Process Safety Management in India
Paper presented in International Conference on “Bhopal and its effects on
Process Safety” at IIT,Kanpur,2004
B.Karthikeyan
1A, No.1, Third Main Road, Kasturba Nagar, Adyar, Chennai-600020,
India
e-mail: bkprism@gmail.com
After the Bhopal disaster in 1984, a number of changes were made in the
Indian Factories Act and environmental legislation. Over the last decade the
Indian Chemical industry has been striving to improve its safety and
environmental performance. Twenty years after Bhopal, what are the lessons
that we have learnt in India ? This paper examines the following in the
context of the current Indian scenario and also suggests the way ahead:
• Changes in safety and environmental legislation – Are they adequate to
prevent another Bhopal?
• Process Safety Management in India –
- Current trends in process safety management and business strategy
- Process Safety Information: Design data and their limitations in the
light of old plants
- Contractor safety in the Indian context
- Emergency response planning and off site emergencies: Limitations
and problems faced
- Management of change in the light of globalisation and cost cutting
initiatives
- High personnel turnover and training
- Incident Investigation
- Improvements needed in the measurement and tracking of process
safety performance
- Industry Institution interaction and its need in the Indian context
- Terrorism and process safety
Keywords: Lessons, Bhopal, Process Safety Management, India
1
Introduction:
After the Bhopal gas disaster in 1984, the Indian legislation governing safety
and environment underwent significant changes. Specifically, the Factories
Act was amended to assign the responsibility of the “occupier”, who is
legally responsible for the safety of the workplace and workers, to the
highest level of management in an organization. For a company, this meant
that one of the directors on the board had to be designated as “occupier”.
The Environmental legislation also underwent changes, with the
Environment Protection Act introduced in 1986. Under this act, a number of
new legislations were framed. The Manufacture, Storage and Import of
Hazardous Chemical rules, 1989 was introduced with the objective of
preventing another Bhopal type of disaster. Specifically, this rule required
safety audits to be carried out in hazardous chemical factories, storing more
than a threshold limit of hazardous chemicals.
The Chemical Accidents (Emergency Planning, Preparedness and Response)
Rules, 1996 was also introduced. Preparation of on-site Emergency Plan by
the Industry and Off-site Plan by the District Collector and the constitution
of four-tier Crisis Groups at the Centre, State, District and Local level for
management of chemical accidents are mandatory under these Rules. These
rules also focus on accident prevention, preparedness and mitigation for
achieving adequate safety by minimising risks while handling hazardous
chemicals during production, storage, transport, trading and use of
chemicals.
Under these rules, the industries have been identified as ‘Major Accident
Hazard” based on exceeding threshold quantities of hazardous chemicals
specified in Schedules 2 and 3 of the rules.
The Public Liability Insurance Act, 1991 was also promulgated, which
mandates compulsory insurance for the purpose of providing immediate
relief to persons affected by accidents that occur in handling any hazardous
substance.
Are the changes in the Indian legislation enough to prevent another Bhopal?
After Bhopal, a number of serious chemical incidents took place in India.
Some of them are listed in Table 1.The table indicates that incidents
2
involving hazardous chemicals still continue to occur in India. Many of the
near miss chemical incidents go unreported.
Meanwhile, in the USA, after Bhopal and other disasters, the Process Safety
Management System developed by Occupational Safety and Health
Administration became mandatory in 1992 for industries handling, storing
and manufacturing hazardous chemicals above a threshold quantity
specified.
The PSM system comprises of 13 elements:
1. Process safety information
2. Process hazard analysis
3. Operating procedures
4. Contractor control
5. Pre start up safety review
6. Training
7. Hot work permit
8. Incident investigation
9. Mechanical integrity
10. Management of change
11. Emergency planning and response
12. Trade secrets
13. Compliance audits
Recently, incidents due to reactive chemicals have gained prominence in the
USA. Based on the experience of adopting PSM for more than a decade in
the USA, India must leapfrog to the latest PSM standards, adopt and enforce
them in hazardous industries.
The enforcement of legislation by the Indian authorities must be made
effective by training the law enforcers in the latest developments in risk
prevention, inspection and management system audit techniques.
The safety officers employed in hazardous industries are mandatorily
required to be trained in any of the Regional Labour Institutes across the
country. However, during their training, they are not exposed to the latest
trends in Process Safety Management Systems. This results in the inadequate
knowledge of process safety issues and inability to solve them when they
arise.
3
As per KPMG (2003) , the Indian Chemical Industry contributes to 6.7 % of
India’s GDP, with revenues of USD 28 billion. As per Indian Chemical
Manufacturer’s Organisation (website,2004) the industry has the following
credits to its name:
• The Indian fertilizer industry is the fourth largest in the World.
• It is the largest manufacturer of pesticides in Asia, second only to
Japan
• The Indian Pharmaceutical industry is the largest in the developing
World.
The large scale players in the industry have been proactively adopting
management systems for process safety, occupational health and
environment. Though the Process Safety Management system is not
mandated by Indian law, a number of chemical industries in India are
voluntarily adopting the PSM system developed by OSHA, USA.
Process Safety Management is increasingly being woven into business
strategy, during the project conceptualization stage itself.
While the large scale players are systematically adopting best practices in
process safety management, the fragmented medium and small scale
manufacturing sector is yet to systematically adopt process safety
management.
Process Safety Information: design data and their limitations in the
light of old plants:
The Process Safety Information is the heart of the PSM system. Indian
chemical industry has a mix of old and new chemical manufacturing plants.
For the old (plants of 10 years or more), critical process safety information
like design basis of safety valves, safe operating limits, electrical area
classification, reaction chemistry, reactivity data, thermal and chemical
stability data are either missing or inadequate. These plants undergo constant
modifications to increase productivity or process different grades of
products. Lack of critical process safety information may cause a major
incident later.
The old plants also suffer from a lack of knowledge management of previous
R & D efforts. In the pharmaceutical sector, scale up of new molecules from
4
R & D lab to the manufacturing plant needs updated process safety
information. Lack of such information have caused serious incidents.
In newer plants, while process safety information is available, in many
cases, they are not kept updated. Piping and instrumentation drawings (P &
ID’s) and material and equipment specifications are prone to changes due to
modifications. Unless a systematic system for managing changes is
implemented, the process safety information does not get updated in a timely
way. This results in Hazard and Operability studies being performed on old
P & ID’s.
Contractor safety in the Indian context:
As part of cost cutting initiatives, some of the organizations outsource
activities like maintenance functions and operations activities like bagging
and manual handling of products. In many of the activities that are
outsourced, the contractor employs an unskilled worker. A contract
employee in a developing nation like India displays a high risk taking
ability, driven by his urge to earn his daily living. This leads to many
accidents involving contractors. In many large Indian organizations that
have implemented a contractor safety management program, it is observed
that the most effective control programs are those which levy a monetary
penalty for any safety violation by a contract worker.
In the context of the above, it is imperative that the regulations governing
employment of contractors in hazardous chemical plants be strengthened.
The safety training requirements for contractors working in hazardous areas
of the plants must be defined and the contractor should be held accountable
for the safety performance of his employees.
Emergency response planning and off site emergencies: limitations and
problems faced:
The Chemical Accidents (Emergency Planning, Preparedness and Response)
Rules, 1996 was introduced after the Bhopal disaster. Preparation of the on-
site Emergency Plan by the Industry and Off-site Plan by the District
Collector and the constitution of four-tier Crisis Groups at the Centre, State,
District and Local level for management of chemical accidents are
mandatory under these Rules. Based on the experience gained after the
implementation of the rules, the following are observed:
5
• Specialised training in Chemical disaster management should be
made mandatory for all members of the four tier crisis groups.
Refresher training program for the members on latest crisis
management techniques must be implemented.
• Policies for handling media communication during crisis management
should be developed for the four crisis groups. Training on
“communicating during emergencies” should be made mandatory to
the personnel of the crisis committees.
• The results of the mock drills conducted by the Crisis committees
need to be shred at a national level by establishing a national database.
This database should be available to all members of the crisis
committees.
• The Crisis Groups must critique every major incident for lessons
learnt. These learnings must be shared with all crisis groups across the
country.
Management of change in the light of globalisation and cost cutting
initiatives:
The Indian Chemical Industry is gearing itself for the challenges from
globalization. Managing change during these times is very important to
prevent incidents. The cost cutting initiatives that are taken up need to
undergo an effective management of change process. Managing changes to
technology, facilities and personnel in a Chemical Industry are not the same
as managing change in any other industry. The implications on safety
are enormous. The Bhopal disaster stands a testimony to this.
Some of the issues facing the Indian Chemical Industry in managing change
are:
• Reduction of personnel, as part of cost cutting initiatives, is not
assessed for risk versus monetary gain. In many cases, the monetary
gain overshadows the increased risk. This can lead to incidents caused
by inadequate competence or manning.
• Some of the line managers view change management as an
unnecessary burden. This results in ineffective management of
change.
• While developing new products or modifying existing processes, lack
of updated process safety information leads to assumptions. Due to
time pressures, these assumptions are not validated.
6
• The importance of managing change is sometimes not stressed by top
management. This results in the bypassing of systems to manage
change.
• Knowledge management of changes is poorly handled, with
ineffective training and poor sharing of information.
High personnel turnover and training:
The Indian chemical industry faces a paradox. While fresh chemical
engineering graduates are available in plenty, experienced engineers leave
the shores for lucrative jobs in the Middle East and Far East countries.
Highly automated plants with redundant safety shutdown systems would not
normally cause incidents. In some of these plants, in times of poor business
performance, the integrity of such systems gets compromised.
Many of the batch processes in the industry are operated on manual control.
Lack of trained personnel in such areas could cause a major accident.
Some of the industries have process simulators to effectively train their new
recruits. But these are not available to everyone. The large scale plants in the
Indian Chemical Industry should transit towards making simulator training
compulsory for operators prior to manning the control room of plants.
Process Safety Training is still not given a focus in the medium and small
scale plants. The Government should develop institutes which impart the
basic process safety training at operator level.
Incident Investigation
Root cause analysis and human factors
Many of the Indian Chemical Plants have been certified to OHSAS 18001
(Occupational Health and safety management system). As part of its
requirements, it requires an incident investigating system to be in place.
Investigating a process safety incident requires proper training on root cause
techniques and human factors. The investigation of human factors in process
safety incidents should be made mandatory. The categorization
of root causes of incidents needs to be discussed by top management to spot
inherent weaknesses in the systems and take timely corrective action.
7
The need for a process incident database and knowledge management:
A number of incidents continue to occur in Chemical plants. Some of them
are reported to the statutory authorities (Factory Inspectorate) as part of the
legal rules framed under Factories Act. However, the lessons learnt from the
incident are not available in a national database. In the USA, the Chemical
Safety and Hazard Investigation Board, plays a very important role in
investigating and sharing the results of these investigations.
In India, the Directorate General of Factory Advice Service and Labour
Institute (DGFASLI), with its central and regional labour institutes, has the
responsibility for providing technical advice to factory inspectorates on
matters connected with the administration of the Factory Act. It is also
responsible for undertaking the necessary research, training and educational
activities related to the promotion of safety and health in factories. The
DGFASLI should develop a National Process Safety Incident Database,
based on the inputs from its inspectorates. This database should share
lessons learnt from chemical plant incidents.
Improvements needed in the measurement and tracking of process
safety performance
The “Responsible Care®” movement was started by chemical
manufacturing industries in the developed countries after Bhopal and other
incidents. This voluntary initiative is recently morphing to a “Responsible
Care Management System®”, certifiable by third parties. In India, the Indian
Chemical Manufacturers Association (ICMA) has actively encouraged its
members to adopt the Responsible Care® movement. However, only 85
organisations have signed up to the initiative, when over 1000 industrial
plants have been identified in the Maximum Accident Hazard category.
Measuring and tracking process safety performance needs a process safety
management system in place. Performance metrics must be defined to
monitor and measure the process safety performance of an organization. The
process safety management system could be audited with performance
metrics for each element of the system. Some of the examples are:
• Number of process related incidents that are repeated (Indicates poor
quality of investigation or poor implementation of recommendations)
Responsible Care® and Responsible Care Management System® are registered service marks of American
Chemistry Council
8
• Number of top management reviews for process safety held as per
schedule (Indicates top management commitment)
• Number of public complaints received (indicates the effective control
over hazardous chemicals)
• Number of times a parameter for emission or effluent has exceeded
legal norms.
• Number of times incidents have occurred due to bypassing of safety
systems (Indicates line management’s commitment towards safety)
• Number of times an equipment failure has triggered an incident
(indicates the effectiveness of the mechanical integrity program)
• Number of incidents involving contractor workmen (Indicates the
effectiveness of the contractor control program)
Industry Institution interaction and its need in the Indian context
After Bhopal, much remains to be done in improving industry – institution
interaction.
The management of process safety should be dealt as a separate subject in all
undergraduate courses of Chemical Engineering and Diploma in Chemical
Technology. . Refresher courses in the latest management systems for
process safety should be developed for working engineers and managers.
In institutions with good laboratory and research facilities, the pilot plant
studies of new products and the potential problems during scale up are areas
where interaction could be improved.
Terrorism and process safety:
Terrorism rears its ugly head worldwide. In India, the attack on the oil
facility in Assam, last year, is one example. Chemical plants are potential
targets for terrorist attacks. In India, the policy makers are yet to give a clear
thought to this aspect. Security and process safety are interlinked. While the
large plants in India do have some semblance of a security system in place, a
security risk analysis should be made mandatory for all hazardous chemical
factories, with an inventory of chemicals exceeding those specified in the
Chemical Accidents (Emergency Planning, Preparedness and Response
Rules), 1996. The risk analysis should also cover transportation of hazardous
chemicals.
9
The results of these risk analysis should be incorporated in the emergency
response plans of the organizations.
The Way Forward:
Has the land of Bhopal learnt the lessons from the World’s worst Industrial
disaster? From the author’s perspective, a lot remains to be done in the realm
of process safety to ensure that another Bhopal does not occur in India.
Specifically, the following needs to be done in the areas of legislation and
initiatives by the industry:
1. Legislation:
The implementation of a Process Safety Management System
based on PSM standards developed must be made mandatory for
all industries covered under the Chemical Accidents (Emergency
Planning, Preparedness and Response Rules), 1996 . The
standards must learn from the experience of the OSHA of USA
and include the management of chemical reactivity hazards.
Security risk analysis should be made mandatory under the PSM
standard.
The enforcement of legislation by the Indian authorities must be
made effective by training the law enforcers in the latest
developments in risk prevention, inspection and management
system audit techniques.
The Regional Labour Institutes who impart training for Safety
Officers employed in hazardous industries should include
Process Safety Management and reactive chemical hazards in
their curriculum.
Specialised training in Chemical disaster management should be
made mandatory for all members of the four tier crisis groups
formed under the Chemical Accidents (Emergency Planning,
Preparedness and Response Rules), 1996. Refresher training
program for the members on latest crisis management techniques
must be implemented.
Policies for handling media communication during crisis
management should be developed for the four crisis groups
formed under the Chemical Accidents (Emergency Planning,
Preparedness and Response Rules), 1996. Training on
“communicating during emergencies” should be made mandatory
to the personnel of the crisis committees.
10
The safety regulations governing employment of contractors in
hazardous chemical plants need to be strengthened.
The Government operated Technical Training Institutes should
include Process Safety Training for those personnel who will be
employed in Chemical plants.
2. Industry Initiatives:
2.1 A system to update and maintain Process Safety Information
needs to be implemented
2.2 Contractor safety management systems must address the
enforcement and accountability of contractors in the safety of
their workers. The safety training requirements for contractors
working in hazardous areas of the plants must be defined and the
contractor should be held accountable for the safety performance
of his employees.
2.3 Management of Change initiatives in the industry should focus
on changing the attitudes of line management, assessing risks
when reducing manpower and management of knowledge
associated with the changes.
2.4 In large organizations, training of operators using simulators
should be practiced for control room operators.
2.5 The investigation of incidents should account for human factors
also. Sharing of the lessons learnt from Chemical Plant Incidents
should be carried out through an Industry – Government
initiative.
2.6 The tracking of process safety performance should be made as
part of the industry’s voluntary reporting to public.
2.7 Industry – Institution interaction should be strengthened in the
areas of pilot plant studies and refresher courses for employees in
process safety management need to be provided.
References:
Indian Chemical Manufacturers Association website www.icma.org
KPMG and Chemtech foundation, 2003: “The Indian Chemical
Industry – NewDirections, New Hope”
11
Table 1:
Chemical Incidents in India after Bhopal
Location Year Origin Chemical Number of
of involved Deaths Injured Evacuated
incident
Hexacyclo-
Cochin 1985 Release - 200 -
pentadiene
Sulphuric
New Delhi 1985 Release 1 340 >10
acid
Fire in
Bombay 1988 Oil 35 16 -
refinery
Bhatinda 1989 Leakage Ammonia - 500 -
Ethane and
Nagothane 1990 Leakage 32 22 -
propane
Leakage
Calcutta 1991 from a Chlorine - 200 -
pipeline
Vishakhaptna Refinery
1997 LPG 60 31 150000
m fire
Explosio
Vellore 2003 Explosives 25 3
n
Mohali 2003 Fire Not known 4 25 -
Not
Cochin 2004 Fire Toluene - -
known
12
