Standing Committee on Petroleum and Natural Gas (2017-18) on the subject Safety, Security and Environmental Aspects in Petroleum Sector

INTERESTING READING!!

STANDING COMMITTEE ON PETROLEUM & NATURAL GAS(2018-19)(SIXTEENTH LOK SABHA)MINISTRY OF PETROLEUM & NATURAL GAS[Action Taken by the Government on the recommendations contained in the Twenty Fourth Report (Sixteenth Lok Sabha) of the Standing Committee on Petroleum and Natural Gas (2017-18) on the subject Safety, Security and Environmental Aspects in Petroleum Sector]Presented to Lok Sabha on 07.01.2019Laid in Rajya Sabha on 07.01.2019

How Safe Are Workers at India’s Industrial Plants?

How Safe Are Workers at India’s Industrial Plants?

Govt moots single entity for oil sector safety, installations | Business Standard News

Govt moots single entity for oil sector safety, installations | Business Standard News

Contribute to the surviving victims of Bhopal by buying my book "Practical Process Safety Management"

Online access to OISD standards

Recently, I was informed by a senior OISD official that the Oil Industry Safety Directorate has provided free online access to their standards and guidelines. To register for them, please go to oisd.gov.in and see "online access" under the OISD standards tab. Register yourself and after approval you will get online access.
Thanks to OISD for this initiative!

Contribute to the surviving victims of Bhopal by buying my book "Practical Process Safety Management"

Duty of care: Indian Express

Duty of care : Indian Express

Contribute to the surviving victims of Bhopal by buying my book "Practical Process Safety Management"

COMMENTS ON CHEMICAL PLANT SAFETY & SECURITY RATING SYSTEM

I appreciate the initiative on the new safety and security rating system for chemical plants by the Indian Government and am sharing my comments sent to the Ministry on the new safety rating system:

1.    The initial screening criteria will eliminate many of the existing chemical units in the small and medium scale sector which also handle highly hazardous chemicals.  In such a case, what will be the action? I suggest that Initially, for SME sector, certification to OHSAS 18001 could be made mandatory and the proposed safety and security rating system be applied to MAH units. Later the modalities to extend it to SME sector could be worked out.

2.      In the initial screening criteria, one of the KPI’s is mentioned as “approved and documented PSM system available and implemented”. There is no reference to which PSM model to follow. I suggest that the basic OSHA CFR 1910.119 PSM rule of USA be followed. The threshold limit of chemicals for which PSM system applies could be the same list used in MSIHC rules.

3.    Any rating system is a snapshot of the organisations safety performance. However, in process safety management, top management commitment and technical competency of the people who run the system are important for achieving incident free performance. The proposal for the new safety rating system suggests that organisations with good safety performance will be incentivized. The opposite of this must also be implemented – if an organization that has been rated either 3,4 or 5 star in the new rating system experiences a reportable accident ( as defined in factory rules) after the award of the rating and within the periodicity of assessment, then the rating should automatically be downgraded to “Poor”.  This will ensure continued top management focus. The list of organizations who have been thus downgraded may be publicized on the Ministry of Chemicals and Fertilizers website or on a new website specifically dedicated to the “Chemical Plant Safety and Security Rating system”

4.      In the 19 KPI’s of final assessment, KPI’s 12,13 and 14 (Contractor management, emergency preparedness and response and training and competency) are already covered in the PSM system mentioned in KPI 2. They can be assessed as part of the PSM system.

5.      As the concept of “Occupier” and “Factory Manager” is already legally required for companies, I suggest that both of them be mandatorily assessed in final assessment on how they track PSM performance as well as competency levels to maintain the PSM system.

6.      In the evaluation questionnaire for PSM, in point 2.3, it is asked if QRA/LOPA is done for all operations and recommendations implemented? Instead, the question could be Whether Hazard Identification and risk analysis based on guidelines of IS 15526:2006 has been carried out and recommendations implemented?

7.      Finally, the new rating system will be recognized as unbiased and transparent by the public only if the if the assessment evidences for those organisations that have been awarded “Good, Very Good and Excellent” are posted on the website of the Ministry of Chemicals and Fertilizers or on a new website specifically dedicated to the “Chemical Plant Safety and Security Rating system”

                                                   END

Contribute to the surviving victims of Bhopal by buying my book "Practical Process Safety Management"

Safety rating for chemical plants: A step in right direction | Business Standard

Safety rating for chemical plants: A step in right direction | Business Standard

Contribute to the surviving victims of Bhopal by buying my book "Practical Process Safety Management"

Safety rating system for chemical units

The ministry of chemicals and fertilisers have published the draft safety rating system for chemical plants on their website for public comments. Give your comments to them by October end. You can access the draft rating system in this link. See the file in "important links" as well as "updates" scrolling on their website.


Contribute to the surviving victims of Bhopal by buying my book "Practical Process Safety Management"

Follow safety norms or face closure, Andhra Pradesh Minister warns units | The Hindu

Follow safety norms or face closure, Andhra Pradesh Minister warns units | The Hindu

Contribute to the surviving victims of Bhopal by buying my book "Practical Process Safety Management"

Regulatory oversight of PSM

There may be regulations and regulations but regulatory oversight (checking of implementation by legal authorities involved) need to be strong to enforce the regulations - this is one of the lessons learnt from the refinery fire in California. In India, too there are many good regulations but the problem comes when enough manpower and competency is not available with the regulatory authorities.
Read the article on the lessons learnt from a regulatory point of view from the refinery incident in California in this link.        http://www.mercurynews.com/top-stories/ci_22966315/federal-officials-say-regulatory-system-needs-overhaul-wake


Contribute to the surviving victims of Bhopal by buying my book "Practical Process Safety Management"

Challenges for process safety management in India

If we want to prevent another Bhopal type of disaster in India, a number of actions have to be taken on various fronts -industry, legislation, education etc. Please read my thoughts in this article, available in this link.
Hope to hear your comments.

 Contribute to the surviving victims of Bhopal by buying my book "Practical Process Safety Management"

"Get serious about safety"

An article in the Bangkok Post highlights lack of seriousness about safety. The article has similarities to what is happening in India. The recent train accident in Andhra Pradesh has the routine court of inquiry instituted but we never know the outcome of the inquiry! Read the nice article in this link.

Contribute to the surviving victims of Bhopal by buying my book "Practical Process Safety Management"

Lessons to learn from safety report of Railways

The Indian railways high powered committee on rail safety has published its report. There are two recommendations in the report which also apply to process safety management in India. I am quoting from the report: "There is no practice of independent safety regulation by an independent agency separate from operations. The Railway Board has the unique distinction of being the rule maker, operator and the regulator, all wrapped into one. Commissioners of Railway Safety though considered to be the safety watchdogs have negligible role at the operational level. Compliance of safety standards set by Railways for themselves are often flouted for operational exigencies. The Committee has recommended a statutory Railway Safety Authority (RSA) and a safety architecture which is powerful enough to have a safety oversight on the operational mode of Indian Railways without detaching safety with the railway operations. The Committee has also recommended measures to strengthen the present Railway Safety Commission to undertake meaningful regulatory inspections" IR suffers from ‘IMPLEMENTATION BUG’. Implementation of accepted recommendations of the previous safety committees has been a major issue. The Committee has recommended an empowered group of officers in Railway Board to pilot the implementation of the recommendations in a time bound manner with full funding. The Committee has also recommended the review of implementation of recommendations by the new statutory outfit of Railway Safety Authority under Government of India. In India, we need to make PSM mandatory and bring an independant investigating authority like the CSB. Also, the recommendations of safety audits need to be followed up. Read the full report in this link.

Industrial accidents in India

As interesting article in Livemint.com highlights that statistics of industrial accidents in India are not accurate. It mentions that "Data supplied by two labour ministry agencies show that accident insurance benefits claimed by companies indicate a rate of accidents that far outweigh those that are reported".
Read the article in this link.

Fukushima and Bhopal

I have been reading with interest the interest in nuclear safety in Indian nuclear reactors after the Fukushima incident. I was wondering that if Bhopal had happened today, would the implementation of laws improve? While the West has learned from Bhopal and implemented stringent laws,we in India are yet to focus clearly on chemical process safety management. With the chemical industry set to boom in the next decade, should we wait for another Bhopal to occur before actions are taken? The current focus on process safety in India is still largely on a reactive basis. While large organisations have proactively and voluntarily taken up PSM, it is the medium and small scale organisations that are not prepared. Many of these units handle highly hazardous chemicals. It is time that the large players in the Chemical Industry start a mentoring program free of cost to enable the small and medium scale players to improve process safety. It is good for the whole industry.

Process Safety - enforcement is the key

A refinery in the USA has been proposed to be fined US$ 207,500/= for 45 alleged serious and 13 other-than-serious violations for exposing workers to possible fires, explosions and other hazards.
The news article mentions the following:
"OSHA inspected the refinery under its Petroleum Refinery Process Safety Management National Emphasis Program. The PSM standard emphasizes the management of hazards associated with highly hazardous chemicals and establishes a comprehensive management program that integrates technologies, procedures and management practices.
OSHA’s Baton Rouge Area Office began its inspection Sept. 15, 2010, at the company’s facility on Old Highway 7. Serious violations include failing to conduct adequate inspections and testing of piping and pressure vessels; ensure that employees in process and administrative buildings were provided adequate protection in case of an explosion; implement written operating procedures; resolve recommended actions resulting from compliance audits; provide an adequate confined space program; and provide an adequate lockout/tagout program for the control of hazardous energy.
Other-than-serious violations include failing to provide the required machine guarding and correct electrical hazards".
I was reading an article about two deaths due to an accident in a chemical factory in India. The article quotes the Director of Factories as follows 
"We filed charges against the company with negligence, issues of safety and standards of equipment, among others," .He said if the court agrees with the charges, there can be a fine ranging from Rs 25,000 to Rs 2,00,000 under the Factories Act, 1992, for causing deaths". Rs 2,00,000/= is about US $ 4500. You can draw your own conclusions!!
Read the article on the US refinery in this link
Read the article about the accident in the Indian Company in this link.

Chemical Safety Authority needed in India

It is good to note that a Civil Aviation Authority is being set up by the Govt. to address safety issues in aviation.As per a news article, "the proposed CAA, which would have administrative and financial autonomy, is also likely to keep a tab on the entire range of activities —from proper provision of air traffic services and licensing to financial fitness of airlines.Government plans to bring in a legislation to establish the CAA. Bhushan said the CAA would have a "lot of financial, administrative and procedural independence. We will be able to recruit (professionals) directly" instead of routing it through the Union Public Service Commission".
On a similar line, it would be good if a Chemical Safety Authority  on the lines of the Chemical Safety Board of the USA is set up in India. Read the article about the Civil Aviation Authority  in this link.

Process Safety and Proposed changes to Indian Factories act

A news article in the Business Standard mentions the proposed changes to the Indian Factories Act. There are two proposed modifications, which I think may have an effect on process safety:
"The proposed changes to Section 64 and 65 of the Act, which deal with overtime working hours in factories, says the hours will be increased to 100 from the existing 50.
The proposals also seek to shift the blame for industrial accidents from the proprietor to the manager of a factory provided it is government-owned, by changing the definition of “occupier” of the factory in Section 2 (n) from the “person who has ultimate control over affairs of a factory” to the “person appointed to manage the factory”.
Workers who are working more hours of overtime are prone to making mistakes. There is a growing shortage of experienced qualified chemical plant operators in India and the proposed increase in overtime hours may affect process safety. The second proposed change of transferring accountability for Government owned companies to the person appointed to manage the factory may lead to a situation where the unit head in a government owned factory may resign when he or she finds things are not going his/her way with regard to process safety. This will lead to a discontinuity in managing process safety.
Read the article in this link.

Ammonia replaced as refrigerant after incidents of leaks

An article mentions the following:

"The West Bengal Pollution Control Board (PCB) has announced that ice or cold storage plants should switch from ammonia to HCFC 22 following a series of leakages. The ruling means that municipal corporations and municipalities should not give any further licence to any ice plant or cold storage in urban areas unless they submit written undertakings stating that they will use HCFC 22 methane as refrigerant gas instead of Ammonia.It’s claimed that ammonia gas leak from cold storages in the city and adjoining towns and other districts have previously affected thousands of people".

I think this move will spread to the whole of India. The way ammonia gas cylinders are handled in the small and medium scale industries leave a lot to be desired. It is an inherently safer option to replace ammonia used in refrigeration systems. On the same subject, I still observe a number of non chemical plants using chlorine for their water treatment systems. There are safer alternatives to chlorine and it is time that the industry takes a look at it.
Read the article in this link

Safeguards and Regulators

The BP oil spill incident has thrown up an interesting fact. While regulators in two major oil-producing countries, Norway and Brazil require acoustic switches to activate an underwater valve that shuts down the well even if the oil rig itself is damaged or evacuated, the US regulators do not require them. Norway has had acoustic triggers on almost every offshore rig since 1993. How do regulators decide what is necessary? I suspect this again has to do with study of safety integrity levels and the perception of risk. Read the full article in this link