The Bhopal Gas Tragedy in India where there was the leakage of the obnoxious Methyl Iso cyanate gas continues to be a grim reminder of what uncontrolled emissions can do to ravage the lives of people and future generations. Though Union Carbide might have passed on the handle to Dow Chemicals, no conciliatory action can ever compensate for the loss suffered by the people of Bhopal and the damage caused to the environment.
Let us analyse a few possible reasons for the mishap
* Lack of operational controls
* Lack of trained staff
* Lack of application of training
* Absence of regular safety checks and audits
* Lack of periodic maintenance of the plant
* Absence of senior management interest on safety related matters
* Failure to follow safety procedures
* Lack of statutory discipline by authorities
* Lack of panic management and emergency preparedness
* No procedures in place to handle uncontrolled emissions or leaks
Outcome of the mishap
* Loss of life, injuries that can affect generations of population
* Contamination of soil, air, water and damage to environment
* Loss of brand equity
* Major claims and costs arising from the same
* Civil suits in court
* Public outrage
* Jail sentences for guilty [including top management]
Safety & Regulation
Both safety and regulation go hand-in-hand. The presence of regulation acts as a deterrent for non-compliance to safety rules. However, owing to red tape, bureaucracy and corruption, the statutory enforcement of safety [at least in India] has not been up to the mark. Further, the multiplicity of regulatory bodies can add to the complexity if different authorities specify different requirements. However, one cannot deny that this also helps in keeping a tight check on safety. In many chemical plants, especially those conforming to global standards, there can be conflict between what the organisational safety policy demands and what the statute demands. A dialogue across the table and sharp understanding of the statute is essential.
Why is Safety so important?
Human Life is precious and unsafe practices can lead to loss of lives, injuries that can adversely affect a population. The regulation is intended to ensure that safety norms are in place and that they are not flouted. Every chemical factory must have a clear and concise safety policy.
Safety in a chemical plant: Important points to be considered
1. What are the types of chemicals being handled?
2. Are they flammable?
3. Do we have Product Data sheets as well as Material Safety Data sheets?
4. Are people trained in handling chemicals?
5. How are the chemicals stored? In drums or in barrels or in tanks or steel containers?
6. Can there be static reaction between chemicals that are stored? In such a case, are the chemicals appropriately isolated from each other?
7. What is the level of housekeeping in a chemical factory? Is there enough space to manoeuvre?
8. Does the chemical factory have a CCTV surveillance, fire fighting and detection systems?
9. Does the factory have a safety manual? Is there a disaster response plan? Are there clear cut guidelines to handle an emergency?
10. What is the importance given to training? How training is applied and how is the effectiveness of safety training measured?
11. Are there appropriate checks at entry and exit points both in the whole factory as well as at strategic places of storage that can be sensitive?
12. Does the Chemical installation follow any local/ international standards? Like ISO 9001, QS 9000 etc, OSHA standards.
13. In case of hazardous chemicals, are there procedures in place to handle them? How are they disposed?
14. If the plant is handling hazardous chemicals, do they confirm to EMS (Environmental Management Standard) / ISO 14000?
15. Is there a safety check list?
16. Are Quality audits being conducted? If yes, what is the frequency of the audits?
17. How often are Risk assessments of the operations conducted? Monthly, Fortnightly, Quarterly, Yearly?
18. What are the input measures ? What are the output measures? ([Please see note below for the same])
19. Has any accident happened at the site?
20. What is the involvement of top management in day to day operational affairs of the factory? Monthly reviews, Quarterly reviews, Half yearly reviews?
21. Does the factory have spill control measures in place to handle spillage of chemicals?
22. What precautions has the factory taken to prevent uncontrolled release of chemicals in the environment?
Answers to these questions will clearly reflect the emergency preparedness of a chemical installation and the importance accorded to safety.
Input measures & Output measures
This is a simple concept. If you are regularly wearing helmets while driving your bike and driving carefully by following traffic signals, then these are the input measures. As a result of these efforts, if you have not met with any accident in the last 6 months, then this is an output measure. The input measures in a chemical plant can be all the steps (as described above) taken to enhance safety. Similarly, the output measures in a chemical installation can be
* The number of instances when leaks have been reported
* The number of instances when pilferage has been reported
* The number of accidents/ near misses/ injuries over a period of time
If safety procedures are followed religiously, then no. of leaks, accidents, injuries etc can be "zero”. But please note that the converse is not true. Accidents in chemical installations can happen unannounced. So, if there are no accidents, we can't assume that safety procedures are adhered to. A thorough investigation is essential to double check the compliance level.
Safety while transporting chemicals is of utmost importance as this can have an adverse effect if there is lack of awareness about the same.
Some of the questions that one needs to ask:
1.How are the chemicals being transported - in trucks, tankers, lorries ?
2.Does the material safety data sheet and product information accompany the consignment?
3.Is there night driving involved ?
4.Are the drivers trained in defensive driving ?
5.What are the quality checks made before loading the consignment?
6.Are there any quality checks made while unloading the consignment ?
7.What are the penalty clauses in case of short filling ? (i.e. receiving less quantity than what is mentioned in Purchase order or Delivery Challans).
8.If such occurrences (short filling) are recurring, then what action is taken by the management to avoid the recurrences?
9.Is there a procedure in place if there is a chemical spill during transportation? Who are the people who get involved in case of a spill ?
10.How do you ensure that there is no overloading ?
11.Is there a contract between the chemical factory and the supplier that includes transportation safety as part of the contract?
12.Is there training of chemical suppliers and transportation service providers and drivers ?
13.In case of a problem, do you turn back the consignment or is a compromise solution arrived at ?
For example - if a consignment is not accompanied by material safety data sheet and chemical test report, do you refuse to unload? In such a case, what actions do you take ?
It is important to know about all the regulatory authorities who govern the compliance of factories with safety procedures. To take an example, in India, we have
a. Factories Act, 1948 (Factory Inspector)
b. Municipal Corporation (Chemical Storage Inspector)
c. Pollution Control Board
d. Port Trust Inspection (if the chemical factory is located close to a port)
e. The Fire Department
There may be other authorities to ensure factories comply with labour laws. This can vary from state to state, region to region.
I would like to reiterate that though the original intention of having multiplicity of regulatory authorities was to ensure that safety was all-pervasive and given due weight age, it has actually proved to be more complex in India due to lack of coordination between different authorities, differing requirements and the deleterious effect of bureaucracy and red tape.
A few important questions that need answers is: Considering the differing requirements of various statutory authorities, what actions are taken by the chemical factory to bring a semblance of balance to meet the compliance norms ? How often do they review compliance of the factory with various statutes ? Do actions taken to close the gaps receive management support ? How serious is management about complying with regulation ?Are there regulations that overlap each other ? Does this lead to simplification of the compliance process?
Though the compliance process needs the use of a lot of elbow grease, the fruits of the labour can be highly rewarding. Organisations that operate in the manufacturing space will realise that their brand value is intricately linked to the safety policy. Product Stewardship (i.e. the technique of
assuming ownership from birth of a product till it reaches the end of its life cycle) will play a very important role in the future success of such businesses. Product Integrity (what you see on the pack is what you get) is also going to play a crucial role. Safety, quality, product stewardship and product integrity are so closely linked. Time spent on these efforts is certainly well spent.
Top Management involvement
a. How often does your top management review the operations of the factory and safety compliance ? (Weekly/Monthly/Quarterly)
b. How often does the management communicate about the safety policy and need to comply with it?
c. What are drastic actions taken by management in case employees fail to adhere to safety policy ?
Safety is always driven from the top. Though the compliance process and dealing with an array of regulatory authorities can prove to be taxing, it can reap rich rewards for the future and contribute to the business growth. The organisations involved in manufacturing chemicals have a huge responsibility on their shoulders to ensure that their installation is not just safe, but also has controls and checks in place to avoid loss to the community around the factory as well as to the environment. Efforts to comply with safety can never go waste.