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OISD-GDN- 206 First Edition, September, 2001

Guidelines on Safety Management System

in Petroleum Industry

OISD-GDN- 206

Oil Industry Safety Directorate Government of India Ministry of Petroleum & Natural Gas

1 NOTE

OISD publications are prepared for use in the oil and gas industry under Ministry of Petroleum & Natural Gas. These are the property of Ministry of Petroleum & Natural Gas and should not be reproduced or copied or loaned or exhibited to others without a written consent from OISD.

Though every effort has been made to assure the accuracy and reliability of the data contained in these documents, OISD hereby expressly disclaims any liability or responsibility for loss or damage resulting from their use.

These documents are intended to supplement rather than replace the prevailing statutory requirements.

2 FOREWORD

The oil industry in India is over 100 years old. As such, various practices have been in vogue because of collaboration/association with different foreign companies and governments. Standardisation in design philosophies and operating and maintenance practices at a national level was hardly in existence. This, coupled with feed back from some serious accidents that occurred in the recent past in India and abroad, emphasised the need for the industry to review the existing state of art in designing, operating and maintaining oil and gas installations.

With this in view, the Ministry of Petroleum and Natural Gas in 1986 constituted a Safety Council assisted by the Oil Industry Safety Directorate (OISD), staffed from within the industry, formulating and implementing a series of self regulatory measures aimed at removing obsolescence, standardising and upgrading the existing standards to ensure safer operations. Accordingly, OISD constituted a number of functional committees comprising of experts nominated from the industry to draw up standards and guidelines on various subjects.

OISD have brought out a number of documents on various topics like layouts of installations, design, engineering, maintenance and operations of various facilities / equipment etc.

In an economic environment of rising cost of various inputs to the industry, in the form of man, material , machine and increasing cost of health care, it is vital for an organisation to effectively manage occupational safety and health. Benefit may be derived from such management in the form of increased productivity and morale. These benefits are a direct consequence of the reduction in workplace accident, injuries and illness. If workmen are to remain productive, they must be protected from injuries and illness.

There is an obvious effort to protect our facilities including personnel and managing the issue of safety and health in totality. The present document outlines the areas, in the form of elements, which need to be given due attention with a view to enhance productivity, morale of personnel and image of the organisation.

This document will be reviewed periodically for improvements based on the experience and better understanding.

Suggestions from industry members may be addressed to :

The Coordinator, Committee on " Safety Management System", Oil Industry Safety Directorate, II Floor, Kailash, 26, Kasturba Gandhi Marg New Delhi - 110 001

3 COMMITTEE

ON

SAFETY MANAGEMENT SYSTEM

------NAME ORGANISATION ------

Leader

A.A.Raichur Hindustan Petroleum Corpn. Ltd. ( R), Mumbai

Members

C.S.Chakrabarti Bharat Petroleum Corpon. Ltd. (R), Mumbai T.S.Lamba Oil & Natural Gas Corpon. Ltd, Kolkata N.Rengaswamy Engineers India Ltd. , New Delhi S.Thangavelu Chennai Petroleum Corpn. Ltd., Chennai R.C.Pandey, Bongaigaon Refinery & Petrochemicals Ltd., Bongaigaon N.Dasgupta Bharat Petroleum Corpon. Ltd. (M), Mumbai T.K.Kumar Indian Oil Corpon. Ltd. (PL), New Delhi S.S.Maji Indian Oil Corpon. Ltd. (R), New Delhi Dr. D.Buragohain Gas Authority of India Ltd., New Delhi

Member Co-ordinator

Shri S.N.Mathur Oil Industry Safety Directorate, New Delhi ------

(In addition to the above, several other experts from industry contributed in the preparation, review and finalisation of this document).

4 SAFETY MANAGEMENT SYSTEM

INDEX

------S.No. Content Page No. ------1. Introduction 6 2. Scope 6 3. Definitions 6 4. Safety Management System 7 4.1 Safety Organisation 8 4.2 Employees Participation 9 4.3 Process Safety Information 10 4.4 Process Hazard Analysis 13 4.5 Operating Procedures 17 4.6 Training 18 4.7 Contractors 19 4.8 Pre-start up Safety Review 20 4.9 Mechanical Integrity 21 4.10 Work Permit 28 4.11 Management of Change 28 4.12 Incident Investigation and Analysis 29 4.13 Emergency Planning and Response 33 4.14 Compliance Audit 36 4.15 Occupational Health 37 4.16 Off-the-job Safety 38 4.17 Customers and Products 38 4.18 Road Transportation 43 4.19 Trade Secrets 48 5.0 References 49

------

5 SAFETY MANAGEMENT SYSTEM

1.0 Introduction An effective Safety Material Safety Data Sheet Management System is (MSDS):Data sheet required to prevent hazardous incorporating safety incidents and eliminate or information / properties of a mitigate their consequences. chemical / product and useful A number of catastrophic for handling the material incidents in hazardous process industry have drawn Incident : An unplanned attention to the safety of event (occurrence, condition processes. Employees have or action) which did or could been and continue to be have resulted in personal exposed in their workplace to injury or damage to the plant, the hazards of chemicals community or environment. which may be toxic, reactive, flammable or explosive. The Near-miss : An incident present document which does not result any emphasises the application of injury or damage to property management controls for but has the potential to result tackling the risks associated in injury and / or property with handling / working with or damage. near to hazardous substances in petroleum industry. Process : Any activity involving a highly hazardous chemical including any use , 2.0 Scope storage, manufacturing, This document provides handling, or on the site guidelines for development of movement of such chemicals , detailed procedures for Safety or combination of these Management System and activities. covers the petroleum industry as a whole. For the purpose of this definition, any group of vessels which are 3.0 Definitions interconnected or separate vessels which are located Competent Person : A such that a highly hazardous person duly designated / chemical could be involved in authorised by the potential release should be management to carryout a considered as single process. specified job

6 Catastrophic release : A equipment, material and major release involving one or environment. Objective of more dangerous substances developing such a system is that leads to serious danger to to standardise the procedures persons as well as which should continue to be environment both within and followed by one and all unless outside the workplace and a change in the system is duly results from uncontrolled authorised by a competent developments. person. Such a Safety Management System should Critical equipment : refers to comprise the following basic columns, vessels, machinery, elements : piping, interlocks, and controls determined by 1. Safety Organisation management to be vital for 2. Employees Participation preventing the occurrence of 3. Process Safety a catastrophic release. Information 4. Process Hazard Analysis Facility : Buildings, 5. Operating Procedures containers, piping and 6. Training equipment that could 7. Contractors reasonably be expected to 8. Pre-startup Safety Review participate in catastrophic 9. Mechanical Integrity release as a result of being 10.Work Permit physically interconnected or of 11.Management of Change their proximity and in which 12.Incident Investigation and hazardous substances are Analysis used, stored , manufactured , 13.Emergency Planning and handled or moved. Response 14.Compliance Audit Process Hazard Analysis : 15.Occupational Health Process Hazard Analysis 16.Off-the job Safety (PHA), sometimes called 17.Customers and Products process hazard evaluation, is 18.Road Transportation an organised and systematic 19.Trade Secrets effort to identify and analyse the significance of potential Each of the these elements hazards associated with the should be taken care of as processing or handling of given below: highly hazardous chemicals.

4.0 Safety Management System 4.1 Safety Organisation System for managing safety intend to cover all aspects of 4.1.1 Safety Policy plant and facilities like to Every organisation should control loss to personnel, have safety policy duly

7 approved by the Board of 4.1.3 Enforcement of Safety Directors of the organisation. In the organisation, Safety It should contain intentions should be ensured through and commitment from the top repeatedly highlighting it's management. It should be utility in preventing loss of life made available to all and property and providing employees in a language training / retraining to easily understood. employees in safe working. Following modes should be It should be displayed at followed for enforcing safety : various locations in the organisation. a) Work Permit System b) Job safety analysis Organisational set-up for c) Training of employees implementation and and contractors monitoring of safety policy d) Surprise checks should be in place. Safety e) Drills target and objectives for each f) Operating manuals / position in the organisation Safety manual should be set and pursued. It g) Periodic MIS reports for should be revised as and monitoring by top when required. management

4.1.2 Safety Committees 4.1.4 Monitoring of Systems Safety Committees should be Following systems should be formed in the organisation. monitored regularly for The Committees should effective implementation : encourage employees participation. a) Checking of safety interlocks It should meet at least once b) Internal audits of plants in a quarter and minutes of /facilities in line with the meetings should be OISD-STD-145 recorded. c) Management of change d) Testing / Inspection of Deliberations of safety equipment reports, audits, incident e) Checking of fire detection enquiries should be a part of and protection system agenda of safety meetings.

For implementation of safety 4.1.5 Safety Promotion committee recommendations, Visuals play an important role time bound programme in reminding personnel of should be enforced. safety information. Therefore, display of following

8 information should be done in safety & health hazard the premises: associated with products & work environment. (a) Safety precautions for critical operations at 4. Employees should be strategic locations trained on use of personal (b) Safety posters and protective equipment slogans (PPE). (c) Safety records (d) Do's and Don'ts at toxic 5. Means & methods should chemicals be established to keep handling/storage/operation employees informed about areas relevant safety & health (e) Wearing helmet and other issues. Personal Protective Equipment (PPEs) 6. Safety & health committee (f) Labeling of chemicals at floor level should be (g) Material Safety Data Sheet formed with participation of (MSDS) employees & employer's (h) Safety manuals, Rules and representatives to review Regulations safety & health related (i) Safety News Letters & issues of the plant. The bulletins committee should meet (j) Dissipation of incident periodically to discuss the information relevant issues & suggest and implement remedial measures. 4.2 Employees Participation Following activities should be 7. Written information about undertaken to involve process, chemicals employees in the working of including MSDS and the plants / facilities : equipment should be accessible to employees. 1. Company should develop a written action plan to 8. Critical procedures & implement the employees' instructions should be participation. prepared in English and in a local language, 2. Employees should be understood by employees. involved in Internal Safety Audits and Job Safety 9. Employees should be Analysis. involved in management of change related to process 3. Employees should be & equipment. explained about operation of the plant, including

9 10.Safety quiz / suggestion verification of drawings to schemes / competitions ensure consistency with the etc. should be conducted actual process equipment and to enhance participation of arrangement may be made. employees. Information should be so located that it can be easily 4.3 Process Safety Information available at the time of need. Process safety is defined as Computerisation of the the operation of facilities that information is desirable. It handle, use, process or store facilitates easy up-dation and hazardous materials in a retrieval. It may be put on manner free from episodic or local network for easy catastrophic incidents. accessibility by all concerned. Knowledge of chemicals, process and plants is one of A master-index indicating the the prime asset. This location of information and the knowledge is required for medium in which it is developing other modules of available should be prepared. the management system like process hazard analysis, operating procedures, 4.3.2 Process Chemicals training, emergency Process chemicals should preparedness plans etc. include all raw materials, intermediates / finished products and chemicals 4.3.1 Process Information used in the process. Data Complete and accurate pertaining to process written information should be chemicals should help in compiled for the following assessing fire and explosion three categories: characteristics, reactive hazards, safety and health 1) Process chemicals hazards to workers and the 2) Process technology corrosion and erosion effects 3) Process equipment on the process equipment. Complete inventory of the This information should process chemicals should be represent current operation. prepared. For each process All data sheets, drawings, chemical, following specifications and other information should be documents should be available wherever applicable: updated / revised based on the present condition of the (A) Physical properties: process. Care should be Physical state, calorific taken for incorporation of all value, heat of modifications. Field vapourisation, Boiling

10 point, Vapour pressure, protective equipment Melting / Freezing point, (PPE), emergency Vapour density & treatment for exposure specific gravity and release / spill containment. (B) Fire & explosion Hazards: Flash point, Auto-ignition Note: Temperature, Explosive Material Safety Data Sheet limits, Burning rate (MSDS) : OISD-STD-114 on 'Hazardous Chemicals and (C) Reactive Hazards : Their Handling' may be The tendency of the referred. material to react violently when subjected to heat or the presence of other 4.3.3 Process Technology process chemicals, water, air (oxygen) or Process technology other possible information should include contaminants. the following:

Hazardous a) Written process combustion/decompositi descriptions on products. b) Process chemistry (D) Health Hazard Data: c) Process Flow Personnel exposure Diagrams (PFD) hazard properties (long term & short term) d) Safe operating limits of process parameters Information of toxicity of like pressure, the material and temperature, flow rate exposure limit values etc. and the such as Threshold Limit consequences or Value (TLV), Short Term results of deviation that Exposure Limit (STEL), could occur if operating Permissible Exposure beyond the established Limit (PEL), Lethal Dose process limits 50 (LD 50) etc. e) Maximum inventory (E) Corrosive properties of levels for process the chemical, runaway chemicals reaction and over- pressure hazards f) Material and energy (F) Information on fire fighting balances media, use of personal

11 A block flow diagram (BFD) showing major process equipment and pipelines is a 4.3.4 Process Equipment preliminary tool for Process equipment include understanding about the columns, vessels, heat process. Flow rates, exchangers, reactors, pumps pressures, temperatures and & compressors, valves, stream composition may be piping; drilling rigs & work- indicated for better clarity. over rigs; cross country pipelines; tanks, loading & un- Process flow diagrams (PFD) loading facilities and other are more elaborate than equipment that contain block flow diagrams. PFD process chemicals. Design should indicate all main data of process equipment streams including critical should be documented and valves. Major process should include the following: parameters like flow rate, temperature and pressure a) Materials of should be indicated at the construction ins and outs of major process equipment and at the control b) Design specifications points. Whenever necessary, pump capacities, compressor c) Codes, standards and power and other such relevant industry accepted information may be engineering practices mentioned. Major control used for design and loops and key utilities may be fabrication preferably shown in the PFDs. d) Electrical classification Piping and instrument diagrams (P&ID) are the 4.3.5 Design basis for the pressure detailed representation of the relief system and plant. Each and every piece of arrangement of shut-down & equipment, pipelines, valves interlock system should be and instrument along with documented. their interconnection are shown and most appropriate 4.3.6 For the existing plants where to show relationship between the codes used for design are equipment and instrument. no longer in general use, Information mentioned under design and construction of PFD and all the components such equipment should be of the control loops are documented. It should be depicted to enhance clarity. ascertained that the P&IDs should be updated equipment is still suitable whenever any modification is for its intended use and carried out. testing/inspection carried out

12 for this purpose should be In performing the PHA for a documented. new process or facility , special consideration should 4.3.7 When process technology be given to previous requires departure from experience with the process applicable codes, it should be and design circumstances , documented that the such as shorter- than - normal equipment is suitable for the design periods or changes in intended use. the design team or the design itself after the project is under way. 4.4 Process Hazard Analysis The purpose of Process Hazard Analysis (PHA)) is to 4.4.1 Conducting Process Hazard minimise the likelihood of the Analysis ( PHA) occurrence and the Following considerations consequences of a dangerous should be taken into substance release by account for conducting PHA : identifying, evaluating and controlling the events that 1) A process hazard analysis could lead to the release. should be performed for all facilities and processes. A PHA provides information which assists in making 2) The process hazard decisions for improving safety analysis should be and reducing the appropriate to the consequences of unwanted or complexity of the process. unplanned releases of hazardous chemicals. 3) The priority order of conducting process hazard The PHA of existing facilities analysis should be should be performed in order determined and of priority in terms of hazards documented based on a of the process. A preliminary rationale which includes hazard analysis may be useful such considerations as in determining the coverage of extent of the process the process safety hazards, number of management standard. The potentially affected factors like quantities, employees , age of the susceptibility to failure, mode process, and operating of failure, proximity, severity, history of the process. process complexity, operating history etc. should be 4) A PHA is directed toward considered while establishing analysing potential priority. causes and consequences of fires, explosions,

13 releases of toxic or failure scenarios should be flammable chemicals and assessed using qualitative major spills of hazardous or quantitative techniques chemicals. judged to be appropriate.

5) The PHA focuses on c) Alternatives- Feasible equipment, changes to reduce the risk instrumentation, utilities, of occurrence and the human action ( routine and consequences of the non-routine), and external failure scenarios should be factors that might impact identified. the process. These considerations assist in determining the hazards 4.4.3 Methodology and and potential failure points Technique or failure modes in a The selection of PHA process. methodology or technique should be influenced by many 6) The process hazard factors including the amount analysis should also of existing knowledge about address to : the process, age of the a) Human factors process, operational b) A qualitative evaluation experience of the process, of a range of the changes, limitations and possible safety and assumptions health effects of failure of controls on The PHA should take an employees in the orderly , systematic approach. workplace. One or more of the following methodologies that are 4.4.2 Basic Steps appropriate to identify, Steps to be incorporated in determine and evaluate the PHA should include : hazards of the process being analysed should be used. a) Identification - Based on What if, checklist, Hazard the process safety and Operability Study information, expertise and ( HAZOP), Failure Mode and experience with similar Effects Analysis, Fault Tree facilities, failure scenarios Analysis, an appropriate that could result in equivalent methodology. catastrophic release should be identified. The application of PHA may involve the use of different b) Assessment - The methodologies for various likelihood and parts of the process. A consequences of the process involving a series of

14 unit operations of varying standards, codes, sizes, complexities, and ages specifications, and may use different regulations applicable to methodologies and team the process being studied. members for each operation. The conclusion can be c) The selected team integrated into one final study members need to be and evaluation. compatible.

When there is large d) The PHA team can vary in continuous process which has size from two people to several control rooms for number of people with different portions of the varied operational and process such as for distillation technical back ground. tower and blending operation , each segment can be done e) The team members should separately and then integrate be fully knowledgeable in the final results. the proper implementation of PHA methodology that is to be used and should 4.4.4 The Team be impartial to the The process hazard analysis evaluation. should be performed by a team with expertise in engineering and process 4.4.5 Frequency operations , and the team The process hazard analysis should include at least one should be updated and employee who has revalidated by a team, having experience and knowledge requisite back ground, at least specific to the process being every 5 years after the evaluated . Also, one member completion of initial process of the team must be hazard analysis. knowledgeable in the specific process hazard analysis The PHA for a new process or methodology being used. facility or modification in Following aspects should be existing facility and considered while constituting recommendations resulting such teams : from the PHA should be completed before start-up. a) The team conducting the PHA should understand the methodology being 4.4.6 Recommendations and used. Follow up Following approach should be b) The team should have adopted once intimate knowledge of the recommendations of Process

15 Hazard Analysis are made taken. Written down available: operating procedures should be available for all process 1. System to promptly plants for safe operation. address to the team's findings and 4.5.2 Operating procedures should recommendations should be based on process safety be established. information so that all known hazards are taken care of. 2. Recommendations should Operating parameters be resolved in a timely should be consistent with the manner and resolution process safety information. should be documented. 4.5.3 The operating procedures 3. Written schedule should should provide specific be drawn for completion of instructions on what steps to the recommendations and be taken or followed while should be monitored. carrying out the following:

4. The actions taken should (a) Startup - including be communicated to the procedure for initial operating, maintenance startup of the process or and other employees who equipment as well as may be affected by the startup after normal and recommendations or the emergency shut downs. actions. (b) Normal operation - 5. Process hazard analysis, including limits of the updates or revalidation for "normal" operating each process as well as ranges for parameters the documented such as pressure, resolutions of temperature and flow, recommendations should the consequences of be retained for the life of operating outside these the process. limits, and the actions that should be taken to correct or avoid deviation 4.5 Operating Procedures from the normal ranges.

4.5.1 Operating procedures (c) Temporary operation - describe tasks to be including special performed, data to be requirements while recorded, operating conditions operating in the to be maintained, samples to temporary mode and the be collected and safety & acceptable duration of health precautions to be the temporary operating mode.

16 IV. Fire protection/fighting (d) Normal shut-down - facilities including actions to be taken to safely shut 4.5.6 Manuals should be available down the process or to the employees. All equipment and operators must understand conditions to be avoided. thoroughly and should be fully conversant with the (e) Emergency operation operating manual. Training and shut-down - should be imparted to the including the conditions operators on operating under which an procedures and should be emergency shut-down is certified as competent. required. This should also include 4.5.7 Computerisied process assignment of authority control system has added a and responsibility to new dimension. Logic of the qualified operators to software and relationship ensure that shutdown is between the equipment and executed in a safe and the control system should be timely manner. described.

4.5.4 Operating instructions should 4.5.8 Operating manuals should be be specific to the plant / facility. updated as often as necessary. Every year, 4.5.5 Operating manuals should operating manuals must be contain hazards of exposure certified as updated by of the chemicals being competent person. handled. Preventive methods and control measures adopted for exposure 4.6 Training protection should be clearly Personnel in the plant / brought out. These facilities should be trained and information may be provided retrained for improving their in a separate volume of the understanding and up operating manual. MSDS grading skill in their area of provides majority of such work based on identification of information. Operation their training needs. manuals should also describe the following:

I. Purpose and function of 4.6.1 Initial Training safety interlocks Each employee, before being II. Equipment handing over involved in operating a newly procedure assigned process, should be III. Work permit system

17 trained in an over view of the e) Safety systems and process and in the their functions a) operating procedures f) Each employee should viz., initial startup, be given training on normal operations, operating procedures & temporary operations, safe work practices, emergency shutdowns emergency including the conditions preparedness or under which disaster management emergency shutdown plan, safety is required, emergency procedures, work operations, normal permit system and shutdown and startup areas pertinent to following a turnaround process safety & or after an emergency health. shutdown. g) Each employee should b) Operating limits viz. be explained action to consequences of be taken in the event deviation and steps of unwanted release required to correct or of hazardous avoid deviation. chemicals. c) Safety and health considerations viz. The training should also properties of, and include/reflect hazards presented by, the chemicals used in I. current operating the process, practice, changes that precautions necessary result from changes in to prevent exposure, process chemicals, including engineering / equipment and administrative controls facilities; and PPEs. II. on safe work practices d) control measures to be to provide for the taken if control of hazards exposed(physical, air during operations such borne), Quality control as lockout / tagout, for raw materials and confined space entry, control of hazardous opening process chemical inventory equipment and piping levels and and maintenance. special/unique hazards

18 4.6.2 Refresher Training 1) Management should Refresher training should be ensure that contractor provided at-least every three personnel are trained in years and more often, if the work practices necessary to each employee necessary to perform their involved in operating a job safely. process to assure that the employee understands and 2) Contractor should provide adheres to the current & maintain work places, operating procedures of the plant, equipment, tools, process. machinery and so organise construction work that as far as 4.6.3 Training Documentation reasonably practicable, Record should be prepared there is no risk of accident containing the identity of the or injury to workers. employee, the date of training and the means used to verify 3) Contract personnel are to that the employee understood be informed about the the training. known potential fire, explosion or toxic release Refer OISD-STD-154 for hazards related to their further information. job & the process and in the applicable provisions of the emergency 4.7 Contractors preparedness plan. In petroleum industry where contractors are deployed to 4) Contractor must ensure accomplish various types of that each of their jobs of different nature, it is personnel has received very much essential to and understood their formulate an elaborate system roles in safe working for ensuring their safety at practices by preparing a work place. Suitable space for record and should verify contractors camp, if required, the efficacy of inside factory area for any dissemination of the safety construction activities to be information. He should made available at a safe also ensure use of PPEs distance from hazardous at work place. area. The camp should be dismantled on completion of 5) Contractor should ensure the job. To meet the that each of their requirement, following personnel follows the measures should be safety rules of the owner's incorporated in the system : facility including safe work practices.

19 reviewed , items needing 6) Contractor should keep attention from PHA's have owner informed about any been resolved and personnel unique hazard presented have been trained. The main by their personnel's work. purpose of the review is to reduce chance of some item 7) Management should being overlooked that could ensure for regular safety create a hazard or introduce inspection of its own as un-expected safety problem well as contractors' as process is brought to construction equipment / normal operating conditions. tools & tackles by competent person The management should perform a pre startup safety 8) Contractor should assign audit for new facilities, for workers only that job for modified facilities when the which they are suited by modification is significant their age, physique, state enough to require a change in of health and skill. the process safety information as well as for startup of 9) Contractor should be existing facility / plant after made responsible for turn around. application & enforcement of safety & health Pre startup safety review measures in respect of should confirm that the workers at site and construction is in accordance should maintain constant with design specifications, liaison with management. Safety, operating, maintenance and emergency 10)Management, while procedures are in place and selecting a contractor, are adequate. should obtain information regarding their safety For new facilities, process performance. hazard analysis is performed and recommendations have been resolved or 4.8 Pre-startup Safety Review implemented before start up One of the most critical and modified facilities meet period in an operation is the the requirements contained in start up of the process. Before management of change a new or modified unit is started, a systematic check should be made to ensure 4.9 Mechanical Integrity that the equipment has been Mechanical integrity of the installed properly, operating plant or the facility need to be procedures have been ensured so as to perform

20 intended activities without the chances of its failure. (a) Annual plan Following aspects should be (b) Tasks and taken into considerations: responsibilities (c) Manpower (number 1. Applicable requirements and type) of the codes of practices (d) Contractors, if any should be met or (e) Equipment control and exceeded & mechanical calibration integrity should be (f) Control of spare parts maintained by use of (g) System of work clearly defined permits, records maintenance, inspection (h) Recording of conditions and corrosion control of parts during use and procedures. replacement (i) Incident reporting 2. Equipment used to process, store or handle 6. The procedures, methods hazardous materials and techniques should be should be designed, so selected as to eliminate constructed, installed and risk in carrying out maintained to minimise the maintenance activities. risk of releases of such materials. 4.9.1 Mechanical Integrity 3. The overall maintenance Program plan should be drawn Mechanical integrity program taking into consideration should be in place to assure the safety, reliability and continued integrity of process quality objectives. equipment. The appropriate working procedures, methods 4. Feedback from and techniques should used, maintenance activities which are considered most fit should be given to other for the purpose and in line elements of safety with the codes of practices. systems i.e. design & operations for up-dation of Elements of mechanical P&IDs and operating integrity program should manuals as required. include:

5. Safety aspects with regard (a) Identification and to organising categorisation of maintenance activities equipment and should be focused in the instrumentation, inspection maintenance plan and and tests, training of prioritised as below : inspection personnel,

21 testing and inspection frequencies, development Information should be of maintenance documented covering procedures, the following: establishment of criteria 1. The list of process for acceptable test results, equipment and documentation of test and instrumentation should be maintenance results, and compiled and categorised documentation of to be included in the manufacturer mechanical integrity recommendations as to program. The list should meantime to failure for include pressure vessels, equipment and storage tanks, process instrumentation. piping, relief and vent systems, fire protection (b) The information pertaining system components, to process equipment emergency shut down design should be systems, and alarms and documented as to what interlocks and pumps. were the codes and standards relied on to 2. The list of equipment establish good engineering should be prioritised to practice. determine which piece of equipment requires closer (c) Documented system scrutiny than others. should be in place to confirm that equipment 3. Information pertaining to complies with recognised the equipment in the and generally accepted process should include good engineering material of construction, practices. piping and instrumentation diagram, electrical (d) For existing equipment classification, relief system designed and constructed design and design basis, in accordance with codes, ventilation system design, standards or practices that design codes and are no longer in general standards employed. use, it should be determined and documented that the equipment is designed, maintained, inspected, tested and operating in a 4.9.3 Inspection and Testing safe manner. This should consider the following : 4.9.2 Equipment Data

22 1. Inspection and testing should be done on all 7. The relevant OISD process equipment. standard and guidelines should be used for 2. Inspection and test developing inspection and procedures should follow maintenance systems. recognised and generally accepted good 8. Frequency of testing / engineering practices. inspection should be based on following 3. Each inspection and test considerations : done on equipment and its components should be a) Meantime between documented. failure of various instrumentation and 4. The applicable national / equipment parts would inter-national codes and be known from standards provide criteria manufacturer's data or for external and internal operating experience inspections including with the parts which frequency and will influence the methodology which inspection and testing should be adhered to. frequency and associated 5. Procedures should be procedures. developed and be in place to ensure that tests and b) Failure data from inspections are conducted operating experience properly and that should be documented consistency is maintained and analysed. even where different employees are involved. c) The frequency and methodology of test of 6. Internal inspections should process equipment cover items such as vessel should be consistent shells, bottom and head, with applicable metallic linings, thickness manufacturer's measurement for vessels recommendations, and piping, inspection for national/international erosion, corrosion, codes,OISD standards cracking and bulge, / recommended internal equipment like practices / guidelines, trays , baffles, sensors and good engineering screens for erosion , practices. Such corrosion, or cracking and inspections/testing other deficiencies. should be done more

23 frequently if 1. The maintenance determined to be procedure should address necessary by prior to the safety aspects with operating experiences. regard to organisation of maintenance (system of work permit and non- 4.9.4 Non-routine Work routine work), determining Authorisation whether execution should be on line/off- line, Following issues should be regulations to be followed, considered : harmonising with 1. All non-routine jobs should operation, incident be carried out in line with reporting system, OISD-STD -105. maintenance analysis, do it one self or contract out. 2. List of non-routine jobs should be prepared and 2. Use of personal protective procedures defined to equipment should be laid carry out them. down for specific maintenance activities. 3. Roles and responsibilities for work authorisation, 3. The task, role and issue/receipt of permit, responsibilities should be handing over, taking over defined should be documented and implemented. 4. Records of trend analysis of machine and 4. In case of any change in equipment should be procedures and practices taken into consideration. system of proper authorisation should be 5. The risks associated with instituted. different phases of maintenance should be established. 4.9.5 Maintenance Procedures The maintenance programs 6. All maintenance and schedules should be procedures should be duly reviewed and analysed to see authorised. if there are areas where break down maintenance is used 7. Maintenance manual rather than an ongoing should be formulated, mechanical integrity program regularly certified, updated consisting predominantly of and approved. preventive & predictive maintenance.

24 4.9.6 Inspection and Test Results 2. Criteria for acceptable test results should be well Inspection programme should defined taking into cover the following : consideration codes of a) Each inspection and test practices, manufacturer's performed on the process recommendation, equipment should be anticipated life and documented. operating experience.

b) The list of process 3. Any deviation accepted equipment, components, should be approved by instruments should be competent person. made for inclusion in the mechanical 4. Equipment deficiencies integrity/maintenance which are outside program. acceptable limits as defined by the process c) The documentation safety information should should identify the date of be corrected before further inspection or test , the use or in safe and timely name of the person who manner when necessary performed the inspection means are taken to assure and test , the serial safe operation. number or other identifier of the equipment on which 5. Proper records for handing the inspection and test / taking over of equipment was performed , a to be maintained. description of the inspection or test 4.9.8 Documentation of performed and the results Manufacturer's of the inspection or test. Recommendations Documentation should cover : 4.9.7 Criteria for Accepting 1. Manufacturer's Equipment after recommendations for Maintenance periodic inspection / Following considerations testing / maintenance of should be taken into account equipment supplied by while accepting equipment them should be after maintenance : documented 1. Equipment that has been out of service for 2. In case of any deviation maintenance should be from the inspection taken over after due procedure as testing and recommended by documentation. manufacturers reason for

25 the same should be of defence which is the documented. controlled release of materials through venting to scrubbers or flares, or to 4.9.9 Training of Maintenance surge or overflow tanks Personnel which are designed to prevent unwanted Training aspects should releases. consider : 1. Appropriate training is to 3. The above two are the be provided to primary line of defence or maintenance personnel to means to prevent ensure that they unwanted releases. The understand the preventive secondary line of defence maintenance program would include fixed fire procedures, safe protection system like practices, and the proper sprinklers, water spray or use and application of deluge systems, monitors special equipment or etc. Dykes, designed unique tools that may be drainage systems and required. other systems will control or mitigate hazardous 2. Maintenance training chemicals once an should be integrated with unwanted release occurs. overall training program and records should be 4. The primary and documented secondary lines of defence should be protected by 3. The frequency and mechanical integrity contents should be in line program and strengthened with OISD -STD-154. where ever necessary.

4.9.10 Line of Defence 4.9.11 Quality Assurance

Following aspects should be The quality assurance considered for safety of plant : program is an essential part of 1. The first line of defence is mechanical integrity program to operate and maintain and will help to maintain the the plant and the process primary and secondary line of as designed and to keep defence that have been the hazardous materials designed into the process to contained. prevent / control / mitigate unwanted chemical release. 2. This line of defence is This require following : backed up by the next line

26 1. In the construction of new assure that qualified plants and equipment, it craftsmen are used to do should be ensured that the job. equipment as it is fabricated is suitable for 7. Use of appropriate the process application for gaskets, packing, bolts, which they will be used. valves, lubricants and welding rods should be 2. Appropriate checks and verified in the field and inspections should be documented. performed to ensure that the equipment is installed 8. The procedures for properly and consistent installation of safety with design specifications devices should be verified and the manufacturer's such as torque on the recommendations. bolts on rupture disc installations, uniform 3. The quality assurance torque on flange bolts, system is needed to help proper installation of pump that the proper materials of seals etc. construction are used, that fabrication and inspection 9. If the quality of the parts is procedure are proper , and a problem, it may be that installation procedures appropriate to conduct recognise field installation audits of the equipment concerns. supplier's facilities to better assure purchase of 4. The maintenance required equipment which materials, spare parts and is suitable for intended components should be use. suitable for the equipment for which they will be used. 10.Any change in equipment that may become 5. 'As built' drawings, necessary will need to go together with certifications through the management of coded vessels and other of change procedures. equipment and materials of construction need to be 11.Calibration / verified and retained in the standardisation of all quality assurance equipment required for documentation. fabrication. 6. Equipment installation jobs 4.10Work Permit should be properly In case work is required to be inspected in the field for performed in the plant / facility use of proper materials, by any person other than the and procedures and to operating personnel of that

27 area, a duly authorised written improve utilisation and permit should be obtained by optimisation of facilities, the person / agency executing reduce downtime, reduce risk the work before to public, enhance knowledge commencement of the work. of plants and process activities. Based on the nature, the work would be undertaken The procedure for under different types of management of change permits. For example, should cover review of the following jobs should be specification of piping and undertaken with the duly equipment, process issued hot work permit : engineering, instrumentation, maintenance, relief, safety, Cutting, Welding, Excavation, health, environment etc. After Road/Dyke cutting, Electrical implementation of the lock out / Energising, changes, the training of Confined space entry, Boxing personnel in accordance with up of a vessel, Working on the changed process, fragile roof structures, updation of document, Radiography, Material equipment history cards, data Handling in operational areas, sheets etc. to be taken care of Crane operation etc. before commissioning of plant / facilities. Refer OISD-STD-105 on Work Permit System for The modifications may require details. changes in process / technologies, hardware, addition, alteration or removal 4.11Management of Change of an equipment or a part of it Management of Change from the plant, in piping refers to implementing any system and process change intended to bring in equipment, replacement of any of the inputs to the plant / equipment or machinery that facility. differs from the original equipment, change in Primarily, plants are modified metallurgy, change in or changed in order to instrument which may include achieve higher efficiency, pressure, temperatures, flow, improve operability and set points, alarm points, safety, reliability, to speed, logic and control accommodate technical parameters. changes etc. Another objective of carrying out such The procedure should be modifications / changes may established and documented be to prevent mishaps, for implementing a change

28 covering all the stages like meet planned objectives and commissioning, operation, acceptable standards. inspection, maintenance, review of performance of the A nearmiss incident is a little plant / facility. better situation in that it is a warning given before actual Refer OISD-GDN-178 injury. It gives an opportunity "Guidelines for Management for concurrent control which of Change" for details. This has the advantage of should be followed by all permitting corrective action plants and facilities. before an injury, illness, death or property loss.

4.12Incident Investigation and Therefore, every incident and Analysis nearmiss incident must be For the management, an recorded and thoroughly incident investigation is a investigated. critical feedback about the system of control of a hazard. 4.12.1 When to investigate Feedback control involves Incident investigation should gathering information about be initiated as promptly as an occurrence or completed possible but not later than 24 activity, evaluating that hours following the incident. information and taking steps to improve the situation in the 4.12.2 The Objectives of the future. This form of control is Incident Investigation valuable as it helps prevent The basic purpose of an recurrence of the incident. incident investigation is to determine the cause of the An incident is a failure in the incident and to formulate a control of any hazard that system to prevent results in un-planned event reoccurrence of such like fire, explosion, run away incidents. reaction release of toxic or flammable material, injury or fatality. A workplace incident 4.12.3 Who Should Investigate is an indication that The immediate and first level prevention was ineffective and investigation should be that prompt changes need to performed by the immediate be made. supervisor of the effected Feedback control gives area. The immediate management the capability to supervisor is closest to the use information on past scene, knows the nature of performance to improve upon the work, the employees who future performance and to do the work, and the nature of

29 the hazards associated with management. When the the work. nature of the accident is complex and the causative 4.12.4 What should an factors are elusive, an outside Investigation Report expert can be engaged to Contain provide additional knowledge. A detailed investigation report, For accidents involving prepared at the conclusion of hazardous chemicals or the investigation, should exposure to toxic substances, include at a minimum the date the services of an industrial of incident, date that the hygienist may prove valuable. investigation began, a description of the incident , the factors that contributed to 4.12.7 Investigation by the the incident and Committee recommendations resulting In case of major incident, from the investigation. Refer management should establish OISD-STD-107 format for multi-disciplinary team to further details. enquire into the incident. Such safety Committee for an 4.12.5 Review of the Initial accident investigation has the Investigation advantages of bringing in a The results of the good mix of knowledge / investigation should be viewpoints as also injects a presented to and reviewed new dose of objectivity into with the next higher level the investigation. supervisor. In case of catastrophe or 4.12.6 The Role of the Safety disaster where the losses are Professional very large and the A Safety professional should consequences are severe, a also be called in to review the senior level of inquiry or investigation. An independent investigation may be instituted review and a second opinion and assigned with completing in such situations will help. an independent investigation.

If necessary, a second investigation should be 4.12.8 Salient Parameters for performed. The safety Incident Investigation professional can conduct a The incident investigator's job joint investigation with the is to gather all available primary investigation. information to essentially explain how the accident The primary safety happened and how the responsibility still rests with occurrence may be the immediate line prevented.

30 did management fail to The investigation should be recognize and evaluate? open to input from all persons who were directly or (3) "Where" Questions indirectly involved in the Where did the incident accident. The primary thrust happen? Where was the of the investigation should immediate supervisor / not be to cast blame but operating personnel at the should be to prevent it's time of the accident? reoccurrence (4) "When" Questions The six key questions that When did the incident should be asked and happen? When did answered are who, what, controls fail to protect? where, when, how, and why This question should not as below : be answered by a simple hour, day, and month (1) "Who" Questions answer. The time of Who was injured? Who occurrence in witnessed the accident? relationship to the Who was involved in process cycle and responding to the equipment timing must accident? Who contributed be determined. So is the to causing the accident, if time in relationship to the any? Who has immediate work activities of other responsibility for safety workers in vicinity / and health of the work related functions. area? (5) "How" Questions (2) "What" Questions How did the incident What occurred (the happen? How did all the complete sequence of physical conditions and events should be human behavior come determined). What together and combine to equipment, process, or cause the accident? How facility was involved? What well did the safety chemicals or energy was controls (all types from involved? What Safety engineering to controls failed to protect? administrative) work or What did the injured fail? How was personal worker do or not do? protective equipment What did others do or not used or not used? do? What did management do or not (6) "Why" Questions do? What Safety factors Why did the incident occur? Why the controls

31 fail to protect? Why did may be pursued except with the workers not recognize greater accuracy. The basic the hazard. Why did the idea is to fine-tune the inquiry worker fail to evaluate the until the sharpest picture of hazard. Why was the accident has been management unable to obtained. prevent the incident from taking place? 4.12.11 Findings Should be Put into a Written Report Some of the above A major accident or exposure questions overlap, but the will generate a significant investigation must be amount of investigative work. thorough. Regardless of The effectiveness of the the investigation is being investigation is enhanced by a done by the first line well written report. A written supervisor or by a report is a permanent record Committee , the above of the results of the questions should be investigation. raised and the best answers found. The 4.12.12 Communicating the accident can then be Report properly analyzed after One of the basic purposes of getting the above the written report is to questions answered. communicate the findings of the investigation within and outside the organization. 4.12.9 Analysis of the Incident Thus, careful thought must be After all the facts and data expended to determine to have been gathered, the whom the written report information must be should be released. Additional analyzed . The function of thought must be given to the analysis is to organize the legal ramifications of such information and mentally records and documents. synthesize the raw information into useful ones to 4.12.13 Legal Ramifications of the arrive at conclusion. Accident Report Every written report, document, and physical 4.12.10 Follow-up Questions record have legal If necessary, after the initial ramifications as they have facts have been collected and legal significance. The most digested, a set of follow-up obvious is that they constitute questions may be raised. Like evidence which may be used a computer routine, the same during a trial to prove or Who, What, Where, When, disprove a fact that is under How, and Why questions dispute. For this reason alone,

32 a report should be prepared monitoring performance with the realization that it can, changes, building up a data one day, be used as evidence base on plant history and or proof in a legal proceeding. trend analysis .

Incident investigation reports 4.12.14 Post Investigation Actions to be retained for minimum A system should be period of five years in order to established to promptly determine if an incident address and resolve the pattern develops or exists. report findings and implement recommendations. Resolution and corrective actions should 4.13Emergency Planning and be documented. Response The basis for the Emergency The report should be Preparedness Plan should be reviewed with all affected derived from the hazard personnel whose job tasks analysis and the are relevant to the incident consequences of identified findings including contract Maximum Credible Accident employees when applicable. scenario. The objective of the emergency plan is to provide Findings should be accessible a measures to contain and to all departments and minimise the effects of such personnel concerned. incidents. Communication methods may be safety bulletins, newsletter, 4.13.1 On-site Emergency Plan meetings, revision of should contain the following procedures etc. It is important key elements : to prepare information in suitable form for the intended a) Early warning/alarm recipient. system Providing an early There should be a system of warning system is maintaining an incident data recommended as a base wherein information is standard procedure as it properly recorded in a form has an advantage of suitable for easy use. initiating basic action to control over the Trend analysis of causes of emergency situation. The incidents is vital and help in warning system can be setting priorities to reduce risk via telephone, fire sirens potential. Information etc. Alarm system should gathered on various incidents have distinctive signal for provides immediate lessons. fire & other In long term, it useful in emergencies.

33 safe location and b) Immediate response marked on the site plan. Procedures / Measures The personnel manning It is essential to list down the control rooms and immediate action in case their duties should be of an emergency and identified in the plan. The nominate people / control room will be positions to perform the activated in case of an initial task. The people emergency to direct and and positions coordinate the nominated for such task operations to handle the must be available round- emergency. It should be thc-dock at the site. This furnished with external goes long a way in and internal telephone mobilising further connections, PA / Paging resources in controlling / VHF etc.; list of the emergency. essential telephone numbers; list of key c) Manpower / personnel and their Organogram and their address; fire fighting responsibilities system and site plan. The organogram should Depending upon site be drawn by appointing requirements, additional key personnel and control room can be defining their specific considered. duties, which will be handy in case of an e) Resource Mobilisation emergency. The number Plan (internal / of coordinators at a external) location would depend The emergency plan on the manpower in must contain resource location. The roles mobilisation scheme so identified for the that key personnel will positions should be be able to activate the consistent with the scheme to mobilise the normal day-to-day internal & external responsibilities of the resources within shortest personnel. time available. Such plan must contain d) Emergency Control identified resources Room needed and its The emergency control availability, location and room location should be activation methods. identified in the plan. The emergency control room f) Mutual Aid should be set up at a

34 It is one of the major would take charge of this resources for fire fighting point and plan for and emergency handling. necessary evacuation. Mutual aid arrangements are to be worked out in h) List of Attachments, the plan to facilitate Sketches additional help in the event of fire fighting or in i) Layout showing various rescue operation by way facilities, fire fighting of rendering manpower, system, hazardous medical aid or fire zones and fighting equipment etc. accompanying assembly point(s) and g) Evacuation control room. procedures / Assembly Points ii) Address and telephone In a major emergency, if numbers of Emergency it is essential to evacuate coordinators and key the non essential persons in the location; personnel from affected Mutual aid members; area it is advisable to Fire Brigade; Police have a plan for and Hospitals; Higher evacuation. There officials at region / should be pre- zone / HO; designated areas where Government officials the personnel like like District Collector, workers, staff, Inspector of Factories, contractor workers etc. Commissioner of not involved in Police; Local controller emergency operations of Explosives. (as per Emergency Preparedness Plan) iii) List of fire fighting & should assemble in case safely equipment of an emergency. available at location. Depending on the location of the iv) List of Do's and Don'ts emergency, the during emergency assembly point can vary. For each potential v) Formats for reporting to hazardous zone, a Govt. Authorities, Local specific assembly Agencies, Police and point(s) should be Hospitals. identified and marked on the zones/maps. During vi) Material Safety Data emergency, Pre- Sheet (MSDS) for designated persons each hazardous

35 product handled in safety system is implemented the location. and how they are being accomplished. It is the feed 4.13.2 Information to public back mechanism that The safety measures to be provides management with taken in the event of an the status and measurement emergency should be made of effectiveness of the various known to the general public safety system elements and who are likely to be affected. activities and leads to the appropriate control over these 4.13.3 Training / Drills and efforts. Updating of the On-site plan Following three types of Mock drills activating the safety audits should be Emergency Preparedness carried out: Plan should be conducted 1. Internal Safety Audit periodically for ensuring its 2. External Safety Audit efficacy during emergency as 3. Safety Management well as for refinement and System Audit updation. The above drills based on the plan will help to achieve the following 4.14.1 Internal Safety Audit objectives :- Internal Safety Audit is important as it is carried out a) to familiarize emergency by the personnel who are response personnel with deeply involved in the their roles and duties to operation / maintenance of be performed. the facility, thus are aware of each and every aspect of it. b) to ensure the efficacy of Therefore, such audit can the emergency response best bring out any mechanism. shortcoming in the work area. Following methodology should c) to check the coordination be followed for such audits: of reactions and response of emergency a) Processing, storage, services. handling and transportation facilities d) to gain experience and should be audited once confidence, in a year.

4.14 Compliance Audit b) A calendar containing the Safety Audits are the periodic area, names of auditors examination of the functioning and period of audit should of safety system. It gives an be prepared for every idea about how effectively the calendar year in advance

36 and be circulated to all the recommendations of internal departments and and external safety audits, concerned area managers. risk analysis / HAZOP studies and enquiry c) Areas to be audited should committee be logically grouped based recommendations of fires and on functions. incidents. The audit team should give more d) Audits should be carried emphasis on system audit as out through a multi- safety survey is carried out by disciplinary team. the internal safety audit team. Environment and e) Detailed guidelines occupational health aspects including checklists as may also be included in ESA. given in OISD-GDN-145 Report of the audit team on 'Internal Safety should be submitted within a Audits' should be reasonable time frame. followed. Time bound action plan f) A time bound action plan should be prepared for should be prepared for implementation of the implementing audit recommendations and the recommendations. same should be closely monitored. g) Implementation status of the recommendations Board of Directors should be should be reviewed in the appraised about the Management Safety implementation status of the Committee Meetings. recommendations twice in a year. Whenever, any recommendation cannot be 4.14.2 External Safety Audit (ESA) implemented, specific External Safety Audits are approval should be obtained carried out by a team of from the Board of Directors. experts. The duration of the audit may be two to five days. Location management 4.14.3 Safety Management System should make a presentation Audit for the audit team giving brief Compliance of the Safety description of the process Management System, as per plants / other facilities and the this document, should be safety management systems. assessed by carrying out The audit team should study compliance audit once in 3 the different manuals, years. Companies should technical documents, develop their own implementation status of methodology for such audits.

37 Care should be taken to Refer OISD-GDN-166 select team member / "Guidelines for Occupational members who have adequate Health Monitoring in Oil and experience and training for Gas Industry" for details. auditing safety management system. Such audit report should be reviewed at an 4.16 Off-the job Safety appropriate level with a view Off-the-job safety is a worthy to update the procedures. goal in its own right. Analysis of the off-the-job injuries and 4.15 Occupational Health rates normally shows that The successful they are more costly than lost- implementation of time on-the-job injuries. management plans and Encouraging employees to be polices greatly depend on its safe away from the work help adaptability by the personnel to preserve skills that could be (employees) and maintaining temporarily or permanently their health is vital for lost. It has added advantage productivity and effectiveness. of keeping the absenteeism As such, their health should low. be strongly emphasised in the organisation's strategic plan. Further, being careful Promotion of health of everywhere creates good employees in the widest mindset. Individual's sense, should, therefore, be a concentration on the job is high priority, both a goal and a likely to be enhanced by ones challenge for the organisation. concentration off-the-job and the plant or office is a To meet the above objective, healthier and safer it is necessary to have a environment because of it. structured Occupational The benefits also are widely Health Monitoring so as to shared throughout the plant or have a scientific basis for decisions aimed at protection office communities. Following of human health from any measures should be adopted possible adverse to encourage off-the-job consequences of exposure to safety : the hazards in the occupational environment. (a) The company should have policy to Necessary engineering / encourage covering administrative controls should off-the-job safety of the be exercised to prevent employees. personnel from undue exposure to various hazards (b) The reporting and at the work place. analysis of the off-the- job injuries to employees and their

38 families should be encouraged. (a) The potential safety, health, environmental and (c) Findings of the analysis liability risks associated of the off-the-job with every product sold , injuries should be every service offered known to all the should be recognised and employees through dealt with. news letters / bulletins (b) The organisation policy (d) There should be topics and objectives should covering off-the-job focus on long term safety incorporated in commitment to the news letters / continuously improve magazines. performance in health, safety and environmental (e) Safety quiz, contests quality. and competitions should be organised for (c) Product and customer the family members of safety should be managed employees to motivate as an integral part of the them towards off-the- business and marketable job safety. feature of product and services. 4.17 Customers and Products Primary objective of the (d) Demonstration to the management should be to public , government and make available their customer customers of the the intended product without organisation's intention to causing any harm to human be socially responsible and the environment. supplier of products and services It can further be elaborated as below: (e) All statutory guidelines with regard to health, 4.17.1 Customer and Product safety and environmental Safety Goals aspects of products in their manufacture, processing, The product and customer storage, transportation and safety goals of the marketing should be organisation should be incorporated in the safety defined to ensure that every procedures and manuals product is manufactured, and updated as and when transported, used and there is a change. disposed off safely. It should cover the following :

39 (f) Intermediate custodians reported or experienced by including transporters, those handling these dealers and distributors products. should understand and accept the safety policy (iii) Existing products and commitment to New uses or markets for product and service safety existing products should of the organisation. be evaluated to ensure that health, safety and (g) Roles and responsibilities environmental hazards should be defined with and risks are identified and appropriate procedure. addressed.

(iv)Records and 4.17.2 Products Safety documentation Procedures Records of assessment , background information Risk associated with the and conclusions should be product should be kept up to date through out analysed, defined, the product's life and controlled and instructional retained as appropriate. material should be developed for the same. It should cover the (v) Product Information/ following : Material Safety Data Sheets Up-to-date information on (i) New products health, safety and Assessment should be environmental hazards made for new products and risks relating to use , prior to marketing and storage , handling, distribution to identify transport and disposal of health , safety and products should be environmental hazards available to the workforce , with normal use and customers and community. foreseeable misuse. The database on products should cover following (ii) Periodic reassessment of aspects: products Synonyms of chemical Periodic reassessment names, target organs of should be conducted for all chemicals, first aid manufactured, rebranded requirements for skin, first products and intermediate aid requirements for eye, streams. This includes a first aid requirements for review of adverse effects swallowing, first aid

40 requirements for and environment and to breathing, symptoms of take corrective measures exposure, protective by defining compliance clothing requirements, programs and commitment washing instructions, to these programs. The clothing change quality standards and requirements, clothing system should be removable requirements, documented and updated. protective eye gear requirements. OISD-STD- 155 on Personal 4.17.3 Customer Service , Protective Equipment Education & Awareness should be referred to. The following system (vi) .Reporting adverse effects should be in place: of product (a) Receiving and System should be documenting customer developed and in place complaint with regard to to collect and review safety, health and adverse effects reported environmental aspects of or experienced by those the products and handling the products. services: Causes for concern All customer complaint should be identified and should be reviewed at actions should be taken. appropriate level and action taken for (vii)Product quality manufacturing, certification: distribution and Products should be inspection process to properly classified, prevent its recurrence. described, packaged, marked and labelled and (b) Formal system for should be in proper responding to the condition for complaint to the transportation in satisfaction of the accordance with the customer: applicable regulations. An effective recall system should be in (viii)Environmental and place for products and Quality standards / services where defects systems: could give rise to health, Environmental and quality safety and environmental systems should be in hazards. place to assess hazards to employees, community

41 Education should be imparted 4.17.4Activities related with to the customer on the Product and Customer following: Safety

1) Dissemination of Product safety management product knowledge should be a line responsibility and aligned with the business 2) Establishing effective goals. Activities should method/channel/mediu include : m of communication a) System for disposal of 3) Safe use of product product found not meeting laid down standard/ 4) Critical information to specifications should be in be furnished on the place. product / package b) Training tools and 5) Emergency action and communications including first aid labels and material safety data sheets should be 6) Identification of prepared ,kept up-to-date target/vulnerable and distributed. customers c) Applicable environmental 7) Inspection of product/ guidelines and other packaging on receipt standards should be in by the customer place

8) Information on crisis d) All product safety records communication/emerge should be maintained. ncy cells e) System should be in place 9) Do's and Donot's in to respond on 24hr basis understandable fashion to emergency requests and calls. Emergency Cell 10) Creating customer for handling emergency interest involving products and services at customer 11) Formation of customer premises should function council round the clock

f) Excellence in product and service safety should be rewarded.

42 4.17.5 Investigation of Incidents through road in tank trucks. during Product Handling, To ensure safety of product Transportation and at and human beings involve Customer Premises directly or indirectly, it is essential that such vehicles 1) Establish accident are designed as per investigation policy & standards and driven by procedures competent personnel. To meet the objective, following 2) Establish team, level, task aspects should be taken into and authority for accident considerations : investigation.

3) Set up check list, guide 4.18.1 Vehicle lines for identifying the immediate and under lying Design of the vehicle should causes be in accordance with Petroleum Rules, SMPV 4) Control coordination with Rules 1989 and OISD others involved police, fire standards. brigade, CCOE, insurance 5) Set up communication Periodic Inspection of vehicles procedure and collect should cover the following : relevant information 1. Periodic statutory 6) Activate investigation as inspection in line with quickly as possible. SMPV rules, petroleum rules should be carried 7) Support out by competent person . investigation/analysis by tests and checks of 2. Inspection at the loading / equipment and product. unloading locations should be carried out and 8) Analyse all incidents for documented in line with common causes- the provisions of SMPV management system, Rules, Petroleum Rules installations, technical and OISD standard. systems, materials , tools , procedures , tasks. 3. System should be in place to correct the deviations 9) Implement preventive observed during inspection measures. of vehicles through the contractors with corrective 4.18 Road Transportation actions for non- Large volumes of petroleum implementation. products are transported

43 The relevant provisions of e) Accident analysis and Central Motor Vehicles Rules corrective measures should be adhered to. f) Improving awareness of drivers to the risks of 4.18.2Creating a Road Safety driving and how to reduce Culture them.

Following actions would help g) Focussed training to the creating road safety culture : crews in line with CMV Rules 1989 and OISD (a) Motivation to improve road standards safety performance h) Inspection/audit, (b) Assigning responsibility corrective action and accountability to improve road safety performance 4.18.4 Transport Safety Activities This should cover the (c) Participation and following : involvement at all levels i.e. transporter, crew, I. Establish transportation organisation. safety standards, procedures and (d) Prioritising road safety controls

II. Ensure compliance to 4.18.3 Transport Safety System standards/specification Following aspects should be s for vehicle, considered : accessories, fittings and spare parts a) Develop activities in line with company HSE III. Prepare and implement policies and strategies procedure and schemes for inspection b) Organisation with defined of vehicles and fittings responsibilities. IV. Establish driver/helper c) Implementation of competence standard / specifications / requirements and practices, monitoring and responsibilities corrective action V. Assess/review training d) Raise awareness and needs of drivers based standards on performance and

44 provide necessary XV. Set target and measure training road safety performance for VI. Develop performance employee, crew and indicators for the contractors. vehicle, drivers, contractors XVI. Thorough investigation of all accidents and VII. Establishment of road follow-up measures. safety committees for identification and XVII. Inspection/audit of mitigation of risk in transport operations road transportation. and follow up on action items. VIII. Select, assess, qualify, contract and XVIII. Feed back from periodically re-evaluate contractors on matters contractors affecting their safety performance. IX. Monitor contractor performance XIX. Prepare and ensure that relevant TREM X. Co-ordinate with cards are provided to contractors to improve transporters. safety performance.

XI. Discontinue use of poor performers 4.18.5 Defensive Driving By exercising the defensive XII. Continuously survey driving skills, the drivers the market to identify maintain a safety zone around new contractors who the vehicle. The defensive can provide services driving skill is intended to with required quality make allowance for the and HSE standards. followings-

XIII. Create movement a) Handling characteristics of schedules , monitor the vehicle journey times and routes b) A lack of skill and knowledge or XIV. Constitute road safety unpredictable actions on committees with the part of other drivers company employees , contractors and crews.

45 c) Vulnerability and hazardous products unpredictable behaviour should be as follows : of pedestrians and cyclists (a) Defensive d) Unpredictable behaviour driving skills of animals should be identified e) Hazardous climate conditions (b) Knowledge and understanding of road safety The skill and art of defensive legislation /rules / driving should be inculcated regulations. with the drivers by management through - (c) Emergency response (i) Improving awareness including fire fighting. (ii) Sharpening the skill of observation, (d) General vehicle perceptions and operations and anticipation mechanics of the vehicle. (iii) Providing time for the driver to correctly (e) Vehicle assess and respond to inspection a developing situation. (f) First aid (iv) Educating on Hazardous road (g) Product safety features, e.g. curves, knowledge hills, narrow roads, bridges, absence of signs, or signals and (II) Management should obstructions. ensure the following :

(v) System of assessment a) Legal requirements of driver training program in line with b) Emergency response OISD-STD- 154 and crisis should be in place. management

4.18.6 Safe Driving Assurance c) The main causes of road accidents (I) Competence profile of drivers transporting d) Product knowledge

46 e) Evaluation of (f) General - contractor's maintenance of performance progress, temperament, f) Safety inspections of observation, vehicles and drivers vehicle sympathy, concentration, g) Accident investigation attitude. techniques and analysis (g) Attitude - tendency to over h) Scheduling ,routing speed,overtaking, ,and journey positive/negative management (h) Documentation/re (III) Assessment of cords- Available, driving skill should up to date, include : authentic

(a) Use of controls - 4.18.7 Performance Measurement Accelerator, clutch, brakes, Following indicators should gears, steering, be pursued for performance mirrors measurement :

(b) Reversing - a) Number of potential Control, accuracy, incidents reported observations b) Setting targets for (c) Road procedure - transport safety activities Move off/stop, and its realisation signalling, positioning and c) Implementation of audit cornering, use of recommendations speed, lane discipline, d) Reported near misses overtaking. e) Follow up of non- (d) Reaction to - conformances found in Signs, hazards, inspections related to traffic lights vehicle / fittings during loading, unloading (e) Judgement - operations, non- standard Distance, items / maintenance length/width

47 f) Cases of speed and that gives the employer violations/over taking an opportunity to obtain an resulting into accidents advantage over competitors who do not know or use it.

4.18.8 Emergency Rescue The information needed about Operations a process or chemicals must be made available in such a This should cover the way that both employee and following : contractor personnel will (a) Each loading/unloading understand any hazard that location should develop may be present and what emergency rescue plan in precautions are necessary to line with the OISD protect them from exposure to standard. these hazards. Such information is required for (b) Such plan should broadly compiling process safety include limits of individual information , developing plants, emergency PHAs, developing operating response preparedness, procedures, incident communication linkages, investigations, emergency emergency organisation planing and response etc. If structure for required, confidentiality transportation, emergency agreement may be made with action plan action to the supplier. handle specific scenarios. Its objective is to prevent (c) Mutually agreeable casual access to critical emergency action plan for technical information about a road transportation should process by limiting the access be drawn in consultation to certain proprietary data. with the neighbouring oil industry and should be 5.0 References implemented. I. OISD-STD-105 "Work Permit System" (d) Mock drill on emergency II. OISD-STD-107 "Format handling in road for Incident Reporting" transportation should be III. OISD-STD-114 "Hazardous Chemical carried out once a year. Data" IV. OISD-STD-154 "Safety 4.19 Trade Secrets Aspects in Functional Trade secrets means any Training" confidential formula, pattern, V. OISD-GDN-145 process, device, information "Guidelines on Internal or compilation of information Safety Audits" that is used in the business VI. OISD-STD-155 "Personal Protective Equipment"

48 VII. OISD-GDN-166 "Guidelines on Occupational Health Monitoring" VIII. OISD-GDN-178 "Guidelines on Management of Change" IX. 29 CFR Part 1910 OSHA Rules, Process Safety Management of Highly Hazardous Chemicals X. AIChE Guidelines on Technical Management of Chemical Process Safety, 1995

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