Status of Chemical Disaster Risk in India

Chemical Disaster
Chemical, being at the core of modern industrial systems, has attained a very serious concern for disaster management within government, private sector and community at large. Chemical disasters may be traumatic in their impacts on human beings and have resulted in the casualties and also damages nature and property. The elements which are at highest risks due to chemical disaster primarily include the industrial plant, its employees & workers, hazardous chemicals vehicles, the residents of nearby settlements, adjacent buildings, occupants and surrounding community. Chemical disasters may arise in number of ways, such as:-

1. Process and safety systems failures -Human errors
   -Technical errors
   -Management errors
   
2. Induced effect of natural calamities
3. Accidents during the transportation
4. Hazardous waste processing/ disposal
5. Terrorist attack/ unrest leading to sabotage

Status of Chemical Disaster Risk in India
India has witnessed the world’s worst chemical (industrial) disaster “Bhopal Gas Tragedy” in the year 1984. The Bhopal Gas tragedy was most devastating chemical accident in history, where over 2500 people died due to accidental release of toxic gas Methyl Iso Cyanate (MIC).
Such accidents are significant in terms of injuries, pain, suffering, loss of lives, damage to property and environment. India continued to witness a series of chemical accidents even after Bhopal had demonstrated the vulnerability of the country. Only in last decade, 130 significant chemical accidents reported in India, which resulted into 259 deaths and 563 number of major injured.
There are about 1861 Major Accident Hazard (MAH) units, spread across 298 districts and 25 states & 3 Union Territories, in all zones of country. Besides, there are thousands of registered and hazardous factories (below MAH criteria) and un-organized sectors dealing with numerous range of hazardous material posing serious and complex levels of disaster risks.
Safety initiatives taken in India to address chemical risk
The comprehensive legal/ institutional framework exists in our country. A number of regulations covering the safety in transportation, liability, insurance and compensations have been enacted.
Following are the relevant provisions on chemical disaster management, prevailing in country:-

1. Explosives Act 1884                                      - Petroleum Act 1934
2. Factories Act 1948                                        - Insecticides Act 1968
3. Environment Protection Act 1986                 - Motor Vehicles Act 1988
4. Public Liability Insurance Act 1991               - Disaster Management Act 2005

Government of India has further reinforced the legal framework on chemical safety and management of chemical accidents by enacting new rules such as MSIHC Rules, EPPR Rules, SMPV Rules, CMV Rules, Gas Cylinder Rules, Hazardous Waste Rules, Dock Workers Rules and by way of amendments to them.
The National Disaster Management Authority (NDMA) of India had come out with very specific guidelines on Chemical Disaster Management. The guidelines have been prepared to provide the directions to ministries, departments and state authorities for the preparation of their detailed disaster management plans. These guidelines call for a proactive, participatory, multi-disciplinary and multi-sectoral approach at various levels for chemical disaster preparedness and response. Further, NDMA has provided specific inputs to the GOM for avoidance of future chemical disasters in the country, along with suggested amendments on the existing framework. NDMA is also working on revamping of CIFs ( Chief Inspectorate of Factories) to strengthen chemical safety in India. In addition, MoEF and NDMA are in process of finalizing the National Action Plan on Chemical Industrial Disaster Management (NAP-CIDM), which will act as the roadmap for chemical disaster management in India.


Guiding Instructions of 15 most commonly used hazardous chemicals

• Acetone
• Acetylene Gas
• Ammonia Gas
• Argon Gas
• Benzene
• Caustic Soda (Sodium Hydroxide)
• Chlorine Gas
• Hydrochloric Acid
• Hydrogen
• LPG (Liquefied Petroleum Gas)
• Methanol (Methyl Alcohol)
• Naphtha
• Phosphoric Acid
• Sulphuric Acid
• Tri Nitro Toluene (TNT)
•  

  6 Steps to Evaluating Your Disaster Plan

  by Chris Kilbourne
  
  
  

  Since you never know when a disaster will hit and how it will affect your workplace, the key is to be prepared. And a first step for that is to evaluate—or reevaluate—your disaster plan.

  Here are six steps to take to insure a comprehensive review of your workplace disaster preparedness plan.
  

  Step 1. Assign priority and responsibility.

  Make it clear that management gives the project high priority and support.
  Assign one person to coordinate the task force or work group that will evaluate hazards and prepare plans. Select and appoint the participants. Most organizations try to involve a wide representation of managers, supervisors, and employees.
  Be sure to involve human resources, as well as safety, security, and operations. When a disaster occurs, employees will come to HR.
  Establish goals and timelines for completion of your review and update.
  

  Step 2. Evaluate your facility's challenges and hazards.

  Evaluate your situation to determine likely or potential problems. Certain challenges could face almost all organizations—fires, injuries, medical emergencies, and violence.
  Address threats that are specific to your geographic location, including flooding, mudslides, earthquakes, hurricanes, tornadoes, and other weather-related problems.
  Categorize and list threats related to your specific operations, such as dangerous equipment, dangerous environments (e.g., confined spaces), and hazardous substances.
  Consider neighboring facilities and the threats they may pose.
  If your buildings are some distance from fire, police, and emergency services, ascertain if providing extra training and equipment will help employees deal with emergencies until responders arrive.
  After approval, put the plan in writing, and share pertinent parts with employees.
  

  Step 3. Delineate steps for avoidance and prevention.

  Once threats are identified, think of measures that will prevent or contain them.
  Establish new rules or procedures as needed, such as increased security or more vigilance in enforcement of safety rules.
  Determine if more training in areas such as first-aid and CPR, hazardous materials response, or handling threats of violence may be required.
  Devise site-specific preparations for protecting materials, equipment, and data.
  Take steps to provide technological or physical protection for IT, including redundant systems and off-site capabilities.
  Meet with local emergency services organizations, including fire and police, and invite them to do a "walk-through" of your facility to familiarize themselves with the layout and help identify potential problems.
  

  Step 4. Plan for actions during and after a disaster.

  Prepare for evacuation
  
  
• Install and/or test the emergency alert systems.
  
• Review evacuation routes and designate assembly sites and reporting procedures.
  
• Inform employees, contractors, and others who frequent your facilities about the alert signal and the evacuation plan.
  
• Detail equipment shutdown procedures and identify employees who will stay to accomplish them.

Establish a command post
Identify:

• The location (on- and off-site)
  
• Who will be in charge
  
• Alternate communication methods including your website and intranet
  
• Who will deal with police, fire, and hazardous materials responders
  
• Who will deal with the media

Prepare for ongoing operations
In your planning, determine ways you will keep the business going after a disaster, including alternative sources of power, water, utilities, etc.
Find sources of temporary space, computer capability, phones, and other means needed to do whatever you normally accomplish.

Step 5. Practice your procedures.

Conduct practice drills to ensure that every employee knows what to do. Determine if drills uncover flaws in your plan.

Step 6. Make regular reviews.

Your standing procedures should include annual reviews of your plan. People leave, phone systems change, partitions are built, and so on. Also note if new technologies, equipment, hazardous substances, etc. have been introduced.

Crisis Manager. The primary Crisis Manager, alternate Crisis Manager, or designee is responsible for directing the recovery of business operations and has full authority to make decisions related to recovery efforts. The Crisis Manager will be responsible for communications with the insurance provider.

• Recovery Management Team. The Recovery Management Team members are responsible for implementing the portions of the Recovery Plan for their functional areas and are given authority to do so by the Crisis Manager.
• IT Manager. The Information Technology Manager will implement the IT Systems Recovery program and maintain all IT operations.
• Physical Plant Manager. The Physical Plant Manager will direct the reestablishment and maintenance of basic utility services (e.g., communications, water, electric, waste disposal) and ensure that critical equipment remains in service.
• Media Relations Manager. The Media Relations Manager will establish and maintain contact with the news media and other organizations concerning disaster recovery operations.
• Vendor/Contractor Manager. The Vendor/Contractor Manager will reestablish and maintain contact with vendors and contractors to provide supplies and services during recovery from a disaster.

Facility Security Manager. The Facility Security Manager will ensure that facility surveillance is maintained, prevent unauthorized entry to the facility, and maintain communications with government enforcement authorities as needed to protect employees and property.

• Human Resources Manager. The Human Resources Manager will implement any changes or amendments to personnel policies during disaster recovery, and administer personnel relocation or layoff programs.
• Customer Service Manager. The Customer Service Manager will reestablish and sustain communications with customers, and resume other customer services as soon as feasible.
• Recovery Command Center Supplies Manager. The Command Center Supplies Manager will provide basic supplies and services for Command Center operations.
• EHSQ EXECUTIVE. The EHSQ Manager will ensure that appropriate safety programs are implemented to protect employees from workplace injuries and illnesses. The EHSQ Manager will also administer the disaster recovery training programs and the disaster recovery integrity test.
• Suppliers and contractors. Suppliers and contractors who have agreed to provide supplies and services following a disaster or any major business disruption will perform work and provide materials and equipment necessary to return to normal operations.
• Critical operations support staff.  Critical operations staff, which consists of key employees that are considered critical for the continuation of business operations after a disaster, will work together as a team to keep the business going during the recovery.

 EHSQ
ARE  APPRECIATING TO SITE IN CHARGE SIR , FIRE & SAFETY DIVISION TO ORG ANISE MOCK DRILL  FROM 10.40 AM TO 11.15 AM,

1.DM Act, 2005 mandates NDMA to coordinate the enforcement and implementation of its policy & guidelines.

2.  The Act also mandates NDMA to take such preventive measures for the prevention of disaster or the mitigation or preparedness and capacity building for dealing with a threatening disaster situation or disaster as it may consider necessary – Mock Exercise one such measure.

3.  NDMA Guidelines on Chemical (Industrial) Disaster reinforces MoEF guidelines, to conduct mock drills for ‘On Site Plan’ at least once every six months and ‘Off Site Plan’  at least  once every year.

4.  NDMA Guidelines give out the formats for ‘On Site’ and ‘Off Site’ plans as

5.  MoEF Rules for ‘On Site’ and ‘Off Site’ Emergency Plans – 2001.

NEED FOR MOCK DRILL 

1.To Inculcate  Culture of Preparedness.

2.To Examine the Plans and SOPs of Identified Stakeholders.

3.To Evaluate the Resource Status of various Departments.

4.To Coordinate the Activities of Various Agencies  for their optimum utilization.

5.To use the Feed back to identify the gaps and improve the Resource Capabilities to Face Actual Disasters

Step 1

1, Coordinating Conference

(a) Delineating objectives of Mock Exercise.

(b) Scope of Exercise.

(c) Selection of the District/industry for Mock Exercise.

(d) Date and Venue for Table Top and Mock Exercise.

(e) Participants

(f) Media Coverage.

Step 2

2.Table Top Exercise.

•Precursor to Mock Exercise.

•Scenarios are initially painted at Local Industry level and spill over as “off site” emergency where district admn comes to aid; sometimes help from State/neighbouring district/s may be sought.. Principal Secy DM, Collector/DC and Stakeholders at State and District levels like  Director Industry, SSP, District Health Officer, Fire Officer, Public Services heads, NDRF Team Leader, Communication, Civil Defence, Home Guard, Red Cross, RTO, NGOs, Public Relations etc respond. Subsequent situations are painted as realistically as possible.

•Details of Coordination and Safety are discussed.

•The Gaps are identified and Remedial Measures taken

3.Mock Exercise.   

• Observers are detailed, briefed and format for assessment issued.

• Self Assessment Formats are given to all stake holders.

• Scenarios are formulated after due deliberations and the Mock  Exercise is conducted by painting of scenarios in a sequential manner.

• Sequence of events and Administrative Arrangements are finalized with States & District Authorities beforehand.

• Actions are taken on ground by concerned stake holders on orders of their own departments.

• Incident Command Post is established at district level for command and control. The State may also operationalise EOC.

•Relief Camps are established for evacuees.

•Hospitals are earmarked for evacuation of casualties and Medical Aid Posts are established at critical areas

Q.        What is Hazard Operability Study ?

A.         The application of a formal systematic critical examination to the process and engineering intentions of new or existing facilities to assess the hazard potential of Mal-operation or Mal-function of individual items of equipments and their consequential effects on the facility as a whole.

Q.        What are source models ?

A.         Source models represent the material release process.  They provide useful information for determining the consequences of an accident, including the rate of material release, the total quantity released and the physical state of the material.

Q.        What are dispersion models ?

A.         Dispersion models describe the airborne transport of toxic/inflammable materials away from the accident site and into the plant and community.

Q.        What is explosion ?

A.         The uncontrolled release of energy from a flame front propagating through flammable medium and characterized by the generation of heat, light and pressure.

Q.        What is Risk ?

A.         Risk is defined as a measure of economic loss or human injury in terms of both the likelihood and the magnitude of the loss or injury.

Q.        What is risk assessment ?

A.         Risk assessment includes accident scenario identification and consequence analysis.  Scenario identification describes how an accident occurs.  It frequently includes an analysis of the probabilities.  Consequence analysis describes the damage  expected.  This includes lose of life, damage to the environment or capital equipments and days outage. 

Q.        What is Occupational Safety and Health Audit ?

A.         A systematic, objective and documented evaluation of the occupational safety and health systems and procedures

Q.        What is Occupational safety and health management system ?

A.         A part of the overall management system that facilitates the management of OSH and risks associated with the business of the organization

Q.        What is Maximum Credible Loss Scenario (MCLS) study ?

A.         MCLS is described as the worst “credible” accident or as an accident with a maximum damage distance, which is still believed to be possible.

Q.        What is flammability limits ?

A.         The concentration of a mixture of flammable vapor or gas in air (% by volume of vapor to air) in which a flash will occur or a flame will travel if the mixture is ignited

Manufacture, Storage and Import of Hazarous Chemical (MSIHC) Rules, 1989

Q.        Which types of industrial activities are covered under the MSIHC Rules ?

A.        The following activities are covered under MSIHC

(a)               An operation or process listed in Schedule 4 carried out in an industrial installation involving one or more hazardous chemicals

(b)               An isolated storage involving one or more hazardous chemicals listed in Schedule 2, and

(c)                Pipeline for conveyance of a hazardous chemical other than the flammable gas at a pressure of less than 8 bars absolute

Q.        Which chemicals are covered under MSIHC Rules ?

A.         The chemicals fulfilling the criteria given in Part I and/or listed in Part II of Schedule I and chemicals listed in Schedule 2 and 3 are covered under MSIHC Rules

Q.         How does an occupier know that which provisions/rules are applicable to his factory?

A.         If one of the operations or processes listed in Schedule 4 is carried out in a factory involving one or more hazardous chemicals, an occupier has to first ascertain the category to which his factory belongs i.e. whether the factory comes under lower-tier, middle-tier or higher-tier because the requirements/ provisions are different for different categories of factories

Q.        Which are the three categories of factories ?

A.        The three categories of factories are given below :

Lower-tier Factory

Factories wherein an operation/process given in Schedule 4 is carried out involving one or more chemicals which satisfies any of the criteria laid down in Part I of Schedule I and/or listed in Column 2 of Part II of Schedule I irrespective of quantity of hazardous chemicals stored inside the factory, fall under this category.

Middle-tier Factory

Factories wherein an operation/process given in Schedule 4 is carried out involving one or more chemicals in quantities equal to or more than the quantity given in Column 3 of Schedule 2, fall under this category

Higher-tier Factory

Factories wherein an operation/process given in Schedule 4 is carried out involving one or more chemicals in quantities equal to or more than the quantity given in Column 4 of Schedule 2, fall under the category

Q.         Which are the specific rules to be complied with for different categories of factories?

A.        Category                   Provisions/Rules of MSIHC applicable

Lower-tier                   4, 5 and 17

Middle-tier                  4, 5, 7, 8, 9, 13, 14, 15 & 17

Higher-tier                  4, 5, 7, 8, 9, 10, 11, 12, 13, 14, 15 & 17

Q.        What are the requirements under different rules?

A.        Rule 4 :           General Responsibility of the Occupier –

(i)              To identify major accident

(ii)            To prevent major accident and

(iii)          Provide the workers information, training and equipment

Rule 5 :           Notification of major accident in Schedule 6

Rule 6 :           Industrial activity to which rules 7 to 15 apply

Rule 7 :           Approval and notification of sites in Schedule 7

Rule 8 :           Updation of notification following changes in T.Q.

Rule 9 :           Transitional provisions

Rule 10 :         Safety Reports/Safety Audit Reports with help of expert : Safety     

  Reports in Schedule 8.  Safety Audit every year

Rule 11:         Updating of reports under Rules 10

Rule 12:         Requirements for further information to be sent to the authority

Rule 13:           Preparation of on-site emergency plan by the occupier in Schedule 11(i).  Authority to ensure a rehearsal of the plan at least once in a calendar year

Rule 14:           Preparation of off-site emergency plan by the Authority in Schedule 12(i).  Authority to  ensure a rehearsal of the plan at least once in a calendar year

Rule 15:           Information to be given to persons liable to be affected by a major accident

Rule 17:           Collection, development and dissemination of information in Schedule 9

Q.         What constitutes a major accident OR what is the definition of major accident?

A.         “Major accident” means an incident involving loss of life inside or outside the installation, or ten or more injuries inside and/or one or more injuries outside or release of toxic chemicals or explosion or fire or spillage of hazardous chemicals resulting in on-site or off-site emergencies or damage to equipment leading to stoppage of process or adverse affects to the environment

Q.         Which type of factories are to be notified and by whom and when?

A.         An occupier of middle or higher-tier factory should submit a written report to the concerned authority i.e. the Chief Inspector of Factories of the State where the factory is located in Schedule 7 at least 3 months before the commencement of that activity.

Q.         Who should notify the major accident and to whom?  What is the time limit for notifying major accident?

A.         An occupier shall notify the major accident within 48 hours to the concerned authority (the Chief Inspector of Factories in case of factory) and furnish thereafter a report relating to the accident in Schedule 6.

Q.         How does an occupier know whether he has to prepare an on-site emergency plan?

A.         If the factory is middle or higher-tier factory, the occupier has to prepare on-site emergency plan.

Q.         What is the role of an occupier of a major accident hazard installation in preparation of off-site emergency plan?

A.         An occupier of a major accident hazard installation has to provide such information relating to industrial activity under his control to the concerned authority i.e. the District Emergency Authority/District Collector as may be required including the nature, extent and likely effects of site of possible major accident.

Q.         How often a mock drill/rehearsal of on-site emergency plan should be done?

A.         The mock drill of the on-site emergency plan shall be conducted every 6 months

Q.         Who is responsible for conduct of mock drill  of on-site emergency plan?

A.         An occupier is responsible for conduct of mock drills of on-site emergency plan

Q.         Who is responsible for organizing rehearsal of the off-site emergency plan and what is the frequency?

A.         The District Emergency Authority /District Collector is responsible for conduct of rehearsal of off-site emergency plan and the frequency is at least once in a calendar year.

Q.         Whether safety report and safety audit report are needed for every MAH installation OR how does an occupier know whether he has to get the safety report and the safety audit report prepared?

A.         No.  It is not required for every MAH installation.  The Safety Reports and Safety Audit Reports are required to be prepared by an occupier of higher-tier factories

Q.         What is the frequency of safety report and safety audit report?

A.         The Safety Report shall be prepared in the prescribed format given in Schedule 8 at least 90 days before the commencement of the activity.  The Safety Audit should be carried out and the Safety Audit Report shall be updated once in a year.

Q.        What are the duties of the authorities?

A.        The duties of the authorities are :

(a)         Inspect the industrial activity at least once in a calendar year

(b)         Report on compliance of Rules by the occupiers to the Ministry of Environment and Forests, through appropriate channel annually

(c)          On receipt of report on major accident, undertake full analysis of the major accident and send requisite information within 90 days to MOE&F through appropriate channel

(d)         Compile information regarding major accidents and make a available copy to MOE&F through appropriate channel

(e)         Inform in writing to occupier of any lacunae to be rectified to avoid major accidents

(f)            Approve the notification  of sites within 60 days from the date of receipt.  Report if notices contravention and issue improvement notice within 45 days of the receipt of the report

(g)         Prepare and keep up-to-date off-site emergency plan and ensure that rehearsal of off-site plan is conducted once in a year.

Factories Act 1948

Q.                 Do a hand driven lifting equipment need certification from competent person under article 29 of Factories Act?

A.                  Section 29 of the Factories Act deals with lifting machines and lifting tackles which are defined under explanation.  In our opinion hand driven lifting equipment does not require certification.

Q.                 Definition of “worker” under Factories Act 1948 & Maharashtra Factories Rules?  Whether officers/executives are to be considered for calculation of the employment strength with regard to recruitment of Welfare Officer under the Act?

A.                  Under the Factories Act, definition of “worker” is clearly given.  For the purpose of calculation of employment strength, officers and executives etc. have to be taken into account.

Q.         Which type of establishments are covered under the Factories Act?

A,         The term “factory” is defined in Section 2(m) of the Factories Act, 1948.  It means that in any premises if 10 or more workers are engaged in a manufacturing process with aid of power or if 20 or more workers are engaged in the manufacturing process without  aid of power such premises will be covered under the Factories, 1948

Q.        Whether a child is allowed to work in a factory?

A.         The child below 14 years of age is not allowed to work in any factory.

Q.        Whether a woman is allowed to work in a factory?

A.         The women are allowed to work in any factory except between the hours of 7 pm to 6 am i.e. women are not allowed to work during night time.  However, there are certain operations/processes, which are considered hazardous.  In such operations/processes women are not allowed to work.

Q.        What are the weekly hours of work in a factory?

A.         No adult is allowed to work in a factory for more than 48 hours in any week.

Q.        What are the daily hours of work?

A.         No adult worker is allowed to work in a factory for more than 9 hours in any day.

Q.        Which authority enforces the Factories Act 1948?

A.         The Factories Act and the rules framed thereunder are enforced by respective states/UTs. through the office of Chief Inspector of Factories under the Labour Department of the State Government/UTs.

Q.         Whether a place wherein a manufacturing process are carried out with or without the aid of power employing less than 10 or 20 workers respectively can be covered under the Factories Act?

A.         The State Government is empowered to declare that al or any of the provisions of the Act shall apply to any place wherein manufacturing process carried out irrespective of number of workers employed therein.

Q.         Whether a workshop of a teaching institute employing more than 10 workers will be in a factory?

A.         The State Government may exempt with certain conditions, in workshops whether manufacturing processes are carried out for purposes of education, training, research or reformation from all or any of the provisions of this Act.

Q.         Whether the approval, licensing and registration of a factory are compulsory?

A.         Yes, It is compulsory.  The approval, license and registration of a factory is compulsory before starting the manufacturing process.  The occupier of the factory should submit the plan to the Chief Inspector of the State for approval.  After the approval, the licensee will be granted by the CIF and the factory will be registered.

Q.         What are the various provisions to be abided by the occupier of the factory?

A.         There are many provisions, which are to be strictly followed by the occupier.  The details are available in a publication known as the Factories Act, 1948.  There are 120 sections divided into 11 chapters, which can be referred for detailed information.