January 16, 2010

Are your back up systems available?

On Thursday 14th January, it was reported that the entire radar systems at the Air Traffic Control (ATC) at the Indira Gandhi International airport at Delhi failed in the evening for about an hour. It was also reported that no takeoffs or landings could take place for more than two hours following the systems crash. The back up system also failed.The ATC system was finally restored at around 2030 hrs after reloading the system, with the entire procedure taking about three hours. The radar system collapse led to massive delays.
The above incident raises the importance of keeping back up systems always ready. A back up system is just that – it must back up when needed. Obviously something went wrong with the back up also. The only silver lining is that there must have been procedures for manual operation which was obviously put into place as there was no safety of flight issue. How good are your back ups for power supply for the DCS system? How often do you check them? Do not think that it will not happen. I had the personal experience of all 7 DCS screens of a methanol plant operating at full capacity, going blank all of a sudden! Develop procedures and train personnel for handling such situations.

January 14, 2010

Fire near refinery destroys shanties

It was reported that about 100 shanties were gutted in a fire near the Guwahati refinery on 11.1.2010. Luckily there were no casualties. The cause of the fire is yet to be ascertained. Local residents allege that the effluents released from the refinery in a bypass drain caught fire. The incident raises the question of facility siting and how did the shanties come up near the refinery? The Bhopal disaster was an epitome in facility siting. Shanties were allowed to spring up near the plant leading to greater number of deaths when the gas leaked. In today's scenario, allowing dwellings to come up near hazardous installations poses two risks - one is the exposure of people living in the shanties to the hazards from the installation and the other is from the security and terrorism point of view. The Jaipur oil depot fire also pointed out the hazards of allowing development close to hazardous installations. When will we wake up?

Accidents during transportation of Hazardous Chemicals - learning from NTSB

On12.1.2010, a 55 year old woman died when a chlorine cylinder that was being transported in a mini lorry, reportedly "exploded" at Thirumullaivoyal, near Chennai.
The newspaper photo depicts a mangled mini lorry with remnants of the cylinder that "exploded". I am sure that the investigation will be carried out. But what about the disclosure of the results of the investigation? We must learn from the National Transportation Safety Board of the USA who investigate transportation incidents. They investigate incidents involving aviation, road transport, pipeline and hazardous materials,marine, rail transport etc.Their investigators are on call 24 hours a day, 365 days a year. The results of investigations are posted on their website www.ntsb.gov. Why don't we learn from them? Information shared about the lessons learnt help to prevent another similar incident from happening and lives can be saved.
Another aspect of process safety that has been brought out by the incident is that it was reported that the chlorine was being transported for usage as a disinfectant. Today there are less hazardous alternatives to chlorine for the purpose of disinfection of water. The concept of inherent safety proposed originally by Dr Trevor Kletz propounds exactly this.

January 10, 2010

Process Safety -Fatigue and training

Between 2007 and 2009, at least 6 commercial aircraft in India landed on the wrong runway. Fatigued crew and lack of training are supposed to be the reasons. Just ponder for a moment - if incidents like these can happen in the aviation industry, can we in the Chemical Industry ignore these issues? Fatigue and training are issues which are relevant to process safety and a lot of work has been done on shift schedules and circadian rhythms.Overtime in a process plant brings about its own problems. My own experience is that a number of incidents happen when the operator is on overtime. We cannot blame the operator. The bigger issue is whether the organisation has a training program that always has manpower in the pipeline - to replace sudden resignations. Just like the software industry, the chemical process industry in India needs to have trained people "on the bench". But this always has its costs. It finally depends on how much risk the organization is prepared to take.

25 Years after the Bhopal Gas Disaster

The bhopal gas disaster on the night of December 2nd/3rd, 1984 led to a number of changes in legislation regarding the management of chemical process safety.
The recent massive blaze at the petroleum storage facility at Jaipur indicates the need for improvement in managing chemical process safety in India.
A comparison of the changes in legislation made in the USA after the Bhopal Gas Disaster with the changes made in India is given below:
Changes made in USA:
1.After the Bhopal Gas Disaster and other accidents in the 1980’s amendments were made to the Clean Air Act (1991). OSHA (Occupational Safety and Health Administration) was authorized to develop its 29 CFR 1910.119 rule of 1992, Process Safety Management. This system is mandatory in the USA since 1992 for chemical industries, storing or processing highly hazardous chemicals, above a threshold quantity. After the implementation of this rule, there was a major incident at the BP Texas refinery in 2005. A thorough investigation about the reasons for the incident and follow up actions are clearly visible to the public. The investigation reports of the incident are made available to the public on the web.
2.The US Environmental Protection Agency also implemented the Risk Management Program in 1996 to prevent an off –site disaster (An off-site disaster is an event that has repercussions outside the boundary walls of the chemical industry in which the incident took place).
3.The US Chemical Safety Board was set up in January 1998 by an amendment of the Clean Air act. It is authorized to investigate chemical accidents in the USA and publish its investigation reports on its website www.csb.gov. The board cannot impose fines or promulgate regulations. It creates public awareness by publishing its investigation reports on the web.
Changes Made in India:
1.After the Bhopal gas disaster, the Factories Act was amended to assign the responsibility of the “occupier”, who is legally responsible for the safety of the workplace and workers, to the highest level of management in an organization. For a public limited company, one of the directors on the board had to be designated as “occupier”. The Environmental legislation also underwent changes, with the Environment Protection Act introduced in 1986. Under this act, a number of new legislations were framed. The Manufacture, Storage and Import of Hazardous Chemical rules, 1989 required safety audits to be carried out in hazardous chemical factories, storing more than a threshold limit of hazardous chemicals.
2.The Chemical Accidents (Emergency Planning, Preparedness and Response) Rules, 1996 was also introduced. Preparation of on-site Emergency Plan by the Industry and Off-site Plan by the District Collector and the constitution of four-tier Crisis Groups at the Centre, State, District and Local level for management of chemical accidents are mandatory under these Rules.
Recommendations to improve chemical process safety management in India:
1.The enforcement of existing legislation regarding chemical process safety by the Indian authorities must be made effective by training the law enforcers in the latest developments in prevention of chemical accidents, inspection and management system audit techniques.
2.While statutory safety audits continue to be performed in the chemical industries, the public should also be informed about the status of implementation of the recommendations of the safety audit.
3.The investigation of Chemical Process Incidents in India should be carried out by an independent body similar to the Chemical Safety Board of USA and their investigation reports must be made public.

PS: Regarding Sriram's comment below, there is a requirement in Factories rules Sec 41 C for hazardous operations that "the occupier must appoint persons who possess qualifications and experience in handling hazardous substances and are competent to supervise such handling within factory..."