SAFETY REPORT – STATUTORY REQUIREMENT
INTRODUCTION
“ THE MANUFACTURE. STORAGE AND IMPORT OF HAZARDOUS CHEMICALS RULES. 1989) ” is a chemical regulation introduced in India to regulate HAZARDOUS CHEMICALS during manufacture, storage and import, these rules are subsequently amended in 1994 and 2000.
As per these particular rules, HAZARDOUS CHEMICALS means any chemical which satisfies the criteria laid down in Schedule 1, 2 and 3
The main objective of the above said rules is to prevent major chemical accidents happening during Manufacture, storage and import by taking appropriate control and safety measures at each stage of the proposed INDUSTRIAL ACTIVITY.
HAZARDOUS CHEMICALS carries significant risk hazards which can result in major chemical accidents affecting both ONSITE and OFFSITE personnel, assets and considerable damage to the environment.
To mitigate the potential hazards that are present, all hazardous industries assess the hazard situations and their corresponding risk. Based on this information Industries take adequate safety precautions and control measures to mitigate the consequences of a major accident.
SAFETY REPORT is one such document that furnishes all the required information about the INDUSTRIAL ACTIVITY, processes involved, hazard analysis and assessment, hazardous chemicals used, consequences and mitigation of accident etc.
SAFETY REPORT is a mandatory documented requirement that has to be prepared and submitted by the OCCUPIER to the concerned authority by INDUSTRIES that handle HAZARDOUS CHEMICALS.
SAFETY REPORT AS A STATUTORY REQUIREMENT
As per RULE 10 of “ The Manufacture, Storage and Import of Hazardous Chemical Rules, 1989 ”, the following activities are to be ensured regarding SAFETY REPORT.
· The concerned authorities are
a. Central and State pollution control board
b. Chief Inspector of factories
c. Chief Inspector of Dock safety
d. Chief Inspector of mines
e. Atomic energy regulatory board
· For new Industries which are ready to undertake Industrial activities, a Safety report has to be submitted by conducting a fresh safety audit independently taken up by an expert who is not associated with that industrial activity before 90 days of commencing that Industrial activity.
· After the submission of the safety report, the concerned authority after reviewing can issue an improvement notice within 45 days for further review and analysis.
· After submitting the safety report based on the particular Industrial activity (based on a particular technology adopted at that moment) further modifications shall not be made to the Industrial activity which formed the basis for the safety report submitted earlier. If the occupier intends to change the technology/process after submitting the report, he should make a new SAFETY REPORT to the concerned authorities 90 days before making those modifications
CONTENTS OF SAFETY REPORT
As per SCHEDULE 8 of “ The Manufacture, Storage and Import of Hazardous Chemical Rules, 1989 ”, the following information to be provided in the SAFETY REPORT.
1. The NAME AND ADDRESS of the person furnishing the information
2. Description of INDUSTRIAL ACTIVITY which includes details like
o Site details and construction design undertaken
o The distances maintained between different process units
o Plant area classification into zones.
o Protection took against Explosions.
o Accessibility to plant during Emergencies
o Number of workers working and their exposure to hazard
3. Description of the INDUSTRIAL PROCESSES which includes details like
o Details about the technology of the process adopted
o Process description
o Safety-related data for all individual activities of a complete process
o Safety aspects related to Utilities
4. Description of the HAZARDOUS CHEMICALS which includes details like
o The quantity used the degree of purity of the chemical used
o Complete information of each hazardous substance like toxicological data, threshold values, emergency precautions, safe handling procedures etc. which covers the complete details of the chemical
o Physical and chemical behaviour as such and during any abnormality
5. Information about the Preliminary HAZARD ANALYSIS carried out which includes details like
o Safety system analysis to identify system elements or events that can lead to a major accident.
o Safety relevant components
6. Description About the SAFETY RELEVANT UNITS which includes details like
o Safety design criteria adopted
o Safety controls, alarms, and interlocks
o Emergency relief systems present
o Fire protection systems present
o Collection and dump tanks etc
7. Information about the HAZARDS ASSESSMENT which includes details like
o Identification and assessment of hazards
o Risk identification based on the frequency of hazards
o Assessment of consequences arising out of an accident
o Fire protection systems present
o An overall safety system that is in place (PPE’S, work permit systems etc)
8. Description of ORGANIZATIONAL SYSTEMS that help relevant activities/processes function smoothly which includes details like
o Safety policy and safety guidelines
o Inspection, maintenance and other relevant engineering safety schedules
o Guidelines followed in training all Plant personnel
o The organogram of Plant personnel with relevant safety hierarchy indicates the roles and responsibilities of each individual with regards to safety
o Implementation of Operating safety procedures across all process activities
9. Information on the assessment of the CONSEQUENCES OF MAJOR ACCIDENT which includes details like
o Assessment done on the possibility of accidental release of hazardous chemicals and measures taken and its impact on environment and personnel
o Assessment of Toxicological effects of the release on health and damage done to the property etc
10. Information on the MITIGATION OF MAJOR ACCIDENT which includes details like
o Fire Detection and alarm systems
o Fire protection and preventions systems
o Communication with Fire Brigade
o Onsite and Off-site emergency plans and procedures adopted and communicated
o Emergency control committees’ roles and responsibilities
o Rules, guidelines, communication and coordination adopted during emergency with both internally and externally
o Notification of the hazard to the concerned authorities in the event of an accident
o The antidotes prescribed in the event of a release of hazardous chemical
Article by PJ Mohan
Sr.Faculty, NIFS
1 comment:
Thank you for sharing this.
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