

• the provisions of such information, instruction, training and supervision as are necessary to ensure
the health and safety of all workers at work;

Section 87: Dangerous Operations

Supply of protective equipment and clothing, and laying down the standards thereof, having regard to
the dangerous nature of the manufacturing process or operation.

Further, under the various State Factories Rules, the State Governments have declared dangerous
operations under section 87 of the Factories Act and have prescribed safety precautions to be taken in
these operations including the specific PPEs to be provided to the workers (Refer Annexure 5).

Guidance to check compliance:

The role of the auditor is to review that the right type of PPEs are provided and are being used properly
by the employees during the course of operation/work. During the audit the auditor should check the
various elements/ aspects of the organizations’ programme or system of ‘Selection, issue, maintenance
and use of PPEs’. He should carry out some sample checks by undertaking field visit to relevant areas on
the shop-floor, check relevant documents and gather certain documentary evidence to support his
observations. A checklist of certain important aspects to be verified by the auditor is given below for
guidance:

1) A list of required PPE for each hazardous activity available?

2) What is the system of procurement, inspection, issue, maintenance and replacement of
PPE?
3) What are the arrangements for safe custody and storage of PPE?
4) Do the PPE conform to any standard?
5) Whether feedback from workers obtained during selection of PPE?
6) Have the workers been trained in proper use of PPE including BA sets?
7) Are the contractor’s workers provided with the required PPE?
8) Is there any procedure for training/retraining of workers on the procedure for using PPE?
9) Whether the contract workers were provided with PPE?
10) Whether there is any provision of budget for procurement of PPE?

Documents to be checked:
1. List available with Safety department/store.
2. Work permit form contains list of PPEs to be used.
3. Procedure for PPE selection and issue.
4. Check PPE issue register.
5. Check PPE training records
6. Check company’s policy regarding issue of PPEs to contractors and discuss with management.
7. Check any Contract document for clause regarding PPEs..

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 Annexure

Dangerous Operations and PPEs to be provided as specified in State Factories

Rules, under the Factories Act, 1948

Schedule Dangerous Operation PPEs Specified

No.
I Manufacture of aerated waters and • suitable face-guards to protect the face, neck
processes incidental thereto and throat,
• suitable gauntlets for both arms to protect the
whole hand and arms
II Electrolytic plating or oxidation of • water-proof aprons and bibs, and
metal articles by use of an • for persons actually working at bath, loose-fitting
electrolyte containing chromic acid rubber gloves and rubber boots or other
or other chromium compounds. waterproof footwear
III Manufacture and repair of electric • a water-proof apron and water-proof footwear;
accumulators
IV Glass Manufactures • protective clothing, footwear, and safety goggles
according to the nature of work, including safety
headgear and such clothing’s, safety, footwear
and helmets etc.,
VI Manufacture and treatment of lead & • Suitable protective overalls and head coverings
certain compounds of lead
VIII Cleaning or smoothening, • Suitable gauntlets, overalls, dust-proof goggles
roughening, etc. of articles by a jet of and boots, protective helmets
sand, metal shot or grit or other
abrasive propelled by a blast of
compressed air or steam Blasting
Regulations
IX Liming and tanning of raw hides and • Water-proof footwear leg coverings, aprons and
skins and processes incidental gloves, chemical safety goggles for persons
thereto employed in processes.
X Manufacture of chromic acid or • suitable respirators, footwear
manufacture or recovery of the
bichromate of sodium, potassium or
ammonium
XI Manufacture or manipulation of Nitro • Long pants and shirts or overalls with long-
or Amino compounds sleeves and head covering. The shirt or overalls
shall cover the neck completely.
• Rubber gloves, rubber gum boots, rubber aprons
and air line respirator
XII Handling and manipulation of • suitable protective wear for hands and feet,
corrosive substances suitable aprons, face shields, chemical safety
goggles and suitable respirators
XIV Processes involving manufacture, • Overalls, face-shields, gloves and footwear all
use or evolution of carbon disulphide made of suitable material
& hydrogen sulphide • Suitable aprons and gloves
XV Manufacture & manipulation of • long pants and shirts or overalls with long
dangerous pesticides sleeves and head coverings,
• rubber gloves, gum boots, rubber aprons,
chemical safety goggles and respirators.
• Where the pesticide contains oil, the rubber
gloves, boots and apron shall be of synthetic
rubber

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 Handling & processing of Asbestos, • breathing apparatus and protective clothing
XVII Manufacture of any Article of
Asbestos & any other process of
manufacture or otherwise in which
Asbestos is used in any form.
XVIII Manufacture or Manipulation of • suitable overalls and head coverings, respiratory
Manganese & its Compounds protective equipment
XIX Carbon di-sulphide Plants • Suitable goggles and protective clothing
consisting of overalls without pockets, gloves and
foot-wear, respiratory protective equipment
XX Benzene • suitable gloves, aprons, boots and where
necessary vapour tight chemical goggles, made
of materials not affected by benzene or its
vapours
• respiratory protective equipment, self-generating
oxygen mask or oxygen or air cylinder masks
XXII Manufacture or Manipulation of • Long trousers and shirts or overalls with full
Carcinogenic Dye Intermediates sleeves and head coverings. The shirt or coverall
shall over the neck completely.
• Rubber gum-boots, Rubber hand-gloves,
Rubber-aprons,
• Airline respirators or other equivalent respiratory
protective equipment

* Please note that the schedule number may be different under the Factories Rules of different States.

The above table gives only the list of PPEs to be provided to employees engaged in the dangerous
operations, for detail provision refer your State Factories Rules.

f) OCCUPATIONAL DISEASE

Notice of occupational disease: As per Sec. 89 of the Factories Act, 1948; A notice in Form should be
sent forthwith both to the Chief Inspector and to the Certifying Surgeon, by the manager of factory Where
any worker in a factory contracts any disease specified in the schedule III .

SCHEDULE III- LIST OF NOTIFIABLE DISEASES

1. Lead Poisoning, including poisoning by any preparation of lead or their sequelae.

2. Lead tetra-ethyl poisoning.
3. Phosphorous poisoning or its sequelae.
4. Mercury poisoning or its sequelae.
5. Manganese poisoning or its sequelae.
6. Arsenic poisoning or its sequelae.
7. Poisoning by nitrous fumes.
8. Carbon disulphide poisoning.
9. Benzene poisoning, including poisoning by any of its homologues, their nitro or amide derivatives
or its sequelae.
10. Chrome ulceration or its sequelae.
11. Anthrax.
12. Silicosis.
13. Poisoning by halogen derivatives of the hydrocarbons of the aliphatic series.
14. Pathological manifestations due to : –
(a) radium or other radio-active substances; and

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 (b) x-rays.
15. Primary epitheliomatous cancer of skin.
16. Toxic anaemia.
17. Toxic jaundice due to poisonous substances.
18. Oil acne or dermatitis due to mineral oils and compounds containing mineral oil base.
19. Byssinosis.
20. Asbestosis.
21. Occupational or contact dermatitis caused by direct contact with chemicals and paints. These are
of two types that is, primary irritants and allergic sensitizers.
22. Noise induced hearing loss (exposure to high noise levels).

The reporting form for Notice of poisoning or disease are given in Form-27 under the model rule 122 of
the Factories Act,1948.

FORM-27
NOTICE OF POISONING OR DISEASE
1. Name of factory :
2. Address of factory :
3. Address of office of occupier :
4. Residential address :
5. Nature of industry :
6. (a) Name of patient :
(b) Works number of patient :
(c) Address of patient
:
7. Precise occupation of patient :
8. Nature of poisoning or disease from which patient is
suffering

9. Has the case been reported

the Certifying Surgeon :

Signature of manager :

Date :

(To be filled in by the Chief Inspector)

Number of the case :
Remarks :

Legal Requirement and audit check list:

The legal requirement for accident reporting under various statue is given at Annexure-1 and
audit check list also given at Annexure-2.

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 A-6 ACCIDENT / INCIDENT REPORTING,
INVESTIGATION AND ANALYSIS

a) Accident reporting,

b) Accident investigation

c) Analysis of accidents

d) Implementation of recommendations

e) Reporting and investigation of near -miss incidents

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a) ACCIDENT REPORTING

Organisations today particularly those operating in the hazardous environment have to tackle numerous
accidents, incidents and near misses that have continuously threaten their workforce and material safety.
Heavy concerns on near misses have also become increasing apparent and organisations are facing
great pressure in ensuring that these do not lead to full blown costly disasters.

Entire base of safety field is accident reporting and investigation. Accident reporting is important from
legal point of view. Accident analysis and investigation is important from the point of view of stopping its
further recurrence that means Accident Prevention point of view. By knowing causes of accident thru
accident investigation, you can take corrective and preventive actions for preventing its recurrence.

Accident reporting, external as well as internal, are important parts of accident prevention program. The
purpose of external reporting is to comply with the legal obligations i.e. report to statutory authorities
and/or contractual obligations whereas the internal reporting is for achieving continual improvement in
accident prevention program.

All accidents should be reported which helps to identify the root cause and prevent accident reoccurring.
Accident reporting varies from organization to organization as procedures are different. Usually the most
effective way of reporting is through a specific reporting form. All reports should be submitted to
management as soon as possible so the incident can be investigated. The investigation process should
carefully examine all aspects and failures that occurred in order to establish the root cause of the incident.
This is vital to ensure whether an effective and appropriate control measures are in place. Further, the
accident needs to be analysed for fostering the accident prevention program such as engineering and/or
administrative, control measure. Also, it helps to ensure whether the identified needs of personnel
protective equipment are in line or not, etc.

Terminology in accident reporting:

Accident - An unintended occurrence arising out of and in the course of employment of a person
resulting in injury.

Death - Fatality resulting from an accident.

Disabling Injury ( Lost Time Injury ) - An injury causing disablement extending beyond the day of shift
on which the accident occurred.

Non-disabling Injury - An injury which requires medical treatment only, without causing any disablement
whether of temporary or permanent nature.

Partial Disablement - This is of two types: disablement of a temporary nature which reduces the earning
capacity of an employed person in any employment in which he was engaged at the time of the accident
resulting in the disablement; and disablement of a permanent nature, which reduces his earning capacity
in every employment which he was capable of undertaking at the time.

Total Disablement- Disablement, whether of a temporary or permanent nature, which incapacitates a

workman for all work which he was capable of performing at the time of the accident resulting in such
disablement.

Injury and ill health: adverse effect on the physical, mental or cognitive condition of a person.

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Note 1 to entry: These adverse effects include occupational disease, illness and death.
Note 2 to entry: The term “injury and ill health” implies the presence of injury or ill health, either on their
own or in combination.

Incident: occurrence arising out of, or in the course of, work that could or does result in injury and ill
health

Note 1 to entry: An incident where injury and ill health occurs is sometimes referred to as an “accident”.
Note 2 to entry: An incident where no injury and ill health occurs, but has the potential to do so, may be
referred to as a “near-miss”, “near-hit” or “close call”.
Note 3 to entry: Although there can be one or more nonconformities related to an incident, an incident can
also occur where there is no nonconformity.

Reportable Disabling Injury (Reportable Lost Time Injury ) - An injury causing death or disablement to
an extent as prescribed by the relevant statute. As per Sec. 88 of the Factories Act, 1948, if in any factory
an accident occurs which causes death or any bodily injury, by reason of which the person injured is
prevented from working for a period of 48 hours or more immediately following the accident or which is of
such nature as prescribed in this behalf, the manager of the factory is required to send a notice thereof to
the authorities and in the form prescribed by the State Government and within four hours of the
happening of the accident.

The accident reporting form for reportable accident or dangerous occurrence resulting in death or bodily
injury are given in Form-25 under the model rule 121(3) of the Factories Act,1948.

FORM-25
REPORT OF ACCIDENT OR DANGEROUS OCCURRENCE RESULTING IN DEATH OR BODILY
INJURY
E.S.I.C. Employer’s Code number :
E.S.I.C. Insurance Number of the injured person :

1. Name of occupier ( or factory)/employer :

2. Address of works / premises where the accident or :
dangerous occurrence took place
3. Nature of industry :
4. Branch or department and exact place where the accident :
or dangerous occurrence took place
5. Name and address of the injured person :
6. (a) Sex :
:
(b) Age (at the last birthday) :
(c) Occupation of the injured person
7. Local E.S.I.C. Office to which the injured person is :
attached
8. Date, shift and hour of accident or dangerous occurrence :
9. (a) Hour at which the injured person started work on :
the day of accident or dangerous occurrence
(b) whether wages in full or part are payable to him :
for the day of the accident or dangerous
occurrence

208
10. (a) Cause or nature of accident or dangerous :
occurrence
(b) If caused by machinery :
(i) Give the name the part causing the accident :
or dangerous occurrence
(ii) State whether it was moved by mechanical power :
at the time of accident or dangerous occurrence
(c) State exactly what the injured person was doing
at the time of accident or dangerous occurrence :
(d) In your opinion, was the injured person at the time
of accident or dangerous occurrence :
(i) acting in contravention of provisions of any law
applicable to him; or
(ii) acting in contravention of any orders given by or :
on behalf of his employer, or
(iii) acting without instructions from his employer? :
(e) In case reply to (d) (i), (ii) or (iii) is in the
:
affirmative , state whether the act was done for
the purpose of and in connection with the :
employer’s trade or business
11. In case the accident or dangerous occurrence took place
while in travelling in the employer’s transport, state
whether -
(a) the injured person was travelling as a passenger :
to or from his place of works
(b) the injured person was travelling with the express :
or implied permission of his employer
(c) the transport is being operated by or on behalf of :
the employer or some other person by whom it is
provided in pursuance of arrangements made with
the employer; and :
(d) the vehicle is being/not being operated in the
:
ordinary course of public transport service
12. In case the accident or dangerous occurrence took place
while meeting emergency, state :-
(a) its nature ; and :
(b) whether the injured person at the time of accident or :
dangerous occurrence was employed for the occurrence
was trade or business in or about the premises at which
the accident or dangerous occurrence took place.
13. Describe briefly how the accident or dangerous :
occurrence took place
14. Names and addresses of witnesses
(1) :
(2) :
15. (a) Nature and extent of injury (e.g. fatal, loss of finger,
fracture of leg, scald, scratch followed by sepsis, etc.) :
(b) Location of injury (e.g. right leg,
left hand, left eye, etc.) :
16. (a) If the accident or dangerous occurrence was not fatal, :
state whether the injured person was
disabled for more than 48 hours :
(b) date and hour of return of work : :
17. (a) Physician, dispensary or hospital from whom or which :
the injured person received or is receiving

209
 treatment
(b) Name of dispensary/panel doctor
elected by the injured person :

18. (a) Has the injured person died? :

(b) If so, date of death :
I certify that to the best of my knowledge and belief the above particulars are correct in every respect.

Signature of manager/employer :

Name, designation and address of manager/employer :

Date of dispatch of report :

(This space is to be completed by the Inspector of Factories)

District ………………………….. Date of receipt :

Number of the accident or dangerous occurrence: Causation :
Other particulars (e.g. fatal, leg injury, arm injury, etc.) :
Date of investigation :
Result of investigation :

Notice of dangerous occurrences- As per Sec. 88A of the Factories Act, 1948, If any ‘dangerous
occurrence’ of such nature as prescribed occurs in a factory, whether causing any bodily injury or not, the
manager of the factory should send a notice thereof to the authorities, and in the form prescribed by the
State Government and within four hours of the happening of the dangerous occurrence.

The following classes of dangerous occurrences, whether they are attended by personal injury or
disablement:

1. Bursting of a plant used for containing or supplying steam under pressure greater than
atmospheric pressure.
2. Collapse or failure of a crane, derrick, which, hoist or other appliances used in raising or lowering
persons or goods, or any part thereof, or the overturning of a crane.
3. Explosion, fire, bursting out, leakage or escape of any molten metal , or hot liquid or gas causing
bodily injury to any person or damage to any room or place in which persons are employed, or
fire in rooms of cotton pressing factories when a cotton opener is in use.
4. Explosion of a receiver or container used for the storage at pressure greater than atmospheric
pressure of any gas or gases (including air) or any liquid or slid resulting from the compression
of gas.
5. Collapse or subsidence of any floor, gallery, roof, bridge, tunnel, chimney, wall, building or any
other structure.

The accident reporting form for dangerous occurrence not resulting in death or bodily injury are given in
Form-26 under the model rule 121(3) of the Factories Act,1948.

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 FORM-26
REPORT OF DANGEROUS OCCURRENCE WHICH DOES NOT RESULT IN DEATH ORBODILY
INJURY
1. Name and address of factory :
2. Name of occupier :
3. Name of manager :
4. Nature of industry :
5. Branch or department and exact place where the :
dangerous occurrence took place
6. Date and hour of dangerous occurrence :
7. Nature of dangerous occurrence :
(State exactly what happened)
I certify that to the best of my knowledge and belief the above particulars are correct in every respect.
Signature of manager:
Name, designation and address of manager:
Date of dispatch of report :

(To be completed by the Inspector of Factories)

District :

Date of receipt :

Number of the Causation :

dangerous occurrence :

Date of investigation :

Result of investigation :

Legal Requirements: ACCIDENT REPORTING

Sr. Legislation Section/sub- Provisions

No. section / Rule/
sub-rule/
Regulation
1 The Factories Sec. 7 A Occupier has to ensure the health, safety and welfare of
Act, 1948 all workers while they are at work in the factory.
Sec. 9 Factory inspector shall inquire into any accident or
dangerous occurrence, whether resulting in bodily injury,
disability or not, and take on the spot or otherwise
statements of any person which he may consider
necessary for such inquiry.

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Sr. Legislation Section/sub- Provisions
No. section / Rule/
sub-rule/
Regulation
Sec. 17 In every factory effective provision shall be made for the
prevention of the formation of shadows to cause eyestrain
or the risk of accident to any worker.
Sec. 41 H Right of workers to warn about imminent danger to the
notice of the occupier of the factory and simultaneously
bring the same to the notice of the Inspector.
Every occupier of the factory is to take immediate remedial
action about the existence of imminent danger and send a
report to the nearest Factory Inspector.
Sec. 88 In every factory, notice of certain accidents including fatal
or any bodily injury within a period of forty eight hours or
more to the concerned authorities
The authority shall make an inquiry into the occurrence
within one month of the receipt of the notice.
Sec. 88A Every occupier of factory shall send the notice regarding
dangerous occurrence to the authorities within a time
period
Sec. 89 A notice in Form should be sent forthwith both to the Chief
Inspector and to the Certifying Surgeon, by the manager
of factory in which there occurs a case of lead,
phosphorus, mercury, manganese, arsenic, carbon
bisulphite or benzene poisoning; or of poisoning by nitrous
fumes or by halogens or halogen derivatives of the
hydrocarbons of the aliphatic series; or of chrome
ulceration, anthrax, silicosis, toxic anaemia, toxic
jaundice, primary epitheliomatous cancer of the skin, of
pathological manifestations due to radium or other radio-
active substances or X-rays

Model Rules Rule – 121 Fatal/Dangerous Occurrence - Manager of a factory

made under the shall forthwith send the notice thereof by telephone,
Factories Act Special messenger or telegram to inspector and Chief
Inspector.
Notice of bodily injury to any person as is likely to cause
death in factory shall also send to,
a. The District Magistrate or Sub-divisional Officer;

b. The officer in charge of the nearest police station

c. The relatives of the injured or deceased person

Non-fatal/Reportable Accident - Send the report of
accident or Bodily injury due to dangerous occurrence to
Chief Inspector in prescribed format within 24 hours after
the expiry of 48 hours from the time of accident or
dangerous occurrence.
2 The BOCW Act, Sec. 39 Employer of any establishment shall send the notice to
1996 authority concerned in prescribed format regarding
accident which causes death or bodily injury and a person
injured prevented from working for a period of 48 hours or
more.

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 Sr. Legislation Section/sub- Provisions
No. section / Rule/
sub-rule/
Regulation
3. The BOCW Rule 210 Notice of any accident on the construction site which be
Central Rules, sent by telegram, telephone, fax or similar other means
1998 including special messenger within four hours in case of
fatal accidents and seventy-two hours, in case of other
accidents involving building workers, to -
(i) the Regional Labour Commissioner (Central), of the
area in which the establishment is located.

(ii) Board with which the building worker involved in

accident was registered as a beneficiary;

(iii) Director General; and

(iv) The next of kin or other relative of building worker

involved in accident

If disability from work is more than ten days following the

accident, then notice of accident shall also be sent to –
(i) the officer in-charge of the nearest police station;

(ii) the District Magistrate or Sub-Divisional Magistrate.

Rule 226 Employer of construction site or work shall maintained and

produced record of all accident to the inspector.
4. The Indian Sec. 8 Every occupier shall send the notice of accident to the
Explosives Act, Chief Controller of Explosives and to the officer in charge
1884 of the nearest police station
5. The Explosives Rule 25 Records of all accidents occurring within the licensed
Rules, 2008 premises shall be maintained and made available to the
inspecting authority
Rule 69 For explosive vehicle accident, the driver of vehicle or any
other authorized person accompanying the vehicle shall
(a) comply with all requirements of law relating to road
accidents
(b) inform the nearest police station;
(c) inform the Chief Controller by licensee
Rule 131 The notice of an accident shall be given within twenty four
hours of the happening of the accident by telephone,
telegram, E-mail, fax or in any other electronic mode or by
special messenger followed by a written report signed by
the occupier or authorized person to
(a) Chief Controller;
(b) Controller in whose jurisdiction accident has taken
place;
(c) District Magistrate; and
(d) Officer-in-charge of the nearest police station
6. The Static Mobile Rule 67 The licensee shall maintain records of all incidents
Pressure Vessels connected with storage, transportation or handling of
(Unfired) Rules, compressed gases and shall produce the same to the
2016 inspecting officer on demand.

213
Sr. Legislation Section/sub- Provisions
No. section / Rule/
sub-rule/
Regulation
Licensee shall be given the notice of an accident to–
(i) the Chief Controller or Controller by fax or e-mail followed
by a letter within twenty-four hours of occurrence

(ii)the District Authority; and

(iii) officer-in-charge of the nearest police station by

the quickest means.

7 The Gas Rule 67 Licensee shall be given the notice of an accident to–
Cylinders Rules, (iv) the Chief Controller or Controller by fax or e-mail
2016 followed by a letter within twenty-four hours of
occurrence

(v) the District Authority; and

(vi) officer-in-charge of the nearest police station by the

quickest means.

8 The Petroleum Sec. 27 The Occupier of the place shall be given notice of
Act, & accidents with petroleum to the nearest Magistrate or to
Petroleum Rules, the officer in charge of the nearest police station and to the
2002 Chief Controller of Explosives
Rule 200 The notice of an accident is required to be given to–
(i) the Chief Controller by telephone/fax and also by telegram
[telegraphic address- ‘Explosive Nagpur’] followed
within 24 hours by a letter giving particulars of the
occurrence the District Authority; and

(ii) the officer-in-charge of the nearest police station by the

quickest means of communication.

9 The Environment Sec. 9 The discharge of any environmental pollutant is excess is

Protection Act, apprehended to occur due to any accident shall be
1986 intimated to the authorities or agencies.
10 The Manufacture, Rule 5 Occupier shall sent the notification of major accident
Storage and occurs on a site or in a pipe line within 48 hours to the
Import of concerned authority
Hazardous The concerned authority shall undertake a full analysis of
Chemicals Rules, the major accident and sent the requisite information
1989 within 90 days to the Ministry of Environment and Forests
through appropriate channel
11 The Chemical Rule 7 Function of the State Crisis Group shall continuously
Accidents monitor the post-accident situation arising out of a major
(Emergency chemical accident in the State and forward a report to the
Planning, Central Crisis group
Preparedness,
Rule 9 Function of the District Crisis Group shall forward a report
and Response)
of the chemical accident within fifteen days to the State
Rules, 1996
Crisis Group
12 The Hazardous Rule 22 Where an accident occurs at the facility of the occupier
and Other handling hazardous or other wastes and operator of the
Wastes disposal facility or during transportation, the occupier or

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 Sr. Legislation Section/sub- Provisions
No. section / Rule/
sub-rule/
Regulation
(Management the operator or the transporter shall immediately intimate
and the State Pollution Control Board through telephone, e-
Transboundary mail about the accident and subsequently send a report in
Movement) prescribed format.
Rules, 2016
13 The Electricity Sec. 161 Notice of electrical accident shall be inform in prescribed
Act, 2003 format to the Electrical Inspector
CEA Regulations, Reg. 8 Accident shall be reported to the authorities within 24
2011 hours.
14 The Indian Sec. 18 Any accident occurs to a boiler or boiler component, the
Boilers Act, 1923 owner or person in charge shall within twenty-four hours of
the accident, report the same in writing to the Inspector
15 The Motor Clause 134 Duties of the driver involved in accident shall report the
Vehicles Act, accident to the Police Station
1988

Guidance for auditing:

While checking the compliance regarding accident reporting in line with the statutory requirement, an
auditor should check the following points

1) What is the procedure for accident / incident /dangerous occurrence reporting? (Documentation
to be checked)
2) Whether there is form for accident reporting (Internal/external) available?
3) Whether factory has maintained register of accidents and dangerous occurrences as specified
under the State Factories Rules.? Check the register.
4) Whether the accident data for the last five years for reportable accidents are available?
5) Whether the accident data for the last five years for non-reportable accidents are available?
6) Do interview with worker about past incidents/accidents happened?

b) ACCIDENT INVESTIGATION

Introduction:

In the aftermath of major accidents, a number of activities are normally initiated aimed at creating an
understanding of why the accident occurred and to prevent similar events in the future. One of these
activities involves the accident investigations conducted in many sectors. The investigation itself,
however, is merely one of the elements in the process of learning from accidents. For safety
improvements to be achieved, it is essential that the recommendations on remedial actions presented in
the accident investigations are followed by necessary actions, i.e. that they are implemented.

The prime objective of accident investigation is prevention. Finding the causes of an accident and taking
steps to control or eliminate it can help prevent similar accidents from happening in the future. Accidents
can rarely be attributed to a single cause. Work environment, job constraints, and supervisory or worker
experience can all play a part. These factors must be examined to determine what role each had in
causing the accident. Once the causes are established, precautions must be identified and implemented
to prevent a recurrence. Investigators must always keep in mind that effective accident investigation
means fact-finding, not fault-finding.

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The purpose of Investigation of Accident is

(1) To identify system deficiencies aiding in process / activity improvement

(2) To identify hazards and hazard mechanisms thereby improving hazard control process
(3) To aid in the financial resolution to compensate injured parties for the effects
(4) To resolve regulatory issues
(5) To reconcile labour / worker relations issues
(6) To identify unsafe work practices and accident-prone areas thereby got a reasonable control over
the facts

Terminology in accident investigation:

Accident: A specific unplanned event or sequence of events that has undesirable consequences.

Hazard: A characteristic of the system/plant process that represents a potential for an accident causing
damage to people, property or the environment.

Fire: A process of combustion characterized by heat or smoke or flame or any combination

of these.

Risk: A measure of potential economic loss or human injury in terms of the probability of the loss or
injury occurring and the magnitude of the loss or injury if it occurs.

Physical Exposure: An exposure which you must come into contact with to cause an injury or illness.

Environmental Exposure: You must be in the general area to be affected, examples include: loud
noises, chemicals fumes, etc.

Direct cause: The result of the condition and/or behaviour. The final event which produces an accident.

Surface cause: Hazardous conditions and unsafe employee/management behaviours that caused the
accident.

Root cause: The underlying reason the surface cause exists.

Personal Protective Equipment (PPE): Equipment worn to minimize exposure to a variety of hazards.
An example of PPE includes gloves or hard hats.

Unsafe conditions: Unsafe equipment/tools which directly cause the accident.

Unsafe actions: Harmful behaviours which contributed to the accident, this can include gaps in safety
training for staff.

Definition of accident investigation:

The accident investigation can be defined as Process of objective evaluation of all facts, statements and
related information as well as action plan to prevent / control the recurrence of the event. It is recognized
that every incident is caused by one or more root causes. It is required to collect evidence and conduct
its analysis to identify and understand what those root causes are and how do they interact. A variety of
methodologies are used to investigate the accidents by combining various investigation tools.

Technique for accident investigations:

The investigation process should begin after arranging for first aid or medical treatment for the injured
person(s). In getting started, remind everyone involved—especially workers— the investigation is to
learn and prevent, not find fault.

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Steps of the investigation process include:

1. Call or gather the necessary person(s) to conduct the investigation and obtain the investigation
kit.
2. Secure the area where the injury occurred and preserve the work area as it is.
3. Identify and gather witnesses to the injury event.
4. Interview the involved worker.
5. Interview all witnesses.
6. Document the scene of the injury through photos or videos.
7. Complete the investigation report, including determination of what caused the incident and what
corrective actions will prevent recurrences.
8. Use results to improve the injury and illness prevention program to better identify and control
hazards before they result in incidents.
9. Ensure follow-up on completion of corrective actions.

What to Include in the Documented Investigation Process:

As with many processes, preparation and documentation are crucial. As part of the injury and illness
prevention program, the investigation procedure should detail:

➢ Who should conduct and participate in the investigation

➢ Incidents to be investigated
➢ Information to be collected
➢ Identification of causal factors (often referred to as root causes)
➢ Determination of corrective actions
➢ Tracking completion of corrective actions

Who is involved - Normally, the investigation is conducted by the injured worker’s immediate
supervisor. However, assistance can also be provided by the safety practitioner, or team members from
an investigative or review committee or safety committee if such teams exist. In cases involving a fatality,
senior management personnel, engineering staff or legal counsel may also be involved. Those
participating in the investigation would include the injured worker, witnesses to the incident or events
preceding it, and the injured worker’s immediate supervisor if some other person is conducting the
investigation. The injured employee may also request the presence of an employee representative
during the interview if contractual agreements are in place.

The incident must be conducted jointly, with both management and labour represented, or that the
investigators must be knowledgeable about the work processes involved.
Members of the team can include:
• employees with knowledge of the work
• supervisor of the area or work
• safety officer
• health and safety committee
• union representative, if applicable
• employees with experience in investigations
• "outside" experts
• representative from local government or police

In some cases, authority should be included, such as if a serious injury or fatality occurred. Organization
should establish, implement, and maintain a procedure to coordinate managing incidents with the
authority having jurisdiction (e.g., police, OH&S inspectors, etc.). This coordination may include the
authority taking control of the incident scene.

217
What gets investigated - Any incident resulting in a fatality, serious injury, or damage to property,
equipment or environment should be thoroughly investigated. To obtain the best possible data to aid in
predicting and preventing future incidents, it is also recommended that all recordable, first aid and near
miss/close call incidents be investigated.

Information to collect - The type of information that should be collected during the investigation
process includes:
• Worker characteristics (age, gender, department, job title, experience level, tenure in company
and job, training records, and whether they are full-time, part-time, seasonal, temporary or
contract)
• Injury characteristics (describe the injury or illness, part(s) of body affected and degree of
severity)
• Narrative description and sequencing of events (location of incident; complete sequence of
events leading up to the injury or near miss; objects or substances involved in event; conditions
such as temperature, light, noise, weather; how injury occurred; whether preventive measure
had been in place; what happened after injury or near miss occurred)
• Characteristics of equipment associated with incident (type, brand, size, distinguishing features,
condition, specific part involved)
• Characteristics of the task being performed when incident occurred (general task, specific
activity, posture and location of injured worker, working alone or with others)
• Time factors (time of day, hour in injured worker’s shift, type of shift, phase of worker’s day such
as performing work, break time, mealtime, overtime, or entering/leaving facility)
• Supervision information (at time of incident whether injured worker was being supervised
directly, indirectly, or not at all and whether supervision was feasible)
• Causal factors (specific events and conditions contributing to the incident)
• Corrective actions (immediate measures taken, interim or long-term actions necessary)

What to have on hand - To be prepared to complete an investigation promptly following an incident, it is

best to have prepared a kit ahead of time that includes:
• Investigation forms
• Interview forms
• Barricade markers/tape
• Warning tags or padlocks
• Camera or video recorder
• PPE
• A pen
• Voice recorder
• Measuring tape
• Flashlight
• Sample containers

Interviewing people - Interviewing injured workers and witnesses necessitates reducing their possible
fear and anxiety, and developing a good rapport. Interviews should follow these steps:
1. Conduct the interview in a quiet and private place.
2. Use open ended questions.
3. State the purpose of the investigation and interview is to do fact-finding, not fault-finding.
4. Ask the individual to recount their version of what happened without interrupting. Take notes or
record their response.
5. Ask clarifying questions to fill in missing information.
6. Reflect back to the interviewee the factual information obtained. Correct any inconsistencies.
7. Ask the individual what they think could have prevented the incident, focusing on the conditions
and events preceding the injury.
8. Thank the witness.
9. Finish documenting the interview.

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The purpose of the interview is to establish an understanding with the witness and to obtain his or her
own words describing the event:

DO...
• put the witness, who is probably upset, at ease
• emphasize the real reason for the investigation, to determine what happened and why
• let the witness talk, listen
• confirm that you have the statement correct
• try to sense any underlying feelings of the witness
• make short notes or ask someone else on the team to take them during the interview
• ask if it is okay to record the interview, if you are doing so
• close on a positive note

DO NOT...
• intimidate the witness
• interrupt
• prompt
• ask leading questions
• show your own emotions
• jump to conclusions

Ask open-ended questions that cannot be answered by simply "yes" or "no". The actual questions you
ask the witness will naturally vary with each incident, but there are some general questions that should
be asked each time:
• Where were you at the time of the incident?
• What were you doing at the time?
• What did you see, hear?
• What were the work environment conditions (weather, light, noise, etc.) at the time?
• What was (were) the injured worker(s) doing at the time?
• In your opinion, what caused the incident?
• How might similar incidents be prevented in the future?

Asking questions is a straightforward approach to establishing what happened. But, care must be taken
to assess the accuracy of any statements made in the interviews. Another technique sometimes used to
determine the sequence of events is to re-enact or replay them as they happened. Care must be taken
so that further injury or damage does not occur. A witness (usually the injured worker) is asked to re-
enact in slow motion the actions that happened before the incident

Determining causal factors – The purpose of all this fact-finding is to determine all the contributing
factors to why the incident occurred. Statements such as “worker was careless” or “employee did not
follow safety procedures” don’t get at the root cause of the incident. To avoid these incomplete and
misleading conclusions in your investigative process, continue to ask “Why?” as in “Why did the
employee not follow safety procedures? Contributing factors may involve equipment, environment,
people and management. Questions that help reveal these may include:

1. Was a hazardous condition a contributing factor? (defects in equipment/tools/materials,

condition recognized, equipment inspections, correct equipment used or available, substitute
equipment used, design or quality of equipment)
2. Was the location of equipment/materials/worker(s) a contributing factor? (employee supposed to
be there, sufficient workspace, environmental conditions)
3. Was the job procedure a contributing factor? (written or known procedures, ability to perform the
job, difficult tasks within the job, anything encouraging deviation from job procedures such as
incentives or speed of completion)

219
 4. Was lack of personal protective equipment or emergency equipment a contributing factor? (PPE
specified for job/task, adequacy of PPE, whether PPE used at all or correctly, emergency
equipment specified, available, properly used, function as intended)
5. Was a management system defect a contributing factor? (failure of supervisor to detect or report
hazardous condition or deviation from job procedure, supervisor accountability understood,
supervisor or worker adequately trained, failure to initiate corrective action)

Completing report and documenting corrective actions - At this point, once you’ve gathered
information and interviewed the involved worker and any witnesses, you can prepare the investigation
report itself and formulate corrective actions. Your company should have determined who the report is
sent to, within what time frame and what information gets communicated to workers, management, or
gets filed or posted. Each corrective action listed should have a person assigned ultimate responsibility
for the action, a completion date set and a place to mark completion of the item.

Why look for the root cause?

An investigator or team who believe that incidents are caused by unsafe conditions will likely try to
uncover conditions as causes. On the other hand, one who believes they are caused by unsafe acts will
attempt to find the human errors that are causes. Therefore, it is necessary to examine all underlying
factors in a chain of events that ends in an incident.

The following techniques may be used for root cause analysis:

1) Event tray analysis
2) Fault tree analysis
3) Fish bone diagram analysis
4) Why why analysis
5) Management Oversight and Risk Tree (MORT)

The legal requirement for accident investigation

Sr. Legislation Section/sub Provisions

No. -section /
Rule/ sub-
rule/
Regulation
1 The Factories Sec. 7 A Occupier has to ensure the health, safety and welfare of all
Act, 1948 workers while they are at work in the factory.
Sec. 9 Factory inspector shall inquire into any accident or dangerous
occurrence, whether resulting in bodily injury, disability or not,
and take on the spot or otherwise statements of any person
which he may consider necessary for such inquiry.
Sec. 17 In every factory effective provision shall be made for the
prevention of the formation of shadows to cause eyestrain or the
risk of accident to any worker.
Sec. 88 In every factory, notice of certain accidents including fatal or any
bodily injury within a period of forty eight hours or more to the
concerned authorities
The authority shall make an inquiry into the occurrence within
one month of the receipt of the notice.
2. Maharashtra Rule 73 J Function of Safety Committee –
Factories Rules, Causes of accident can be identified with the help of health and
1963 safety surveys in factory
The Maharashtra Rule 8 Duties of Safety officer –
Safety Officers To render advice regarding reporting & investigation of accident,
Rules, 1982 to investigate accidents as well as dangerous occurrences and
maintaining the record of accidents

220
Sr. Legislation Section/sub Provisions
No. -section /
Rule/ sub-
rule/
Regulation
3. The BOCW Rule 208 Function of Safety Committee is to identify probable causes of
Central Rules, accident and unsafe practices in building or other construction
1998 work and to suggest remedial measures
Schedule Duties of Safety Officer are to investigate all fatal and other
VIII selected accidents and advice to maintain such record regards to
Rule 209 accident & dangerous occurrence mentioned as per Schedule
(1) & 209 VIII.
(2)

Rule 211 Enquiry of accident shall be commenced within 15 days of

receipt of notice of accident by authority.
Rule 250 The Director General may engage experts or agencies for the
purpose of conducting any inspection, investigation or enquiry
into the cause of an accident or a dangerous occurrence
Rule 69 For explosive vehicle accident, the driver of vehicle or any other
authorized person accompanying the vehicle shall
(a) comply with all requirements of law relating to road accidents
(b) inform the nearest police station;
(c) inform the Chief Controller by licensee
4. The Static Mobile Rule 68 Inquiry of accident shall be conducted by concerned authorities
Pressure Vessels
(Unfired) Rules,
2016

5. The Gas Rule 68 Inquiry of accident shall be conducted by concerned authorities

Cylinders Rules,
2016
6. The Petroleum Sec. 28 Inquiries into serious accidents with petroleum by concerned
Act, authorities

7. The Manufacture, Rule 5 Occupier shall sent the notification of major accident occurs on a
Storage and site or in a pipe line within 48 hours to the concerned authority
Import of The concerned authority shall undertake a full analysis of the
Hazardous major accident and sent the requisite information within 90 days
Chemicals Rules, to the Ministry of Environment and Forests through appropriate
1989 channel
8. The Chemical Rule 5 Function of the Central Crisis Group is conduct post-accident
Accidents analysis of major chemical accidents and evaluate
(Emergency Rule 7 Function of the State Crisis Group shall continuously monitor the
Planning, post-accident situation arising out of a major chemical accident
Preparedness, in the State and forward a report to the Central Crisis group
and Response) Rule 9 Function of the District Crisis Group shall forward a report of the
Rules, 1996 chemical accident within fifteen days to the State Crisis Group
9. The Hazardous Rule 22 Where an accident occurs at the facility of the occupier handling
and Other hazardous or other wastes and operator of the disposal facility or
Wastes during transportation, the occupier or the operator or the
(Management transporter shall immediately intimate the State Pollution Control
and Board through telephone, e-mail about the accident and
Transboundary subsequently send a report in prescribed format.
Movement)
Rules, 2016

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 Sr. Legislation Section/sub Provisions
No. -section /
Rule/ sub-
rule/
Regulation
10 The Indian Sec. 18 Any accident occurs to a boiler or boiler component, the owner
Boilers Act, 1923 or person in charge shall within twenty-four hours of the
accident, report the same in writing to the Inspector

Guideline for auditing

while checking the compliance regarding accident investigation, in line with the statutory requirement &
best practices, an auditor should check the following points

1) Whether accident investigation procedure is documented?

2) Are all the accidents investigated? (Investigation reports to be checked)
3) Whether root causes of accidents are analysed?
4) Whether accident investigation reports are submitted to top management?
5) Whether the findings of accident investigation reports communicated to workers/injured?
6) Whether the corrective actions as per recommendations are taken to avoid recurrence of
accidents? (it can be verified at workplace for compliance)

c) ANALYSIS OF ACCIDENTS

Introduction:

Accidents may be of different types depending upon the severity, durability and degree of the injury. The
availability of usable and reliable occupational health and safety data is seen as essential by employers,
trade unions and industry associations for the development, monitoring and evaluation of appropriate
preventive strategies designed to improve the health and safety of the working population. The legal
aspects pertaining to accident reporting are mentioned in various laws, rules and regulations. The bureau
of Indian standard has developed Indian standard-3786: Method for Computation of Frequency and
Severity Rates for Industrial Injuries and Classification of Industrial Accidents. The Indian standard-3786
has two Appendices. Appendix A deals with the Scheduled Charges for Disabilities and Appendix B
serves as a guide for Classification of Accidents. This standard prescribes basic methods for recording
and classifying industrial accidents. It also includes details of work injury and gives the methods for
computation of FR, SR & IR of work injuries in industrial premises. The objective for Classification of
Industrial Accidents is as follows:
➢ To help in evaluating the relative need for taking accident prevention measures in different
departments of an establishment
➢ To help in making an appraisal of the progress of an accident prevention campaign and making
people safety-conscious
➢ To provide encouragement when methods used for the prevention of accidents are successful
➢ To enable comparison

The methods for computation of FR, SR & IR of work injuries in industrial premises are given below:

Frequency Rate: Frequency Rate for lost time injury FA & FB

FA = Number of lost time injury X 106

Man-hours worked

FB = Number of reportable lost time injury X 106

Man-hour worked

222
Severity Rate: Severity Rate for Man-days lost due to lost time injury SA & SB:

SA = Man-days lost due to lost time injury X 106

Man-hour worked

SB = Man-days lost due to reportable lost time injury X 106

Man-hour worked

Incident Rate: Incident Rate is the ratio of number of injuries to the number of persons during the period
under review.

It is expressed as no. of injuries per 1000 persons employed. Incident Rate for lost time injury: I A and IB.

IA = Number of Lost-time injury X 103

Average number of persons employed

IB = Number of reportable lost-time injuries X 103

Average number of persons employed

Note 1 In all above cases ‘A’ should be used for comparison. purpose while ‘B’ should be used for
statutory purpose.

Note 2 Man-hours worked shall be calculated from the pay roll or time clock recorded including overtime.
When this is not feasible, the same shall be estimated by multiplying the total man-days worked for the
period covered by the number of hours worked per day. The total number of man-days for a period is the
sum of the number of men at work on each day of the period. If the daily hours vary from department to
department separate estimates shall be made for each department and the result added together.

Accident classification is a standardized method by which the causes of an accident, including the root
causes, are grouped into categories. Accident classification is mainly used in aviation but can be
expanded into other areas, such as railroad or health care. While accident reports are very detailed, the
goal of accident classification is to look at a broader picture. By analysing a multitude of accidents and
applying the same standardized classification scheme, patterns in how accidents develop can be
detected and correlations can be built. The advantage of a standardized accident classification is
that statistical methods can be used to gain more insight into accident causation. An Accident can be
classified according to 'Nature of Injury/Disease', 'Bodily Location of Injury/Disease', 'Mechanism of
Injury/Disease' and 'Agency' etc. A standard classification as given in BIS 3786 -Appendix B could serve
as a guide for detailed analysis of accidents for the study of the various causative factors and their
relationships. Each of the items of classification in Appendix B has been assigned a code number which
may be used to identify the recorded items of information. The classification of accident depends upon
causation factors related to accident and it can be classified as follows:

1) Agency:
Agency is the object or substance which is most closely associated with the accident causing the injury
and with respect to which adoption of a safety measure could have prevented the accident. The broad
category of Agency associated with accident is as follows:
• Machines
• Means of transportation and moving equipment
• Other equipment
• Material, Substances and radiation

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 • Working Environment
• Other Agencies- Mining and Tunneling
• Other Agencies not elsewhere classified
• Agencies not classified for lack of sufficient data
• Other Agencies

2) Unsafe mechanical or Physical condition:

This identifies the unsafe mechanical or physical conditions or conditions related to the agency which
contributed to the causation of accident. The classification of accidents according to Unsafe mechanical
or Physical condition is as follows:
• Improperly guarded agency
• Defects in agency
• Hazardous arrangement, procedure, etc in, on, or apparel
• Improper illumination
• Unsafe dress or apparel
• Improper ventilation
• Others

3) Unsafe act:
This identifies the deviation from the accepted and laid down safe procedure which contributed to the
causation of accident. The Classification of accidents according to unsafe act is as follows:
• Operating without authority, failure to secure or warn
• Operating at unsafe speed
• Marking safety devices inoperative
• Using unsafe equipment, hand instead of equipment, or equipment unsafely
• Unsafe loading, placing, mixing, combining, etc
• Taking unsafe position or posture
• Others

4) Unsafe personal factor:

This identifies the anatomical, physiological or psychological characteristic which permitted or occasional
the selected unsafe act. The Classification of accidents according to unsafe personal factors:
• Unsuitable anatomical, physiological, or psychological characteristics
• Lack of knowledge or skill
• Unsuitable mechanical or physical conditions, social environment etc.

5) Type of accident:

The type of accident is the manner in which the object or substance causing the injury comes into contact
with the injured person, or the movement of the injured person which resulted in the injury. It is
considered as immediate cause to accident because sudden release energy from the event like fire,
explosions, fall of object which and cause to injury. The Classification of accidents according to type of
accident:

• Fall of Persons
• Fall of objects
• Stepping on, striking against or struck by object Excluding falling objects
• Caught in or Between Objects
• Over-Exertion or Wrong Movements
• Exposure to or contact with Extreme Temperature
• Exposure to or contact with Electric Current

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 • Exposure to or contact with harmful substances, including radiation
• Explosions
• Others

6) Nature of Injury:

This identify the injury in terms of its principal physical characteristics.

• Fractures
• Dislocations
• Sprain or Strains
• Concussion and Other Internal Injuries
• Amputations and Enucleations
• Other Wounds
• Superficial Injuries
• Contusions and Crushing
• Burns
• Acute Poisoning
• Effect of Weather, Exposure and Related Conditions
• Asphyxia
• Effect of Electric Current
• Effect of Radiations
• Multiple Injuries of Different Nature
• Other and Unspecified Injuries

7) Location of Injury:

Location of injury identifies the part of the injured person’s body directly affected by the injury.
• Head
• Neck
• Trunk
• Upper Limb
• Lower limb
• Multiple location
• General Injuries
• Unspecified location of Injury

Legal requirement

Sr. Legislation Section/sub- Provisions

No. section / Rule/
sub-rule/
Regulation
1. The Factories Sec. 7 A Occupier has to ensure the health, safety and welfare of
Act, 1948 all workers while they are at work in the factory.
Sec. 41 H Right of workers to warn about imminent danger to the
notice of the occupier of the factory and simultaneously
bring the same to the notice of the Inspector.
Every occupier of the factory is to take immediate remedial
action about the existence of imminent danger and send a
report to the nearest Factory Inspector.

225
 Sr. Legislation Section/sub- Provisions
No. section / Rule/
sub-rule/
Regulation
2. Maharashtra Rule 73 J (7 h) Function of Safety Committee –
Factories Rules, Reviewing the implementation of the recommendations
1963
3. The BOCW Rule 208 Function of Safety Committee is to identify probable
Central Rules, causes of accident and unsafe practices in building or
1998 other construction work and to suggest remedial measures

Rule 250 The Director General may engage experts or agencies for
the purpose of conducting any inspection, investigation or
enquiry into the cause of an accident or a dangerous
occurrence
4. CEA Regulations, Reg. 4 (4 i) Establish system for accident reporting, analysis,
2011 investigation and implementation of recommendations.

Audit checks

While checking the compliance regarding accident analysis in line with the statutory requirement and
best practices, an auditor should check the following points

1) Whether there is a procedure for accident analysis? (Documentation to be checked)

2) Whether root causes of accidents are analyzed?
3) Whether accident analysis is done as per IS 3786 : 1983 or any internal system?
4) Is the Frequency rate, Severity rate for reportable accidents calculated?
5) Is the accident analysis helping in reducing similar accidents in last five years?

d) IMPLEMENTATION OF RECOMMENDATIONS

Introduction:

In many industries, a team of management people & workers conducts accidents investigation. Based on
investigation, the recommendations are made to address the contributing factors and are aimed at
eliminating or minimising risks associated with this or similar incidents, near misses or hazards. For safety
improvements to be achieved, it is essential that the recommendations presented in these investigations
are followed by necessary actions. Management is responsible for acting on the recommendations in the
investigation report. The health and safety committee or representative, if present, can monitor the
progress of these actions through the following process:

Develop Action plan: An action plan to be developed for the implementation of recommendations. This
action plan MUST include:

➢ details of which recommendations are to be implemented and how they are to be

implemented/actioned
➢ details of any additional actions arising from the discussions by the stakeholder group
➢ individuals who will be accountable for the implementation and monitoring of each
recommendation
➢ completion dates for the implementation of each recommendation
➢ dates for follow up and/or review of actions

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 ➢ A complex incident involving more than one stakeholder group, department and/or school, may
have more than one action plan directed at different work areas and/or managers.

Implementing action plan: The manager/supervisor must ensure the implementation and monitoring of
recommendations on the action plan by the dates stipulated on the plan.

If any of the actions are not able to be implemented by the proposed date the manager/supervisor must
provide details in writing/via email to Unit Head, prior to the proposed completion date, so that a new date
can be set or alternate arrangements made.

Review: The recommendations/actions must be reviewed post implementation to:

➢ ensure that they are effective in reducing risks
➢ ensure that the implementation has not created additional hazards

Legal requirement

Sr. Legislation Section/su Provisions

No. b-section /
Rule/ sub-
rule/
Regulation
1. The Factories Act, Sec. 7 A Occupier has to ensure the health, safety and welfare of all
1948 workers while they are at work in the factory.
Sec. 41 H Right of workers to warn about imminent danger to the notice
of the occupier of the factory and simultaneously bring the
same to the notice of the Inspector.
Every occupier of the factory is to take immediate remedial
action about the existence of imminent danger and send a
report to the nearest Factory Inspector.
2. Maharashtra Rule 73 J (7 Function of Safety Committee –
Factories Rules, h) Reviewing the implementation of the recommendations
1963
3. The BOCW Central Rule 208 Function of Safety Committee is to identify probable causes
Rules, 1998 of accident and unsafe practices in building or other
construction work and to suggest remedial measures
Rule 250 The Director General may engage experts or agencies for the
purpose of conducting any inspection, investigation or enquiry
into the cause of an accident or a dangerous occurrence
4. CEA Regulations, Reg. 4 (4 i) Establish system for accident reporting, analysis,
2011 investigation and implementation of recommendations.

Audit Check.

While checking the compliance regarding implementation of recommendation of accident investigation

report in line with the statutory requirement and best practices, an auditor should check the following
points

1) Whether the corrective actions as per recommendations are taken to avoid recurrence of
accidents? (it can be verified at workplace for compliance)
2) Whether the management ensures implementation of the recommendations to avoid recurrence
of accidents and incidents?
3) Whether there is a segregation of the recommendation on short term and long term action?
4) Whether there is a timeframe and responsibility for implementing recommendation?

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f) REPORTING AND INVESTIGATION OF NEAR –MISS INCIDENTS

Introduction:

An incident where no injury and ill health occurs, but has the potential to do so, may be referred to as a
“near-miss”. Other familiar terms for these events are a “close call,” a “narrow escape,” or in the case of
moving objects, “near collision” or a “near hit.”

Various accident investigations and reports have implied that accidents do not occur without any
precursors. There are dozens of incidents without any injuries or loss, prior to fatal accidents. This type of
incident is called a “near-miss”, which is usually neglected by workers and managers on-site. According to
Murphy’s Law, “Anything that can go wrong will go wrong”.
This indicates that if there are near misses on work sites, they will definitely develop into accidents with
serious consequences sooner or later.

Heinrich introduced the theory while working at the Travelers Insurance Company in 1929. Heinrich was a
pioneer in the field of accident prevention where he spent nearly 30 years in his work. Since the 1930s,
Heinrich’s work has influenced many safety practitioners. After studying 75,000 industrial accidents in the
1920’s, he concluded that every major injury there are 29 minor injuries and 300 no-injury accidents i.e
near miss cases. Out of that 88% of industrial accidents are caused by unsafe acts, 10% caused by
unsafe conditions with the remainder 2% being unpredictable.

Most people working in health and safety would have seen some variation of this formula in presentations
containing triangles with different coloured horizontal bands representing the different severity of injuries
and the ratios between them. Most commonly, these are used by proponents of Behaviour Based Safety
(BBS) programs and are often called Heinrich’s Triangle or Bird’s Triangle (after Frank Bird who revised
Heinrich’s classifications in 1969).
Heinrich’s Safety Pyramid provides a motivation to reduce the number of actual accidents by identifying,
recording and mitigating accidents that had a potential to occur. The Safety Pyramid illustrates that a
multitude of minor incidents are required for one major incident to occur, and even more near misses
should occur for some minor incidents. Behaviour by identifying, reporting and mitigating near misses,
safety lagging indicators, including first aids, injuries, illnesses and fatalities, can be avoided.
This theory explained an accident as a sequence that was likened to a row of dominoes knocking each
other down in a row. The sequences are Injury, caused by an Accident, due to an Unsafe act and/or
mechanical or physical hazard, due to the Fault of the Person, caused by their Ancestry (Physiological or
Psychological unsuitability or Lack of knowledge or skill) and Social Environment. Thus, when an accident
occurs, there is always a chain of events which occurs in a logical and fixed order. Each link in the chain
is dependent upon the preceding link. This is known as the Heinrich theory of injury occurrence. Thus,
for when accident prevention work, it is essential to analyse every accident, establish the real causes,
and take suitable corrective actions to prevent recurrence.

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Legal requirement

Sr. Legislation Section/sub- Provisions

No. section / Rule/
sub-rule/
Regulation
1 The Factories Sec. 7 A Occupier has to ensure the health, safety and welfare of
Act, 1948 all workers while they are at work in the factory.
Sec. 9 Factory inspector shall inquire into any accident or
dangerous occurrence, whether resulting in bodily injury,
disability or not, and take on the spot or otherwise
statements of any person which he may consider
necessary for such inquiry.
Sec. 41 H Right of workers to warn about imminent danger to the
notice of the occupier of the factory and simultaneously
bring the same to the notice of the Inspector.
Every occupier of the factory is to take immediate remedial
action about the existence of imminent danger and send a
report to the nearest Factory Inspector.
2. The BOCW Rule 208 Function of Safety Committee is to identify probable
Central Rules, causes of accident and unsafe practices in building or
1998 other construction work and to suggest remedial
measures.

Guidance for auditing:

While checking the compliance regarding Reporting and Investigation of Near –Miss Incidents in line with
the statutory requirement and best practices, an auditor should check the following points
1) Whether there is a procedure established for Near Miss reporting? (Documentation to be
checked)
2) Whether factory has maintained register of Near Miss reporting? Check the register.
3) Whether the Near Miss data for the last five years are available?
4) Whether Near Miss investigation procedure is documented?
5) Are all the Near Miss cases investigated? (Investigation reports to be checked)
6) Whether root causes of Near Miss cases are analysed?
7) Whether Near Miss cases investigation reports are submitted to management?
8) Whether the findings of Near Miss cases investigation reports communicated to workers/injured?
9) Whether the corrective actions as per recommendations are taken to avoid recurrence of Near
Miss ? (it can be verified at workplace for compliance)
10) Is there any system of classifying and analysing the near-miss incidents??
11) Is the Near Miss cases analysis helping in reducing similar accidents in past?
12) Whether the management ensures implementation of the recommendations to avoid recurrence
of incidents?
13) Whether there is a segregation of the recommendation on short term and long-term action?
14) Whether there is a timeframe and responsibility for implementing recommendation?

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A-7 EMERGENCY PREPAREDNESS (ON-SITE / OFF SITE)

a) Site specific details

b) Duties and responsibilities of key personnel
c) Identification of emergencies and accident scenario
d) Declaration and termination of emergency
e) Resources-evacuation / transport
f) Communication facilities
g) Medical care
h) Updating of emergency plan
i) Periodic drills / exercises
j) Training of plant personnel
k) Public awareness programmes
l) Mutual-aid programme
m) Emergency control centre

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a) Site Specific Plan
Putting together a comprehensive emergency action plan that deals with those issues specific to your
worksite. It involves taking what was learned from your workplace evaluation and describing how
employees will respond to different types of emergencies, taking into account your specific worksite
layout, structural features, and emergency systems.

Most organizations find it beneficial to include a diverse group of representatives (management and
employees) in this planning process and to meet frequently to review progress and allocate development
tasks. The commitment and support of all employees is critical to the plan's success in the event of an
emergency; ask for their help in establishing and implementing your emergency action plan.

Plans must contain site area maps (including layout, access roads and assembly points) available in
control room / emergency control centre.

• Plant site maps indicating designate Primary & Secondary Exits

• Hazardous Materials locations
• Exit Signs Indicating the Nearest Emergency Exit
• Designate a safe primary and secondary Assembly Area
• Indicate the Employee’s Current Location and be Oriented to the Actual Floor Arrangement

The zones and maps shall be prepared highlighting the accident prone areas of the unit so that in case of
an emergency it gives a basis for taking the action. This gives the size of the area within which human life
is seriously endangered by the consequences of accident scenarios. This should also indicate the
location of assembly points and emergency control rooms.

b) DUTIES AND RESPONSIBILITIES OF KEY PERSONNEL

Management of a major emergency in an installation requires a well-coordinated team with a senior
member of the installation acting as head of the emergency team. He is called the Chief Emergency
Commander.

An organogram of the emergency management team showing the reporting of various key members
should be made. The responsibilities of each key member should be clearly written and made known to
the member. The members should be made familiar with their roles by regular drills/rehearsals as
explained later on.

Key Members and Their Contact Numbers A key member for coordinating each of the following functions
of an emergency should be identified:
• Operations
• Security
• Medical.
• Rescue/Evacuation
• Human Resources
• Emergency Maintenance and Repairs
• Emergency Materials
• Technical and Engineering Services
• Transportation
• Public Relations

A list showing the contact telephone numbers of all the key members should be made which should be
regularly updated to incorporate any changes. This list should be available to each member to be kept
handy in his wallet.

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c) IDENTIFICATION OF EMERGENCIES AND ACCIDENT SCENARIO
All the possible accident scenarios leading to emergency must be identified and known to the operating
personnel , The emergency plan should be based on the risk assessment, whether it is quantitative or
qualitative. In absence of risk assessment, at least hazards analysis report is required for deciding the
probable emergencies such as fire, explosion and/or toxic release.

Assessing the hazard potential of an installation is the first step in planning for emergencies. To analyse
and to assess the potential hazards and safety of an installation, hazard analysis should be carried out
covering the following areas:

a) Which substance in the installation constitutes major hazard ?

b) Which design deficiency can contribute to a hazard ?
c) What failures or errors could cause abnormalities leading to an accident ?
d) Measures for preventing the accident.
e) Consequences of a major accident on the workers, people in neighbourhood and the environment.
f) Mitigation of the consequences of an accident.

The three basic steps of hazard analysis are :

• Hazard Identification
• Vulnerability analysis
• Risk analysis.

Hazard identification is the first step in the hazard analysis and entails the process of collecting
information on

• The types and quantities of hazardous substances stored, handled and disposed in the location
• The location of storage tanks & other facilities.
• Potential hazards associated with the spillage and release

Vulnerability analysis is the second step of hazard analysis and provides estimation of the zones of
influence or vulnerable zones. The process of estimation of zone of influence . The maximum single
storage of hazardous substance, should be identified and then probable maximum loss scenario should
be determined. This study will estimate the effects of the accident and draw evacuation plan, the
population statistics, the facilities and the environment encompassed within the vulnerable zone should
be available with the occupier.

Risk analysis is the third step of hazard analysis process, which provides a relative measure of the
likelihood and severity of various possible hazardous events and enable the emergency plan to focus on
the greatest potential risk.

Risk : Risk is defined as Risk = Consequence x Probability

One method of characterising the equipment failure is to assume that the failure is "worst possible"
failure, the failure that would produce the largest hazardous zone which is often called catastrophic failure
and includes such events as a tank collapse, rupture of vessels etc. This approach will be useful in
emergency response planning i.e. to determine the maximum area required for evacuation. Catastrophic
events are often least likely to occur. Therefore, the hazard assessment that includes only catastrophic
event may not address the failures that will expose the public at the greatest risk.

A thorough hazard assessment and all risk must consider both catastrophic and less severe release.
The less severe releases include gasket leak/failure, pump and compressor seal failures, discharge of the
relief valve to the atmosphere. tank filling piping failure, hose rupture etc.

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After calculating the risk, it must be brought to a level of "Maximum Tolerable Criterion" above which the
risk is regarded as intolerable whatever the benefit may be and must be reduced below this level. The
risk should also be made "As Low As Reasonable Practicable. The risk calculated above can be
compared to various levels of risk that may be considered acceptable by general public, plant workers,
govt. agencies etc. This forms basis for good emergency plan

d) DECLARATION AND TERMINATION OF EMERGENCY

Any emergency starts as a small incident which may become a major accident if not controlled in time. At
the initial stages, the fire organisation chart shall be put into action. If the incident goes beyond control
the on-site emergency plan will be actuated by Main Incident Controller or by emergency response
coordinator (ERC) at the appropriate stage as considered necessary.

During an emergency, individuals may panic or otherwise overreact. In the absence of leadership training,
problems will inevitably occur, and the chances for personal injury and significant damage to property,
equipment and facilities compound quickly. So first step in preparing for disasters or emergencies Plan
we should designate a leader -- an emergency response coordinator (ERC) -- who is trained to assess
the degree of the emergency and to determine the appropriate action.

The coordinator(ERC)/Leader should be drawn from top management ranks, In larger facilities, a backup
coordinator should also be named. The ERC is responsible for overseeing all emergency activities,
including the planning process and the selection and training of response team members. In an actual
emergency, the coordinator's duties would include:

• Determining whether a situation requires emergency procedures.

• Directing the orderly shutdown of plant operations when necessary.
• Evacuating personnel when necessary.
• Ensuring that outside emergency services such as medical and local fire departments are called
as needed.
• Notifying senior management of the emergency and the company’s response.
➢ Authority of activation and termination for onsite remains with ERC and communicating same
to all plant people generally done with help siren.
➢ The list of designated officials who are to be communicated about declaration and termination
of emergency must be available in the control room / emergency control centre or with
telephone operators
➢ The methods of communication (siren, public address system etc.) for declaration and
termination of an emergency known to all the workers

When emergency becomes disaster and evacuation beyond the plant premises is considered necessary
by the ERC , the situation will be handed over to District Authority for implementing the off-site emergency
plan. The management of emergency henceforth has to be controlled by the district crisis management
group from control room under the supervision of the District Collector.

e) RESOURCES-EVACUATION / TRANSPORT
For rapid mobilization of resources, it is essential to ensure that emergency are handed safely and
efficiently, To ensure the mobilization of resources extensive resource mapping must be done during
peace time. Planning must be done for getting Vital resources, in event of an accident in a industry, for
fire-fighting units, safety equipment, transport, local police help , medical help and help from district
authorities responsible for relief, rescue and evacuation operations.

In peace time planning and agreements must be done with various agencies and organization for
ensuring supply of material men and help from them during emergency scenarios .

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 The following internal resources (equipment, personnel and procedures) are required to handle
emergency. The following basic minimum must available within industry at site
1) Communications,
2) Public announcement systems
3) Monitoring of hazardous releases into the environment,
4) Emergency shelters at the facility,
5) Emergency exits with proper illumination, with uninterrupted power supply ,
6) Direction for emergency exit / escape route marked in haulage / Alleyways,
7) Transport for evacuation of plant personnel,
8) Medical care including administration of antidotes,
9) Security for maintain for law and order.

f) COMMUNICATION FACILITIES
During an incident, communication with the community becomes especially critical. Emergency
communications may include alerts and warnings; directives about evacuation, curfews, and other self-
protective actions; and information about response status, family members, available assistance, and
other matters that impact response and recovery.

Well-conceived and effectively delivered emergency messages can help ensure public safety, protect
property, facilitate response efforts, elicit cooperation, instil public confidence, and help families reunite.

The extent to which people respond to a warning message is influenced by many factors, including
individual characteristics and perceptions, whether the message comes from a credible source, how the
message is delivered, and the message itself.

You have many communication tools to choose from, including in-person events, print and broadcast
media, and Internet and social media. Each has advantages and limitations depending on your
communication objective and the intended audience.

Whatever communication tools you use, be sure your emergency communications are clear, contain
specific and adequate information, are in sync with other information being disseminated, and are
accessible to the whole community.

In the industry for internal communication of emergency equipment such as

• Manual call points
• VHF systems
• Land line telephones, wireless phone
• Pagers/SMS
• Public address systems
• Alarms and sirens

For external communication most of industry after getting approvals will communicate either from main
control room or fire stations have following modes of communication to out side agencies
• Hot line dedicated telephones
• In-person events—briefings
• Print media—newspapers and magazines.
• Broadcast media—television and radio.
• Internet and social media

In-person events such as media briefings and public meetings can be used to get information to the
media and the public. When properly planned and executed, these events can be a powerful tool to aid
you in communicating the messages you want disseminated to the public while guiding the news media to
important information for the public. Television and radio can be used to disseminate information quickly,
through the Emergency Alert System (EAS), Public Service Announcements (PSAs), and news programs.

234
More in-depth features can also be presented. Stations that broadcast in other languages can be used
as an avenue to reach specific populations within the community.

All emergency communications—regardless of the medium—should conform to general principles of

effective communication. In a crisis, clarity, specificity, and consistency are vitally important. Be sure to
this information is given by well trained person who also responsible and having full authority and having
full knowledge,
• Present the information in sequence.
• Present the reason for the message, the supporting information, and the conclusion.
• Word the message precisely, making every word count.
• Avoid jargon, codes, and acronyms.
• Use common terminology for all personnel and facilities.
• Omit unnecessary details.
• Speak in sync with other related authorities.
• Keep messages consistent across various media.

g) MEDICAL CARE

Medical care in normal time

The Factories Act 1948 Sec.45: (First Aid Appliances) There shall, in every factory, be provided and
maintained so as to be readily accessible during all working hours first-aid boxes or cupboards equipped
with the prescribed contents, and the number of such boxes or cupboards to be provided and maintained
shall not be less than one for every one hundred and fifty workers ordinarily employed at any one time in
the factory.

In every factory wherein more than five hundred workers are ordinarily employed there shall be provided
and maintained an ambulance room of the prescribed size, containing the prescribed equipment and in
the charge of such medical and nursing staff as may be prescribed and those facilities shall always be
made readily where a factory works in more than one shift, the Chief Inspector, if he is satisfied that on
account of the size of the factory, nature of hazards or frequency of accidents, it is not necessary to
employ a whole time medical officer for each shift separately, may, with the previous approval of the State
Government, grant exemption from the provision of this sub-rule and permit employment of only one
whole-time medical officer for more than one or all shifts, subject to the conditions.

Emergency health care –

Health and Hospital systems are the most critical units of the Emergency Support Function. “Guidelines
for developing Emergency Management Plan” intends to support the hospitals to formulate their own “all
hazard” emergency plans in accordance with their manpower and infrastructural resources that will meet
the demands of medical care more effectively during disasters/emergencies. Industry must tie with
hospitals services for emergency needs.

h) UPDATING OF EMERGENCY PLAN

Nothing ever stays the same. That’s why it’s important to take time to update your facility’s Emergency
Preparedness Plan at least every year. You never know when an emergency will occur. An up-to-date
plan will make sure you, staff, will be able to take quick action to keep everyone as safe as possible.

The emergency plan should be a living document. In fact, there is nothing worse than the “paper plan
syndrome”—or its modern digital equivalent—in which the plan is formulated and relegated to a desk
drawer (or a hard drive) without being used or updated. Such plans can do more harm than good when
they are eventually put to the test by a crisis. As time wears on, both small and large changes will occur.

235
Hence the plan should include provisions, not only for disseminating it and training its users, but also for a
process of constant updating, with checks at regular intervals, perhaps every six months.

Reviewing and updating the Emergency Response Plan is required to Communicate the contents of the
plan to all workers on the site as well as visitors during the site induction Assist in identifying the muster
point Provide support and assistance during an emergency Workers shall: Cease all activities when
requested during an emergency

i) PERIODIC DRILLS / EXERCISES

In most parts of the world, major incidents and disasters are, thankfully, rare, although they may be an
ever-present threat. The emergency plan therefore needs to be tested under hypothetical conditions.
Exercises and drills can be divided into table-top, command post, and field-based simulations. The last
category is clearly the most onerous, and it may require up to six months of meticulous planning.
Generally, none of these methods is capable of testing the whole plan, and so elements of it must be
selected for verification by simulation.

One common element is the ability of different organizations to work together under specific, unfamiliar
circumstances; for example, the ability of different medical response organizations to set up and run a
field hospital together.

Exercises need to be designed with clear, well formulated objectives, and the progress of the simulation
needs to be carefully monitored so that any need for improvements can be detected and communicated
to participants in post-exercise debriefings and reports. All of this needs to be done in an atmosphere of
constructive support, and certainly not recrimination, as the aim is not to examine but to help participants
improve their performance during future emergencies. Simulations need to be treated as learning
processes, from which it may be possible to derive improvements to the plan. One hopes that in real
emergencies it will also be possible to learn lessons and improve the emergency plan on the basis of real
experience. One such lesson is that personal familiarity with other participants in emergency operations
greatly improves the ability to work together. This underlines the value of emergency simulations and
drills.

Legal requirement of Emergency Drills

Sr. Statute/Act Section/Rul Provisions
No. e/ sub-rule
1. The Manufacture, Rule 13 Preparation of On-Site Emergency Plans: This occupier
Storage and is to prepare and keep up-to-date On-Site Emergency Plan
Import of (as per the details specified in Schedule II) for dealing with
Hazardous possible major accidents on his sites. Conduct mock drills
chemicals rules, of the On-Site Emergency Plan once in a period of six
1989 (Amended months.
2000 )
2. PNGRB Regulation 12.1 Carry out mock drills for on-site emergency plan once in
Regulations, three months and for off-site emergency plan once in
2010 twelve months
3. CAPPR Rules, Rule 9(2)(a) Puts statutory obligation on the Districts Crisis Group as its
1996 and functions to assist in preparing district off-site emergency
Rule 9(2)(g) plan and conduct on full-scale mock drill of a chemical
accident each year and send a report of the strength &
weakness of the plan to the State Crisis Group.
Rule Puts statutory obligation on the Local Crisis Group as one
10 (2) (a) of its functions to prepare local emergency plan of the
And industrial pocket and to conduct one full-scale mock drill of
Rule a chemical accident every six months and send a report to
10 (2) (e) the District Crisis Group

236
Sr. Statute/Act Section/Rule/ Provisions
No. sub-rule
4. Control of Industrial Rule 12 • Prepare on-site emergency plan as per
Major Accidents schedule 6 and keep it up-to-date
Hazards (CIMAH) Rules • Conduct mock-drill at least once in every six
under the Factories Act months
• Detailed report of the mock-drill shall be made
available to the Inspector
5. CEA Regulations, 2011 Regulation 9 Emergency Management Plan:
• Formulate On-site Emergency Management
Plan as per Schedule-III covering fire,
explosion, gas leakage, natural calamities and
crisis situations arising in the event of strikes,
terrorist threat and sabotage
• Conduct mock drill at least once every six
months
• Provide information to the District Collector for
preparing off-site emergency plan.
The Model Rules made 82-D(1) Required information to be provided to the
under Factories Act workers regarding measures to be taken by them
in case of spillage or leakage of hazardous
substances vis-à-vis the emergency plan of the
factory, in particular the evacuation procedure.
The information provided in the form of booklets
or leaflets and cautionary notice at workplaces in
the language understood by majority of workers.
National Building Code 2016 provides following provisions about evacuation plan and emergency drills
Sr. Part / Section Provisions
No. Annexure

1. Annex D D-3 DRILLS D-3.1 Fire drills shall be conducted, in accordance

(Clause 4.11) with the Fire Safety Plan, at least once every three
Guidelines for months for buildings during the first two years.
Fire Drill and Thereafter, fire drills shall be conducted at least
Evacuation once every six months.
Procedures for D-3.3 A written record of such drills shall be kept
High Rise on the premises for a three years period and shall
Buildings be readily available for fire brigade inspection.
D-8.9 Evacuation Drills
a) Frequency of drills
b) How conducted?
c) Participation? Who participated? How?
d) Controls and supervision
e) Recording of details of drills
D-9.1.4 Conduct fire and evacuation drills.
D-9 DUTIES D-9.3.6 Provide for Fire Warden identification
D-9.3 Fire Warden’s during fire drills and fires, such as using armband,
and Deputy Fire etc.
Warden’s
Duties

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Sr. Part / Section Provisions
No. Annexure
1 Part 3 Annex B B-23 Emergency Evacuation in
Development [Clauses 4.6.1.3(g), Buildings
Control Rules 13.3.1, 13.4 and 13.5]
And General Anthropometrics and Means of egress, alarm panel, alerting
Building Requirements for systems, evacuation plans, emergency
Requirements Accessibility in Built- evacuation routes, provision of area of rescue
Environment for Elders assistance/refuge areas and
and Persons with signages in such areas shall be in accordance with
Disabilities Part 4 : Fire and Life Safety of the Code.
Part 4 Fire and 4 Life Safety 4.10.2 The Fire Officer shall, buildings in the use of
Life Safety 4.10 Fire Officer firefighting equipment
provided on the premises and keep them informed
about the fire emergency evacuation plan

Audit Check Points :

• What is the system for conducting mock drills?
• The statute specifies the conducting of drills with certain frequencies as mentioned in above table.
Accordingly, check the frequency of the drill and its documentation including drill report. Such drills to
be conducted as per the scenarios identified in the Plan. Check whether identified scenarios are
covered under the past drills or not?
• Check in the drill report, whether deficiencies are reported. If reported, what actions have been
taken?
• Whether mock drill for chemical emergency is carried out? What is the frequency?
• evacuation procedures. (document check and discussion)
• Whether role of workers vis-a-vis the emergency plan of the factory, in particular the evacuation
procedures made available to all workers including contract workers?
• Documents to be checked: Emergency plan
• Field visit: Availability at field office and display of assembly point

j) TRAINING OF PLANT PERSONNEL

As the workplace becomes increasingly complex, new demands have arisen for greater understanding of
the causes and means of prevention of emergency incidences. The critical next step is the effective
transmission of this information to workers, supervisors, managers, government inspectors, and fire and
safety professionals.

The primary tools needed to achieve the goals for reduction of emergency incidence are to educate,
trained and aware about the plant emergencies . The specific purpose and impetus for education, training
and awareness will, however, vary for different target audiences.

Education, training and awareness to all employees are the first step in engaging them in discharging
their responsibilities effectively towards reduction in emergency incidences. The statutes also require
occupiers, employers to provide and make adequate arrangements for training of all workers. Such
trainings are to be imparted on regular basis either in-house or can be arranged outside. Certain jobs or
responsibilities require fire personnel and other employees to under-go specific training related to fire
safety.

The management should identify the training needs of all or all types of employees based on proper
assessment. Programmes should be designed on the principles of adult learning with right mix of
theoretical and practical inputs. The impact of training should also be assessed using in-process and end
of process techniques as well as on the job evaluation. Schedule of training programmes should be

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prepared on annual/quarterly basis along with the target participants and their numbers, responsible
personnel, venue, faculty and budget requirement. Proper records of all training programmes conducted
in-house as well as list of personnel under-gone training out-side should be maintained.

Basic emergency Awareness Training is a legal requirement that must be provided to all workers. In
addition to Awareness training, there is a requirement for training of those people who are responsible for
specific fire safety issues such as Fire Wardens, Emergency controllers, control room operators people
in charge of departments with specific fire safety emergency duties or risks and people who need advice
on a specific issue. It is essential that fire marshals/wardens as well as other staff in workplace should
know how to use a fire and emergency handling equipment safely and effectively and enable to manage a
workplace situation and provides with all the knowledge and practical experience needed to contain a
emergency at work.

k) PUBLIC AWARENESS PROGRAMMES

The key to reducing loss of life, personal injuries, and damage from emergency or disasters is
widespread public awareness and education. People must be made aware of what hazards they are likely
to face in their own communities. They should know in advance what specific preparations to make
before an event, what to do during a hurricane, earthquake, flood, fire, or other likely event, and what
actions to take in its aftermath.

Equally important, public officials and the media — television, radio, and newspapers — must be fully
trained to respond effectively, responsibly, and speedily to large-scale l emergencies. They need to be
aware, in advance, of procedures to follow in a crisis that threatens to paralyze the entire community they
serve, and they need to know how to communicate accurate information to the public during disaster.

Special efforts must also be made to train particularly vulnerable segments of the population — latch-key
children, the elderly, individuals in health care and correctional facilities, people with disabilities, and
those who do not speak English — with information about possible disasters and what to do in an
emergency.A significant portion of a good emergency plan to trained and shall provide instructions on
how to relay information to the general public..

l) MUTUAL-AID PROGRAMME
Introduction
In Indian at many industrial pockets a voluntary initiative on developing ‘mutual aid arrangement’ for
effective emergency response are formed .The industries during emergency situation mutually help each
other by sharing available resources to tackle emergencies. This industry initiative is supported by the
Director of Industrial Safety and health in many states,

Objective of scheme
• To identify and utilise the available resources effectively to mitigate emergency effects
• Minimise loss of life, property and human suffering
• Support the industries
• Technical Expertise on Chemical Safety
• Fire Prevention and Control
• Medical Facilities
• Information sharing on Hazardous Chemicals
• Preparation of ‘Green Book’: a ready reckoner of industries
• Safety training, Awareness programmes, Seminars
• Visual display of Safety information
• Formulate an Off-Site Emergency Plan
• Assist Government agencies in case of Off-Site Emergency

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 MARG Comprises
• Directorate of Industrial Safety and Health.
• Representatives of Large, Medium and Small Scale Industries.
• Technical Experts from Industries.
• Safety Professionals
• Fire Brigade.
• Local Police Personnel.
• Medical Experts from Industries and Local Hospitals.

m) EMERGENCY CONTROL CENTRE

Emergency Control Centre should low risk area and equipped with adequate means of communication to
areas inside and outside the work together with relevant data of Personal Protective equipment to assist
those manning the centre and to enable them to plan accordingly

The Emergency Control Room will be occupied by the Chief Incident Controller, the officials nominated
as key personnel and Sr. Executives of outside Services called in for assistance. No other person shall
have access to the Emergency Control Centre.(ECC)

ECC should also contain the following minimum facility and documents
• Safety data pertaining to all hazardous materials’ likely emergency etc.
• Procedure of major and special firefighting rescue operations and First Aid etc.
• Emergency call out list of persons drafted for emergency control key personnel fire safety
First Aid, medical, P&IR, Security and District Administrative Authorities.
• The following minimum facilities should be available in Emergency Centres:
• 2 nos. of Intercoms.
• 2 nos. of P&T Telephones.
• Telex and Fax.
• Wireless.
• Emergency manuals.
• Blown up area maps.
• District phone directories.
• Emergency lights.
• Wind direction and speed indicator.

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 A-8 SAFETY INSPECTION

a) Inspection programme

b) Safety Related Deficiency (SRD) Report

c) Safety inspection records

d) Methodology and inspection team

e) Compliance of recommendations

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a) INSPECTION PROGRAMME
The primary purpose of inspection is to detect potential hazards so they can be corrected before an
unintentional injury or illness occurs. Inspection can determine conditions that need to be corrected or
improved to bring operations up to acceptable standards, from both safety and operational standpoints.
Secondary purposes are to improve operations and thus to increase efficiency and effectiveness.

Planned inspections at specific intervals are what most people regard as real safety and health
inspection. They follow an established procedure and use checklists for routine items. These inspections
can be any one of three types – periodic, intermittent and general.

Pant Safety Inspections help discovering potential accident risks and is none of the oldest of accident
prevention techniques. The purpose of PSI is to find and remove hazards in jobs before accidents occur.
It may not be possible to spot and remove all the unsafe conditions or unsafe practices in the entire plant
in one stroke. A number of different types of inspections are undertaken so as to cover a good proportion
of all unsafe actions and conditions.

Persons making the inspection could achieve purpose of inspection better by consulting the persons
concerned in the shop and thus enlisting their cooperation. Safety inspection cannot be done effectively
by any one individual or agency. The responsibility should be shared by all those concerned.

Though the safety inspection will have to be carried out by all levels of personnel, the safety officer and
his assistants have a special responsibility in this respect. Being solely concerned with safety they have
the necessary time and critical eye for carrying out these inspections. Safety being principally a line
management function, persons from the line management should also take the main responsibility for
plant inspections. The duties of the supervisor require that he should continuously look out for hazardous
conditions and unsafe practices on the part of the men in his section. In addition to these in sections of
continuous type, he should make periodic inspections at regular intervals to see that all the hazards have
been properly safeguarded and that the safe procedures are being followed. The senior plant
management should periodically make thorough safety inspections of the plant of the sections of the plant
in their charge to locate all the hazardous conditions and practices.

Since the workers come into close contact with the machinery, equipment, tools and other parts of the
plant during working they can easily detect the defects associated with these. They should be
encouraged to report defects or hazardous condition which can cause accidents to themselves or others.
The persons making inspections should be familiar with the equipment, tools, the processes and
operations and should have adequate knowledge of the hazards associated with these. An inspection
checklist often proves to be very handy and will eliminate the chances of overlooking some of the sources
of accidents.

Types of Inspections
Safety Inspections can be of the following types:
(a) Periodic inspections,
(b) Intermittent inspections,
(c) Continuous inspections,
(d) Special inspection.

(a) Periodic Inspections

These inspections are well planned and made at regular intervals. Machinery, equipment, tools and all
parts of the plant should be inspected periodically. Their periodicity should be decided according to the
requirement. While making periodical general inspections, effect should be made to cover the entire plant,
particularly the inconspicuous places. For periodic inspections of pressure vessels, cranes, hoists,
elevators, chains cables, ropes, power trucks etc., a pre-arranged schedule as required by law should be
followed and these should be carried out by Competent persons.

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(b) Intermittent Inspections
These are unannounced inspections made at irregular intervals. These may be made by safety
department personnel, supervisors, safety committees, or individual workmen and may cover all particular
department, place of equipment or small work area.

(c) Continuous Inspections

In a system of continuous inspection, some selected employees spend all their time on serving certain
equipment or operations. Maintenance men, electricians; etc. fall under this category. Continuous
inspections of tools are done by stores staff in some factories. Continuous system of inspection of
personnel protective equipment to keep in good shape is especially desirable.

(d) Special Inspections

Special inspections are those which are occasionally made to locate hazards which are suspected to be
present in certain situations or processes. Example of such inspections are -
− Inspections during special campaigns such as fire prevention week, waste elimination.
− Inspections of new buildings, installations and processes.
− Inspections for investigation of accidents to determine causes.

b) SAFETY RELATED DEFICIENCY (SRD) REPORT

Every organizations ensure that safety deficiencies are properly identified and abated through an internal
process of reporting and recording safety hazards, promptly initiating corrective action and tracking those
actions through completion.

The monitors its success in mitigating deficiencies and its overall compliance with the e use of various
assessment techniques, including physical plant inspections and organizational safety program reviews
(conducted by the line management staff, building management and security office) and Management
Evaluation and Technical Reviews (conducted by the Office of Safety, Health and Environmental
Management).

These various tools and techniques provide a system of internal checks and balances that ensure the
continual improvement in the overall performance of the safety, health and environmental management
programs.

Each facility shall maintain a Log of Deficiencies reported to the Safety Coordinator and listing for each
deficiency: an identifying number, the date identified, description and location, who identified it and the
SRD of the deficiency Corrective Action Plan will be established for each deficiency, to include the details
of the corrective action, the interim controls taken to reduce the deficiency (if applicable), the interim SRD,
the individual/department/division responsible for correcting the deficiency, including a work ticket or
project number as applicable, and the estimated completion date. Final completion date will then be
noted for the record.

c) SAFETY INSPECTION RECORDS

Safety recordkeeping is more than just the OSHA Log. Records of inspections, training, audits,
corrections and other safety activities can help you in the event of an OSHA inspection. Additionally, a
good safety recordkeeping system of using these safety forms will allow you to track changes and trends
which is essential in reducing workplace accidents, injuries and illnesses.

Safety inspections records data must be analysis and results steps, be careful to maintain confidentiality.
Breeches in confidentiality can affect your credibility. Do not report results in such a way that individual
responses can be identified. This is especially important where there are workgroups is small . In such
circumstances, it may be necessary to report results for several workgroups, combined.

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Keeping inspection records is important. Past inspection records show what has been previously
identified. They also show what an earlier inspection team concentrated on and what areas it did not
inspect. Do not simply repeat or copy previous inspection results. Use the older inspection reports to help
look for issues, and then determine whether recommendations were implemented. Note if the changes
have been effective

d) METHODOLOGY AND INSPECTION TEAM

Planning for inspection
Planning is essential for an effective inspection. Every inspection must examine who, what, where, when
and how. Pay particular attention to items that are or are most likely to develop into unsafe or unhealthy
conditions because of stress, wear, impact, vibration, heat, corrosion, chemical reaction or misuse.
Include areas where no work is done regularly, such as parking lots, rest areas, office storage areas and
locker rooms.

Look at all workplace elements – the people, the environment, the equipment and the process. The
environment includes such hazards as noise, vibration, lighting, temperature, and ventilation. Equipment
includes materials, tools and apparatus for producing a product or a service. The process involves how
the worker interacts with the other elements in a series of tasks or operations.

Inspection Team

Health and safety committee members are obvious choices of personnel to carry out formal inspections,
especially if they have received training or certification. Other criteria for selecting the inspection team
are:
• knowledge of regulations and procedures
• knowledge of potential hazards
• experience with work procedures involved

Engineers, maintenance personnel, occupational hygienists, health and safety professionals, supervisors
or managers may be a part of the inspection team or they may be called upon to help with certain aspects
of the inspection, or to help explain equipment or processes. Large workplaces may have more than one
inspection team. The various teams can have separate areas to inspect.

Modality of Inspection

Discuss the planned inspection route before undertaking the inspection. Review where inspection team
members are going and what they are looking for. For example, during the inspection, "huddle" before
going into noisy areas. This discussion eliminates the need for arm waving, shouting and other
unsatisfactory methods of communication.

For inspections, wear personal protective equipment (PPE) where required. If you do not have PPE and
cannot get any, do not enter the area. List this as a deficiency during the inspection. Re-inspect the area
when PPE is provided.

Look for deviations from accepted work practices. Use statements such as: "a worker was observed
operating a machine without a guard." Do not use information derived from inspections for disciplinary
measures. Some common poor work practices include:

• using machinery or tools without authority

• operating at unsafe speeds or in other violation of safe work practice
• removing guards or other safety devices, or making the devices ineffective
• using defective tools or equipment or using tools or equipment in unsafe ways

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 • using hands or body instead of tools or push sticks
• overloading, crowding, or failing to balance materials or handling materials in unsafe ways,
including improper lifting
• repairing or adjusting equipment that is in motion, under pressure, or electrically charged
• failing to use or maintain, or improperly using, personal protective equipment or safety devices
• creating unsafe, unsanitary, or unhealthy conditions by improper personal hygiene, by using
compressed air for cleaning clothes, by poor housekeeping, or by smoking in unauthorized areas

Inspection Principles When conducting inspections, follow these basic principles

:
• Draw attention to the presence of any immediate danger - other items can await the final report.
• Shut down and "lock out" any hazardous items that cannot be brought to a safe operating
standard until repaired.
• Do not operate equipment. Ask the operator for a demonstration. If the operator of any piece of
equipment does not know what dangers may be present, this is cause for concern. Never ignore
any item because you do not have knowledge to make an accurate judgement of safety.
• Look up, down, around and inside. Be methodical and thorough. Do not spoil the inspection with a
"once-over-lightly" approach.
• Clearly describe each hazard and its exact location in your rough notes. Allow "on-the-spot"
recording of all findings before they are forgotten. Record what you have or have not examined in
case the inspection is interrupted.
• Ask questions, but do not unnecessarily disrupt work activities. This interruption may interfere
with efficient assessment of the job function and may also create a potentially hazardous
situation.
• Consider the static (stop position) and dynamic (in motion) conditions of the item you are
inspecting. If a machine is shut down, consider postponing the inspection until it is functioning
again.
• Consider factors such as how the work is organized or the pace of work and how these factors
impact safety.
• Discuss as a group, "Can any problem, hazard or accident generate from this situation when
looking at the equipment, the process or the environment?" Determine what corrections or
controls are appropriate.
• Do not try to detect all hazards simply by relying on your senses or by looking at them during the
inspection. You may have to monitor equipment to measure the levels of exposure to chemicals,
noise, radiation or biological agents.
• Take a photograph if you are unable to clearly describe or sketch a particular situation. Are
checklists available for inspections?

Report writing

To make a report, first copy all unfinished items from the previous report on the new report. Then write
down the observed unsafe condition and recommended methods of control. Enter the department or area
inspected, the date and the inspection team's names and titles on top of the page. Number each item
consecutively, followed by a hazard classification of items according to the chosen scheme.

State exactly what has been detected and accurately identify its location. Instead of stating "machine
unguarded," state "guard missing on upper pulley #6 lathe in North Building."

Assign a priority level to the hazards observed to indicate the urgency of the corrective action required.
For example:
A = Major - requires immediate action
B = Serious - requires short-term action
C = Minor - requires long-term action

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Report issues in a concise, factual way. Management should be able to understand and evaluate the
problems, assign priorities and quickly reach decisions.

After each listed hazard, specify the recommended corrective action and establish a definite correction
date if possible and appropriate. Each inspection team member should review for accuracy, clarity and
thoroughness.

e) COMPLIANCE OF RECOMMENDATIONS

Review the information from regular inspections to identify where corrective action was needed.
Determine if these actions have been taken. Use older reports to identify trends. Analysis of inspection
reports may show the following:
• priorities for other corrective action
• need for improving safe work practices
• insight about why incidents are occurring in particular areas
• need for education and training in certain areas
• areas and equipment that require more in-depth hazard analysis

The updated recommendations Corrective Action Plan, discuss it with the Director, key facility staff and
management as frequently as needed but at least twice per year to obtain management commitment,
budgetary resources, person, or position responsible for corrective action and estimated completion date.
The Log of Deficiencies and Corrective Action Plan will also be made.

The health and safety committee can review inspections, identify trends, and monitor the progress of the
recommendations. This analysis can be used as part of the continual improvement process for the
occupational health and safety program or management system.

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A-9 - OTHER RELEVANT TOPICS
a) Techniques of collecting information

b) Report writing

c) Examination of Documents

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a) TECHNIQUES OF COLLECTING INFORMATION

Method 1 – Collecting information by means of checklist

Different types of checklists can be prepared for use in monitoring. These checklists vary in length from
thousands of items to only a few. Each type has its place.

• Checklists serve as reminders of what to look for and as records of what have been covered.
• Checklists allow on-the-spot recording of all findings and comments before they are forgotten.
• Incase an inspection is interrupted; checklists provide a record of what has and what has not
been inspected.
• Without checklists, inspectors may miss things that they should see or be sure, after inspecting
an area, that they have covered everything.
• Checklist help in follow-ups.
• The amount of details included in the checklist will vary, depending upon the auditor’s knowledge.
• Checklists for frequent inspections generally will be more detailed than daily or weekly ones.
• Checklists should have columns to indicate either compliance or action-date.
• In the checklists, space should be provided to cite the specific violation.
• On each checklist, space should be provided for signature and date.
• Checklists should avoid:

1. Time-consuming backtracking and repetitions.

2. Long walks between items.
3. Unnecessary interruptions of the production process.
4. Distracting employees.

For each element, detailed checklist should be made.

Priority should be given in the checklist (i.e. compliance with statutory requirements) should be followed
while collecting information. Information received through checklist must be verified with supporting
records and sample observations during plant visit.

Method 2 – Interviews

This method is used to collect more information beyond that received through checklists.
The following points should be kept in mind while interviewing a person:

a. Interviewing persons is a difficult matter and should be handled properly.

b. Sometimes due to various reasons, the person is reluctant to provide required information.
c. During interview unnecessary/irrelevant question should be avoided.
d. The person being interviewed should be kept at ease.
e. It is very much necessary that the interviewer clear the air, create a feeling of trust and establish
lines of communication before beginning the actual interview.
f. Collect information by interviewing a person of appropriate level.
g. Verify statements from other person of same level/different level.
h. Interview the person at normal working location on shop floor.
i. Proper judgment should be used to select only sample of workforce for interview.

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Method 3 – Plant Visit

The following points should be kept in mind during this method:

a. Visit to the plant must be during normal working conditions.

b. Observations on relevant audit elements should be made and should be recorded on the spot.
c. Auditor should develop skill to make observations on several elements at each location.
d. Once sufficient deficiencies related to a particular item are detected, checking of that item at other
locations may be stopped.
e. When sufficient observations (particularly about acceptable systems) are made on a particular
element during plant visit auditor should spend less time in document verification of that item.
f. Priority should be given to checking against minimum (statutory) standards.
g. Safe operating procedures should also be checked.
h. Auditors should try to visit some locations under shut down/maintenance/construction etc.
i. Auditors must make one visit during second shift/third shift, holiday to assess conditions and
functioning of systems.
j. Auditor must check availability of operating manuals, safety manuals and safe operating
procedures and their compliance.

Method 4 – Checking of Records

• Check for completeness and authenticity of records.

• Evaluate formats for purpose and effectiveness as well as satisfactory filling up of formats.
• Asses checking of records and follow up action by higher authorities.
• Method of maintaining records should be checked. The following points should be taken into
consideration:
a. Period
b. Storage
c. Accessibility.
• Insist original records/documents for checking.

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 b) Report Writing

➢ Preparation of report is the core of the audit activity

➢ Normally report is to be sent within 4-6 weeks after completion of field work
➢ The report is called ‘DRAFT REPORT’
➢ The management goes through the draft report to incorporate typographical and factual
error
➢ Final report is prepared after incorporation of typographical and factual error pointed out by
auditee
➢ Final report to be sent within 2-4 weeks after receiving comments on draft report
➢ One copy original report alongwith a copy is sent

Preparation of Report

Report Writing

➢ Recommendations and observations as per finding and to be written element-wise

Management elements to technical elements.
➢ Any observation which appears to be serious violation of statues or standard practices should
be highlighted.
➢ Recommendation should be practical and free of bias.
➢ For any recommendation reference should be given (statutory, standard, guidelines of
manufacturer’s association, international standard etc.)
➢ Format, checklist, procedures etc. suggested should be enclosed.
➢ Factual and typographical error should be avoided.
➢ Language should be easily understood.
➢ Dubious/ambiguous word should be avoided.
➢ Reference to any document, equipment, location, procedures etc. to be made with correct
nomenclature, document number, date, identification number, plate, etc.
➢ The words ‘recommend, satisfactory, maintain, good practice may be used carefully.
➢ The report should complement the management for good practices.
➢ No department, section, individual should be blamed directly in the report.
➢ Confidentiality of report should be maintained.
➢ One copy should be retained by auditor.

Report Format

➢ Introduction of Company
➢ Brief description of manufacturing process
➢ Objectives
➢ Methodology
➢ Observations/Recommendations
➢ Executive Summery
➢ List of documents/Records checked
➢ List of references, standards, statutes followed
➢ List of enclosures such as format, photograph, checklist, work permit copy, internal order,
guidelines etc.
➢ Acknowledgement with date and name of auditors

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c) EXAMINATION OF DOCUMENTS
Types of Records to be examined during the Safety Audit – as per IS code

1. OH & S policy;
2. Safety organization chart;
3. Training records on safety fire and first-aid;
4. Record of plant safety inspections;
5. Accident investigation reports;
6. Accidents, dangerous occurrences and near miss incidents - statistics and analysis;
7. Record of tests and examinations of equipment and structures as per statutes;
8. Standard Operating Procedures (SOP) for various operations;
9. Record of work permits;
10. Record of work environment monitoring (flammable, toxic and explosive substances);
11. Maintenance, testing and calibration records of fire detection and fire fighting equipment;
12. Medical records of employees;
13. Records of industrial hygiene surveys (noise, ventilation, illumination, dust etc.);
14. Material Safety Data Sheets (MSDS);
15. On-site emergency plans and record of Mock Drills;
16. Records of storage of hazardous solid waste and its disposal;
17. Records of gaseous emissions and effluent discharges to the environment;
18. Housekeeping inspection records;
19. Minutes of safety committee meetings;
20. Statutory licences and approvals;
21. Records of any modifications carried out in plant or process;
22. Maintenance procedure and records;
23. Instrumentation and equipment calibration and testing records;
24. Planned shutdown maintenance procedures;
25. In service inspection manuals, records including that of material handling;
26. OH & S budget;
27. Inspection books and other statutory records;
28. Records of previous audits and safety analysis;
29. Procedures for safe transportation of hazardous substances;
30. Calibration records;
31. Records for breakdown of plants during the process of manufacture;
32. Records for waste material generated and their disposal;
33. SOP for disposal of waste materials; and
34. Records for issue of PPE items to the personnel working in process building

List of Statutory Records and Documents to be Checked (Indicative)

1. Approval of plan Under Factories Act 1948
2. Renewal of license of factory under factories rules
3. Stability certificate of factory
4. Records of minutes of meeting of safety committee
5. Inspection register of factory inspector
6. Reporting of accident to factory inspector
7. Compliance report against note of factory inspector
8. Record of periodical medical checkup employees
9. Records of checking of lifting machines (12 months) in prescribed format
10. Record of inspection of hoist (once in six months) as per prescribed format
11. Record of hydro testing of air receivers (once in 12 months)
12. Licenses requirement for storage of petroleum products under section 7, 8 of the petroleum
Act 1934 and its renewal
13. License and its renewal under Boiler Act 1923

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 14. License as per Rule 114 of the Explosive Rule 1983
15. Consent to operate under the Air (Prevention and Control of Pollution) Act 1981 with its
renewal
16. Consent to operate under the Water (Prevention And Control of Pollution) Act 1974 with its
renewal
17. Authorization for storage, Handling and Transportation and disposal of Hazardous waste
under Hazardous waste (Management and Handling) Rules 1989
18. License to store and Handle gas cylinders Under Rule 52 of The Gas Cylinder Rule 2004
and its renewal
19. License for storage of compressed gases Under Rule 45 of The Static and Mobile Pressure
Vessels (Unfired) Rule 1981 amended in 2002
20. List of authorized persons Under Rule 3 Electricity Rule 2005 etc.

DOCUMENTS TO BE VERIFIED Electrical Safety

1. Single line layout drawing of electric power distribution in the plant. (Approved Plan)
2. Test reports of Transformers, electrical equipment and earth resistance measurement
records.
3. Details of earthing system.
4. Inspection report of portable hand tools
5. Wiring diagram of protection and instrumentation systems
6. Accident register with a note to electrical accidents and their investigation records
7. Work permit system – samples
8. Operating manuals (SOP on electrical operations)
9. Training records
10. Original equipment manufacturer’s certificates w.r.t. flame proof equipment
11. Documents submitted to electrical inspectors and certificates obtained.
12. Electrical Inspectors approval and record of Annual Electrical Inspection.
13. Procedures for excavations.
14. Record on major electrical faults corresponding relay actions in past 5 years
15. Maintenance schedules of electrical equipment and record on types of maintenance carried
out.
16. Emergency Lighting Details
17. List of approved and licensed contractors and vendors.
18. Log book of operators
19. Battery backup system, battery Maintenance, testing and discharge testing records.
20. Licenses, testing and approval records of lifts, hoists etc.
21. NOC to operate DG set.

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