EPSILON CARBON PRIVATE LIMITED DOC.

NO: ECPL/SMS&PSM/SS/00

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1 Purpose
Hazard Identification and Risk Assessment (HIRA) is a collective term that encompasses all activities
involved in identifying hazards and evaluating risk at facilities, throughout their life cycle, to make
certain that risks to employees, the public, or the environment are consistently controlled within the
organization’s risk tolerance. This standard is established to provide a formal process for hazard
identification, risk assessment and control to effectively manage workplace Occupational Health &
Safety hazards within the facilities of ECPL.

2 Scope
This document details the procedures related to identification of hazards, evaluation of the risk
associated and bring the risk to acceptable level through implementation and sustainment of the
control measures. This procedure is applicable for all manufacturing sites of Epsilon Carbon Private Ltd,
Toranagallu.

3 Responsibility
Job position

Employee Line Element Site Safety

Activities Champion HOD Site Head
concerned Manager Head

Identifying the routine and non-

C R C A R I
routine activity

Preparing the schedule for HIRA I R C A C I

Carry out HIRA as per the plan I R C A C I

Completion of recommendation I R C A R R

Updating HIRA register I R C A R I

Audit for compliance I R R C R A

R: Responsible A: Accountable C: Consulted I: Informed

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3.1 HODs
They are responsible for: -
3.1.1 Reviewing HIRA for their respective departments.
3.1.2 Ensure legal requirement are fulfilled
3.1.3 Ensure review HIRA register at least twice in a year. (Preferably – June & December)
3.1.4 Re-evaluation of HIRA, status of objectives, targets, status of safety management
programs (SMPs) at least once in 6 months (June & December)
3.1.5 Identification of any new/ modified or changed environmental aspect & associated
impact within/ outside the company & include in the register of environmental aspects-
impacts & communicate the same to concerns.
3.1.6 Re-evaluation of HIRA & addition of new hazards should consider following inputs:
Past accidents/incidents. New or modified activities or processes (Eg., New M/c
installation, construction), New product introduction, change in legal requirements,
results of audits etc.
3.1.7 Constitution of Core team and appointment of team leader.
3.1.8 Initiating the HIRA activities.
3.1.9 Ensuring that Risk Register are reported to ECPL Corporate, as required.
3.1.10 Ensure the implementation of control measures.
3.1.11 Ensure identified hazards in the work environment are reported to the HES Team.
3.1.12 Ensure a current HES risk register is maintained for the site, location, project or activity
undertaken in their area of responsibility.---What is the mechanism
3.1.13 Regularly monitor and review the effectiveness of controls and implement corrective
actions and treatment plans where required in their area of responsibility.
3.2 Human Resources
3.2.1 Provide/ Arrange training / awareness to employees for Hazard’s Identification and Risk
Assessment.
3.3 Site HES in charge
3.3.1 Coordinate HIRA activities at the site.
3.3.2 Carry out workplace monitoring activities to verify the implementation of the HIRA.
3.3.3 Provide support on the implementation and application of this procedure.
3.3.4 Maintenance of Risk registers.
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3.4 Employees
3.4.1 All employees have a responsibility to participate in the HIRA activities.
3.4.2 All employees shall be aware about Hazard associated with the activities and control
measures.
3.5 HIRA Core Team///Who are the core team members
3.5.1 Conduct HIRA as per the plan.
3.5.2 Seek for resources to complete HIRA.
3.5.3 Evaluate the risk and existing control measures.
3.5.4 Recommend additional control measures, if any.
3.5.5 Develop a reliable Risk Register.
3.5.6 Determine corrective measures;
3.5.7 Compliance Requirement, time frame and distribution to key duty holders, who shall be
responsible to implement;
3.5.8 Documents and records keeping;

4 Reference
1. ISO 45001 – Occupational health and safety management systems
2. IS/ISO 31000 – Risk Management – Principles and Guidelines
3. ISO 12100:2010 – Safety of machinery — General principles for design — Risk assessment and risk
reduction
4. IS 15656: Hazard Identification and Risk Analysis – Code of Practice
5. HSE UK – Managing risks and risk assessment at Work
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5 Definition & Abbreviations
5.1 Definitions
5.1.1 Hazard: Source or situation that could result in harm in terms of human injury or ill
health, damage to environment, property or the workplace or combination of these.
5.1.2 Hazard Identification: Process of recognizing that a hazard exists and defining its
characteristics.
5.1.3 Severity: A measure of the possible consequences of a hazard.
5.1.4 Risk: Combination of the likelihood and consequence(s) of a specified hazardous event
occurring.
5.1.5 Risk Assessment: Process of evaluating the risk(s) arising from a hazard(s), taking into
account of adequacy of any existing controls, and deciding whether or not the risk(s) is
acceptable
5.1.6 Risk register: A risk register is a comprehensive document that compiles all potential
risks in the facility, helps to prioritize those risks and track the completion. It gives clear
picture of risk (and potential consequences) to the management as well as to the
operating team.
5.1.7 Ill health: Identifiable adverse physical or mental condition arising from and/or made
worse by a work activity and or work-related situation.
5.1.8 Incident: Work related event(s) in which an injury or ill health or fatality occurred, or
could have occurred.
5.1.9 Occupational Injury: Injuries that occur at workplace due to organization activities to
either of employees, contractors, visitors. Injury is an instantaneous effect.
5.1.10 Occupational Illness: A disease or Illness caused by repeated or prolonged exposure to a
workplace hazard as well as acute & chronic illness or diseases caused by inhalation,
ingestion, absorption or direct contact
5.2 Abbreviations
ECPL : Epsilon Carbon Private Limited
HES : Health Environment Safety
HIRA : Hazard Identification and Risk Assessment
HOD : Head of the Department
ISO : International Organization for Standardization
OHS : Occupational Health and Safety
PPE : Personal Protective Equipment
6 RACI : Responsible, Accountable, Consulted, and Informed Interface with other
element
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WI
II MOC

HIR
PSI A PSSR

SOP Trg

The HIRA element interfaces significantly with other SMS/PSM program elements. The primary
interfaces include the following:

Workforce Involvement: HIRA are one of the primaries means to foster employee participation in
the SMS/PSM program as personnel serve as HIRA team members.

Process Safety Information (PSI): Knowledge/information should be reviewed for accuracy and
updated, if necessary, prior to a HIRA. HIRA teams use this information to understand and assess
process hazards and controls.

Operating Procedures: The significant hazards identified in a HIRA are often included in the
operating procedures as warnings, cautions, or safe operating limits. Procedures are often used
during PHAs to understand the operation being assessed.

Training: The training program for operators and other personnel should include information on the
hazards identified in the HIRA.

Management of Change: HIRA, while not mandatory, may be performed to assess the impact of a
proposed change on process safety. Resolution of recommendations made during a HIRA may
require use of the MOC process. MOC forms are often reviewed during HIRA revalidations.

PSSR: PSSR review activities require HIRA for new processes.

Incident Investigation (II): HIRA are sometimes performed as part of or as a result of the
investigation process for a process safety incident. Incident investigations are reviewed during HIRA
revalidations.
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7 Procedure
7.1 General Requirements
7.1.1 The HIRA shall be carried out, but not limited to the following activities:
[Link] Routine and non-routine Operations and Maintenance activities.—What about
potential emeregcny, abnormal activities
[Link] Operations, Products and services originated from ECPL unit activities that have
control and/or over which it can be expected to have potential emergency
situations inside and or outside the premises.
[Link] Activities with applicable regulatory requirements.
[Link] Activities of all personnel having access to the workplace (including sub-
contractors and visitors). ---Mechanism to access
[Link] Potential external hazard sources and events which is not under the control of
ECPL management.
7.1.2 Identified risks shall be evaluated using the approved Risk Level. The evaluation criteria
and results shall be documented. In case gaps against applicable legislation,
requirements, standards, codes or practices with respect to OHS are identified, a
documented decision shall be taken on the corrective actions providing evidence that
activities can be continued with an acceptable risk level and legally compliant.
7.1.3 Every effort shall be made to bring the Risk to acceptable levels.
7.1.4 Risk Assessment shall be conducted by personnel who are trained for the selected
methodology.
7.1.5 Risk Assessment team shall be provided with necessary resources and access to relevant
document required for conducting Risk Assessment exercise.
7.1.6 Results of Risk Assessment studies shall provide input to the setting of ECPL OHS
objectives, requirements/ improvements of operational controls and identification of
needs for training and/or instructions.
7.1.7 All High-Risk activities and activities with legal implications shall be considered as
“Significant Risks” and a “Management Program” shall be developed. Such Management
Programs shall have provisions to document Short Term Control and Long-Term Control
with fixed timelines for implementation.
7.1.8 Actions resulting from Risk Assessment studies, their scheduled completion dates and the
completion of actions shall be recorded.
7.1.9 The implementation of the identified prevention, risk reduction and control measures,
and resulting changes shall follow Management of Change procedure.
7.1.10 Risk Assessment for the section/activity shall be revisited after any incidents with a
potential over and above Near Miss.
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7.2 HIRA Methodology
7.2.1 Identification of Workplaces or Activities
[Link] Each plant should identify all routine (day to day activities like start-up, shut-
down, cleaning, setting, operating, loading, unloading, pay-off, take-off, drum
movement) and non-routine (infrequent activities like breakdown, change-over,
preventive maintenance, wire breakage, leakage, spillage, emergency)
operational activities, posing potential OHS risks as well as related workplaces.
This has to include activities by contractors, truck drivers, surveyors, visitors and
other third parties, since they can interfere with and influence the operational
activities.
[Link] It is recommended that all the defined activities (Routine & Non – Routine) are
listed and broken down into separate work steps.
[Link] Mark the activities that may lead to emergency situations.
7.2.2 Identify Hazards
[Link] In consultation with workers identify all potentially hazardous activities or
situations that may cause harm. In general, hazards are likely to be found in the
following;
a. Physical work environment,
b. Equipment, materials or substances used,
c. Work tasks and how they are performed,
d. Work design and management
[Link] In order to identify hazards, the following are recommended:
a. Past incidents/accidents shall be examined to see what happened and
whether the incident/accident could occur again.
b. Employees shall be consulted to find out what they consider are safety issues,
i.e., ask workers about hazards, near misses they have encountered as part of
their work. Sometimes a survey or questionnaire can assist workers to
provide information about workplace hazards.
e. Work areas or work sites be inspected or examined to find out what is
happening as-on date. Identified hazards should be documented to allow
further action. The work environment, tool and equipment as well as tasks
and procedures should be examined for risks.
f. Information about equipment (e.g., operating instructions, maintenance
instruction etc.) and Safety Data Sheets be reviewed to determine relevant
safety precautions.
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g. Brain storming sessions on what could go wrong takes place, i.e., what
hazardous event could take place here?
[Link] Checklist attached in Annexure 1 to be followed for Hazard Identification.
7.2.3 Risk Assessment
[Link] Risk assessment involves considering the possible results of someone being
exposed to a hazard and the probability of this occurrence. A risk assessment
assists in determining:
a. Risk Level
b. Whether existing control measures are effective
c. What action should be taken to control a risk
d. How urgently action needs to be taken.
[Link] A risk assessment should include:
a. Identify factors that may be contributing to the Hazard,
b. Review health and safety information that are reasonably available from an
authoritative source and are relevant to the particular hazard,
c. Evaluation of how a hazard may cause harm: This includes examining how
work is completed, whether existing control measures are in place and
whether they control the harm, looking at standard operating situations as
well as infrequent emergency situations. A chain of events related to a hazard
may need to be considered. Emergency situation may be defined as “an
unplanned event that may adversely impact or threaten life, health or
property on a large scale at one or more locations within the Factory or Office
premises, and control of the incident would require specialists and external
supports”).
d. Evaluation of the severity: This includes looking at the types of
injuries/illnesses/harm/damage that can result from the hazard, the number
of people exposed, possible chain effects from exposure to the hazard.
Severity (S): Describes the degree of injury or ill health or property damage
due to hazardous event/exposure.
e. Determine the probability: The level of risk will increase as the probability of
harm and its severity increases. The probability of harm occurring may be
affected by how often the person is exposed to the hazard during the task, in
what conditions, how many people are exposed to the hazard and for what
duration. Likelihood (L): Describes the probability (frequency/occurrence) of
hazardous event or exposure.
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f. The Severity and Probability Matrix outlines the 5-point criteria (from 1 to 5)
to perform the assessment,
g. Once the probability and severity of hazard have been determined, Risk
Rating is calculated as Risk Rating = Probability x Severity. Using the Risk
Evaluation Matrix (Refer Annexure 3), the overall Inherent Risk Rating can be
determined (based on the Severity rating against likelihood rating).
[Link] Legal Requirement: Risk associated with any hazard which is an obligation
under any applicable OHS Acts/Rules from time to time is evaluated as follows-
a. Ensure all legal requirements (If present) are captured for the hazards
identified.
b. If the Legal Requirement is complied, mention the measures taken in the
current control and consider hazard as Acceptable.
c. If Legal Requirement is not complied, then risk is “Not Acceptable”.
7.2.4 Risk Categorization
[Link] After identification of the Hazard, Consequence and Risk Rating, the next step of
the Risk Assessment involves categorization of risk.
[Link] The Risks are categorized as Low Risk, Medium Risk and High Risk with respect
to the risk rating.
[Link] Note: Irrespective of risk rating, if severity is 4/5, it shall be considered as high
risk. (Refer Annexure 3)
7.2.5 Risk Treatment
Risks shall be reduced to the lowest reasonably practicable level by taking preventative
measures, in order of priority as per the hierarchy of control. The list below sets out the order
to follow when planning to reduce risks identified in the workplace.
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[Link] Elimination: Elimination of process / dangerous operation, reorientation of
work place, machines etc. so as to eliminate the hazards.
[Link] Substitution: Alteration/modification/replacement of machine, tolls, substances
etc. so as to minimize/reduce the risk
[Link] Engineering Control: Automation, robotic operations, safety guards, limit
switches etc. Controls here are inbuilt with machine (mostly mechanical / alert /
emergency indicators) to avoid contact of hazard and human.
a. Redesign - Jobs and processes can be reworked to make them safer. For
example, containers can be made easier to hold and lift.
b. Isolation - If a hazard cannot be eliminated or replaced, it can sometimes be
isolated, contained or otherwise kept away from workers. For example, an
insulated and air-conditioned control room can protect operators from a
toxic chemical.
c. Automation - Dangerous processes can be automated or mechanized.
d. Barriers - A hazard can be blocked before it reaches workers. For example,
Proper equipment guarding to protect workers from contacting moving parts
e. Absorption - Baffles can block or absorb noise. Lockout systems can isolate
energy sources during repair and maintenance. Usually, the further a control
keeps a hazard away from workers, the more effective it is.
f. Dilution - Some hazards can be diluted or dissipated. For example, ventilation
systems can dilute toxic gasses before they reach operators.
[Link] Administrative Control: Safety signs, hazardous area marking, photo-
luminescent signs, markings for pedestrian walkways, warning sirens/lights,
alarms, safety procedures, equipment inspections, access controls, safe systems
of working, tagging, and work permits, etc.
a. Safe work procedures - Workers can be required to use standardized safety
practices. The employer is expected to ensure that workers follow these
practices. Work procedures must be periodically reviewed with workers and
updated.
b. Supervision and training – Initial training on safe work procedures and
refresher training should be offered. Appropriate supervision to assist
workers in identifying possible hazards and evaluating work procedures.
c. Job rotations and other procedures can reduce the time that workers are
exposed to a hazard. For example, workers can be rotated through jobs
requiring repetitive tendon and muscle movements to prevent cumulative
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trauma injuries. Noisy processes can be scheduled when no one is in the
workplace.
d. Housekeeping, repair and maintenance programs - Housekeeping includes
cleaning, waste disposal and spill clean-up. Tools, equipment and machinery
are less likely to cause injury if they are kept clean and well maintained.
e. Hygiene - Hygiene practices can reduce the risk of toxic materials being
absorbed by workers or carried home to their families. Street clothing should
be kept in separate lockers to avoid being contaminated by work clothing.
Eating areas must be segregated from toxic hazards. Eating should be
forbidden in toxic work areas. Where applicable, workers should be required
to shower and change clothes at the end of the shift.
[Link] Personal Protective Equipment (PPE): Safety glasses, hearing protection, face
shields, safety harnesses and lanyards, respirators, and gloves. PPE and clothing
are used when other controls measures are not feasible and where additional
protection is needed. Workers must be trained to use and maintain equipment
properly. The Management and workers must understand the limitations of the
personal protective equipment. Facility is expected to require workers to use
their equipment whenever it is needed. Care must be taken to ensure that
equipment is working properly. Otherwise, PPE may endanger a worker’s health
by providing an illusion of protection.
7.2.6 Monitoring & Review (Risk Tolerance)
[Link] A risk register shall be maintained at the plant. Refer Annexure 2 for the format.
[Link] The threshold level of risk exposure which, when exceeded, shall trigger an
escalation to bring the situation to the attention of senior management. All
high risks shall be escalated to Corporate HES for review and monitoring.
[Link] Low & medium risks shall be managed and monitored at team level, any risks
of concern even if not scoring as a High risk can be highlighted to the Corporate
HES for escalation and support.
[Link] At site level/ function level, the Risk Registers shall be reviewed and if necessary
updated once in every year or it shall also be reviewed and updated in case of
new issues related external and internal context and the Corporate HES shall
review the registers on quarterly basis.
[Link] In addition to above, the risk register will also be reviewed and revised, if
necessary, by concerned HOD/HIRA core group member, in the event of:
a. Changes in legislation/ regulations/ notifications/directions
b. Changes in Process method
c. Revision / Addition of new process method / restructuring
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d. Any major change of activity from one area to other
e. Change of equipment / newly installed equipment
f. Addition of new service
g. Introduction of new suppliers / contractors / Material
h. Incidents / actual or potential emergency situation occurring
i. Audit findings / Observations
j. Management Review proceedings
k. Interested party concerns received through internal / external
communication

7.3 Personnel and Skills

7.3.1 The Risk Assessment shall be carried out by a multi-disciplinary HIRA team. The minimum
composition includes team consisting of:
[Link] Plant/Area Manager - HIRA Leader
[Link] Area supervisor (Executive/Officer/shift in charge)
[Link] Operator / Technician / E&M
[Link] Engineering person (Civil, Mechanical, Electrical, Instrumentation, Process)
[Link] HES Executive
7.3.2 The minimum skills required are:
[Link] In-depth understanding of the process and operations
[Link] Minimum experience of 2 years working in the industry.
7.4 Timing & Frequency
7.4.1 HIRA shall be carried out / reviewed a minimum of twice in a year even if there is no
change in the Process (Chemical/Equipment/Individual).
7.5 Communication
7.5.1 Risk assessments must be consultative in nature, and the results of risk assessments
communicated to all affected personnel.
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8 Key Performance Indicator

S. No. Description

1 Awareness program on HIRA

2 Develop and update Risk register

3 Review of HIRA after incidents

4 Review of HIRA once in every year

5 HIRA completion status

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9 Annexure

Annexure 1: Checklist for hazard identification

Annexure 2: Risk Register Template

Annexure 3: Risk Evaluation Matrix

Annexure 4: HIRA sample