The LINK does not give much information other than reporting the development. However, we can keep checking the EPA website for latest news and its applicability to chemicals in our work place.
Dec 7, 2010
Dec 3, 2010
Bhopal Accident - One more year passed!
Another year passed to count on Bhopal accident. After the Bhopal accident, we can recount the accidents at HPCL, Vizag and IOCL, Jaipur where human lives are lost in double digit. We do not know, how many are going to happen at any time. We may think that we are doing pretty well on safety matters, but it is the luck and time factor rather than our safety alertness that accidents of great magnitude did not happen.
All of us know what to do to avert an accident, but complacency and wrong priorities make us to delay immediate actions for improving safety at workplace.
In the West, well established industrial organizations saw occurrence of accidents, though there safety record is at its best till the occurrence of the accident.
Though, incentives do not lead to permanent safety solutions, still we can offer significant incentives to employees who point out hazards and those responsible for allowing those hazards should be punished parallelly.
Too much freedom and associated inaction should not be tolerated in any hazard installation and wrong doers should be handled severely.
All of us know what to do to avert an accident, but complacency and wrong priorities make us to delay immediate actions for improving safety at workplace.
In the West, well established industrial organizations saw occurrence of accidents, though there safety record is at its best till the occurrence of the accident.
Though, incentives do not lead to permanent safety solutions, still we can offer significant incentives to employees who point out hazards and those responsible for allowing those hazards should be punished parallelly.
Too much freedom and associated inaction should not be tolerated in any hazard installation and wrong doers should be handled severely.
Nov 30, 2010
Number of safety officers in a hazardous plant - statutory and practical requirements
Safety officers in any hazardous installation are appointed as specified in statutes, which say that factories where 1000 or more persons are employed, safety officer should be appointed. When the employee strength exceeds 2000, for every additional 1000 employees, one safety officer should be employed with 500 or more employees rounded to 1000. For major hazard installations, factory inspector can specify the number of safety officers irrespective of employee strength. Accordingly, the number of safety officers for various employee strength will be as follows:
Employee Strength No. of safety officers
Upto 1499 1
1500-2499 2
2500-3499 3
3500-4499 4
5499-6499 6
8499-9499 9 and so on.
In some states, rules are framed as one safety officer for every 3000 employees is to be engaged.
As per Maharashtra Safety Officers Rules, 1982; the no. of safety officers required is,
1000-2000 1
2001-5000 2
5001-10000 3
>10000 4
But, in reality safety professionals find it difficult to manage safety aspects with so many employees in a factory, particularly where the operations are varied and complex, and with a large number of departments. The duties of safety officers include carrying out / conducting,
The work load increases depending upon the number of departments / sections, safety officer has to deal with. For example, if the number of employees in a factory having 4-5 departments is 4000, the work load for 4 safety officers appointed as per statutory requirement will be somewhat less compared to the work when the number of department is, say 30-40 as the complexity will increase both in technical and administration. The problem multiplies for the safety officers when his colleague in the safety department proceeds on leave as they have to look after safety aspects temporarily during the leave period.
Technical difficulties are in the form of wide variety of operations and administration difficulties are in the form of dealing with a number of shop floor/section/department heads. As the number of employees and departments increase, the levels of officers will increase and accordingly safety officers have to deal from lower to top level in orderly fashion and this increases work load enormously. Shop floor person can say he is doing as per his next level supervisor instructions and if safety officer directly talks to top and next level person, he can say he is not aware or instruct the safety officer to talk to lower level in-charges.
Added to the above, is contractor workers and their safety. Normally, contractor workers are engaged for doing various petty jobs and sometimes for regular plant operations and civil works. The real difficulty is that they will be working at different places on same day or at different periods and therefore job hazard analysis for their jobs and ensuring their safety is a tough task.
Though there are safety coordinators in some factories who do production and safety coordination with the safety department, in practice these safety coordinators give importance to production activities and thus safety at workplace rests with the safety department.
Though, Factories Act and its Rules say the duty of safety officer is to advice and assist, in reality, safety officer ends up in doing the jobs and in some factories, he will be asked to eliminate the hazards also by engaging few contractor workers, i.e., he has to identify and eliminate. After sometime, this may lead to not doing the jobs even as per Factories Rules and cause a dangerous work place for employees.
In view of the above, I feel that the legislations regarding number of safety officers should be reviewed and revised taking into account of number of employees and number of departments as below:
Upto 500 1 2501-2750 7 4001-4250 13
501-1000 2 2751-3000 8 4251-4500 14
1001-1500 3 3001-3250 9 4501-4750 15
1501-2000 4 3251-3500 10 4751-5000 16 and so on.
2001-2250 5 3501-3750 11
2251-2500 6 3751-4000 12
The employee strength should be taken as maximum number (including contractor workers, casual workers, etc) supposed to work at any given time. To ensure safety, atleast one safety officer should be available in shifts other than general shift, including Sundays and holidays.
With the above, I feel that safety department can function effectively to ensure a safe work place.
Employee Strength No. of safety officers
Upto 1499 1
1500-2499 2
2500-3499 3
3500-4499 4
5499-6499 6
8499-9499 9 and so on.
In some states, rules are framed as one safety officer for every 3000 employees is to be engaged.
As per Maharashtra Safety Officers Rules, 1982; the no. of safety officers required is,
1000-2000 1
2001-5000 2
5001-10000 3
>10000 4
But, in reality safety professionals find it difficult to manage safety aspects with so many employees in a factory, particularly where the operations are varied and complex, and with a large number of departments. The duties of safety officers include carrying out / conducting,
- inspections if not every day but atleast once in a week
- issue of safe work permits
- permission for modifications, changes, erection/commissioning of new equipment/process, etc
- job hazard analysis
- safety meetings in every department
- apex safety committee meetings
- safety audits
- accident/incident investigation
- training
- safety awareness programmes
- safety seminars
- followup with departments for compliance with recommendations of various committees
- safety studies like HAZOP, ETA, FTA, HIRA, etc
- coordination with regulatory agencies
- preparation and filing reports as per statutory requirement
- updating and maintaining records
- PPE procurement
- office safety (of various departments)
- contractor safety
- and so on
The work load increases depending upon the number of departments / sections, safety officer has to deal with. For example, if the number of employees in a factory having 4-5 departments is 4000, the work load for 4 safety officers appointed as per statutory requirement will be somewhat less compared to the work when the number of department is, say 30-40 as the complexity will increase both in technical and administration. The problem multiplies for the safety officers when his colleague in the safety department proceeds on leave as they have to look after safety aspects temporarily during the leave period.
Technical difficulties are in the form of wide variety of operations and administration difficulties are in the form of dealing with a number of shop floor/section/department heads. As the number of employees and departments increase, the levels of officers will increase and accordingly safety officers have to deal from lower to top level in orderly fashion and this increases work load enormously. Shop floor person can say he is doing as per his next level supervisor instructions and if safety officer directly talks to top and next level person, he can say he is not aware or instruct the safety officer to talk to lower level in-charges.
Added to the above, is contractor workers and their safety. Normally, contractor workers are engaged for doing various petty jobs and sometimes for regular plant operations and civil works. The real difficulty is that they will be working at different places on same day or at different periods and therefore job hazard analysis for their jobs and ensuring their safety is a tough task.
Though there are safety coordinators in some factories who do production and safety coordination with the safety department, in practice these safety coordinators give importance to production activities and thus safety at workplace rests with the safety department.
Though, Factories Act and its Rules say the duty of safety officer is to advice and assist, in reality, safety officer ends up in doing the jobs and in some factories, he will be asked to eliminate the hazards also by engaging few contractor workers, i.e., he has to identify and eliminate. After sometime, this may lead to not doing the jobs even as per Factories Rules and cause a dangerous work place for employees.
In view of the above, I feel that the legislations regarding number of safety officers should be reviewed and revised taking into account of number of employees and number of departments as below:
- One safety officer for every 500 employees upto 2000 employees or every 5 departments and thereafter
- one safety officer for every 250 employees
Upto 500 1 2501-2750 7 4001-4250 13
501-1000 2 2751-3000 8 4251-4500 14
1001-1500 3 3001-3250 9 4501-4750 15
1501-2000 4 3251-3500 10 4751-5000 16 and so on.
2001-2250 5 3501-3750 11
2251-2500 6 3751-4000 12
The employee strength should be taken as maximum number (including contractor workers, casual workers, etc) supposed to work at any given time. To ensure safety, atleast one safety officer should be available in shifts other than general shift, including Sundays and holidays.
With the above, I feel that safety department can function effectively to ensure a safe work place.
Nov 10, 2010
Nov 9, 2010
Responsibilities and limitations of regulators
Recently, I read in local news papers about the fire in a chemical plant. It is stated that during distillation of a chemical to supply to a factory, water entry caused explosion causing serious injuries to four workers. A visiting representative expressed his anger on the concerned Inspector of Factories for allowing the factory to run without permission. The licence for the factory expired a few years ago. Regional Pollution Control Board (PCB) also suspended the operations after a fire incident a year before. The anger of the representative is justified. That the plant was closed by PCB after a fire incident, two years after expiry of licence indicates that the plant was in operation all along.
But, on the other side, what are the resources available to the factory inspectors. What are the powers available to the inspectors. When an inspector identifies a plant with dangerous conditions or without valid licence, he will stop the operations. But, how to ensure physical stopping of operations. The factory inspector can't become watchman for the factory to ensure this. If that is the case, then for every factory or a few factories, one inspector is required. At this rate, the factory department needs hundreds of factory inspectors which is not at all possible because of lack of funds. This is a system failure.
If a factory is run inspite of stopping orders, then the occupier is liable along with the authorities responsible for continuing to supply services likes electricity, water, etc. Similarly, municipality, revenue, police, excise, customs departments which collect taxes and other service charges are also responsible. They can't work independent of other agencies. Once these agencies are intimated about a factory closure, all concerned have to keep check on the said factory. In addition, the customers (factories buying products) of the guilt factory should also be held responsible for making purchases without checking validity of licences. Now a days, with ISO certification, every management needs to ensure proper licences and authorizations before purchasing any items. Of course, if the product is a finished item for purchase by public, then these public can't be held responsible as there is no way of checking the credentials before buying.
There is no information in the news papers about how many times the factory inspector inspected the plant in the last few years. If there were inspections, factory inspector is equally responsible for the incident.
When a proper coordination exists between all concerned agencies as listed above and others, I am sure the hands of factory department will be strengthened to ensure safe work place.
But, on the other side, what are the resources available to the factory inspectors. What are the powers available to the inspectors. When an inspector identifies a plant with dangerous conditions or without valid licence, he will stop the operations. But, how to ensure physical stopping of operations. The factory inspector can't become watchman for the factory to ensure this. If that is the case, then for every factory or a few factories, one inspector is required. At this rate, the factory department needs hundreds of factory inspectors which is not at all possible because of lack of funds. This is a system failure.
If a factory is run inspite of stopping orders, then the occupier is liable along with the authorities responsible for continuing to supply services likes electricity, water, etc. Similarly, municipality, revenue, police, excise, customs departments which collect taxes and other service charges are also responsible. They can't work independent of other agencies. Once these agencies are intimated about a factory closure, all concerned have to keep check on the said factory. In addition, the customers (factories buying products) of the guilt factory should also be held responsible for making purchases without checking validity of licences. Now a days, with ISO certification, every management needs to ensure proper licences and authorizations before purchasing any items. Of course, if the product is a finished item for purchase by public, then these public can't be held responsible as there is no way of checking the credentials before buying.
There is no information in the news papers about how many times the factory inspector inspected the plant in the last few years. If there were inspections, factory inspector is equally responsible for the incident.
When a proper coordination exists between all concerned agencies as listed above and others, I am sure the hands of factory department will be strengthened to ensure safe work place.
Nov 2, 2010
Dangers of confined spaces - Oxygen levels below 19.5%
I read an excellent article on wrong notions of safe oxygen level of 19.5%. One should find why oxygen levels are below 21% and only after getting satisfactory answer, should venture into confined space with proper PPE. I feel that, once oxygen levels are below 21%, one should go inside only with airline respirator / self contained breathing apparatus as suitable it is. We should remember that catridge/canister type respirators are useful only upto 2% of contaminant concentrations and above this, one should use fresh air supply system.
Oct 19, 2010
Process safety and stuxnet worm?
Of late a number of articles are appearing on impact of stuxnet worm on process safety and it is an eye opener for me. Though, I am bothered about safety of my computer at home and office, it never occurred to me that this can lead to accidents in plants which are operated from computers. Possibly, this is due to the fact that only limited sections are operated from computers in the facilities which I saw all along.
Now that I am aware of this stuxnet worm and its cousins that can affect process safety, I though what we can do to prevent such process safety hazards and following are some that came to my mind.
1. As the worm has to enter through internet / removable disks, these computers should not be connected to internet.
2. There should not be any provision to use pen drives, floppy drives, CDs.
3. Realtime protection from viruses, worms, etc should be available. For this realtime protection program loading, the server system should be under lock and key control of a senior officer. If it is affected, then this man only is the channel for viruses/worms to enter the system.
4. A realtime standby system operating on a different mode should be available (diversity in redundancy).
5. Backup should be taken in every shift.
6. The persons manning the control room should change their dress totally in the change room and enter with company provided dress before entering control room / server room.
7. Control room, server room, etc should be under surveillance.
8. As it is seen in the movie Die Hard (2?) of taking over all control systems by connecting from distance, the cables connecting servers with plant data monitoring and control cables should be secured and any attempt to interfere should be sensed and alarmed.
9. Like railway gangmen check the rail tracks regularly, cable system should be checked physically also by authorized staff.
Above are some thoughts which came to me for ensuring process safety from worms like stuxnet. I have to understand about how plants are operated from computers and what are their defence systems.
Now that I am aware of this stuxnet worm and its cousins that can affect process safety, I though what we can do to prevent such process safety hazards and following are some that came to my mind.
1. As the worm has to enter through internet / removable disks, these computers should not be connected to internet.
2. There should not be any provision to use pen drives, floppy drives, CDs.
3. Realtime protection from viruses, worms, etc should be available. For this realtime protection program loading, the server system should be under lock and key control of a senior officer. If it is affected, then this man only is the channel for viruses/worms to enter the system.
4. A realtime standby system operating on a different mode should be available (diversity in redundancy).
5. Backup should be taken in every shift.
6. The persons manning the control room should change their dress totally in the change room and enter with company provided dress before entering control room / server room.
7. Control room, server room, etc should be under surveillance.
8. As it is seen in the movie Die Hard (2?) of taking over all control systems by connecting from distance, the cables connecting servers with plant data monitoring and control cables should be secured and any attempt to interfere should be sensed and alarmed.
9. Like railway gangmen check the rail tracks regularly, cable system should be checked physically also by authorized staff.
Above are some thoughts which came to me for ensuring process safety from worms like stuxnet. I have to understand about how plants are operated from computers and what are their defence systems.
Empowering safety department - How long?
Recently, I read an article that the new boss of BP is reshuffling the safety division and is making it as the most powerful voice and that they can intervene in any of the technical functions of the BP. This is what is required by law also. Only that we do not follow.
I do not doubt about the capabilities of earlier safety staff of BP. I doubt only about the production staff. It is normal to see in any production facility that production staff and their bosses pay little attention to what safety department says. As the safety department is part of the facility, it can only advise. Implementation depends on the whims and fancies of the production department. Safety department becomes powerful only when the top man gives unconditional support to it. In the present case also, though the new boss ALLOWED safety division to be powerful, the time upto which it can be allowed to function this way will be limited, as Mr Trevor Kletz said, "corporate memory is short". As the memory fades gradually, well meant safety advises become additional work and time consuming for the production staff and slowly they start ignoring the safety advises. By that time, the BP boss who is making safety division powerful may also leave the organization and the STORY WILL REPEAT. Again as observed by Mr Kletz in his books.
It is my observation which evolved with my interaction with many of my friends in various industries and also from my knowledge of reading various books, safety blogs and investigation reports of CSB, HSE, etc that it is a worldwide phenomenon of giving importance to safety only after an accident and then slowly forgetting about it.
A KNEE JERK REACTION INDEED.
I do not doubt about the capabilities of earlier safety staff of BP. I doubt only about the production staff. It is normal to see in any production facility that production staff and their bosses pay little attention to what safety department says. As the safety department is part of the facility, it can only advise. Implementation depends on the whims and fancies of the production department. Safety department becomes powerful only when the top man gives unconditional support to it. In the present case also, though the new boss ALLOWED safety division to be powerful, the time upto which it can be allowed to function this way will be limited, as Mr Trevor Kletz said, "corporate memory is short". As the memory fades gradually, well meant safety advises become additional work and time consuming for the production staff and slowly they start ignoring the safety advises. By that time, the BP boss who is making safety division powerful may also leave the organization and the STORY WILL REPEAT. Again as observed by Mr Kletz in his books.
It is my observation which evolved with my interaction with many of my friends in various industries and also from my knowledge of reading various books, safety blogs and investigation reports of CSB, HSE, etc that it is a worldwide phenomenon of giving importance to safety only after an accident and then slowly forgetting about it.
A KNEE JERK REACTION INDEED.
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