MANAGEMENT OF OCCUPATIONAL SAFETY AND HEALTH AT UNIT LEVEL
This Chapter, as is evident, deals with the management of occupational safety and health at the unit level, i.e. manufacturing units. The state has a total of 586 manufacturing units, the break-up of which according to factories registered under Section 2(m), Section 85 of the Factories Act, 1948 is given in Chapter-4. In order to have a fair idea, about the safety and health status in these units, the following aspects on safety and health have been converted under this Chapter:
7.1 Safety Policy
7.2 Appointment of Safety Officers
7.3 Safety Committee
7.4 Occupational health centers (FMO, Ambulance)
7.5 Welfare (WO, Canteen, Crèche, Lunch Room, Shelter, etc.)
7.6 On-site Emergency Plans
7.7 Safety Reports
7.8 Safety Audits
7.9 HAZOP Studies
There are certain statutory requirements as provided under the Factories Act, 1948 and Rules framed thereunder, for each of the aspect stated above. Items 7.6 to 7.9 are additional requirement exclusively applicable to MAH installations which are covered by separate set of rules. Each of aspect with its status has been discussed in the following paragraphs.
7.1 SAFETY POLICY
The Rule 90(B) of the Goa Factory Rules, 1985, amended (1990) framed under the provisions of Sections 7A(3), 41-B(2) and 112 requires preparation of a written statement of policy in respect of health and safety of workers at work by the factories meeting the following criteria:
a) Units covered under Section 2(m)(i) of the Factories Act, 1948 and employing more than 50 workers.
b) Units covered under Section 2(m)(ii) of the Factories Act, 1948 and employing more than 100 workers.
c) Units covered under Section 87 of the Factories Act, 1948.
d) Units covered under Section 2(cb) of the Factories Act, 1948.
In addition to the above, the Chief Inspector may require the occupier of any of the factories or class or description of factories to comply with the above requirements of Safety Policy if in his opinion it is expedient to do so.
As per the details available 356 units were required preparation of Safety Policy. However, only 24 units have prepared the Safety Policy which is about 6.74% of the total requirement.
7.2 APPOINTMENT OF SAFETY OFFICERS
As per the provisions of Section 40-B of the Factories Act, 1948, Safety Officer is required to be appointed for the units meeting the following criteria:
7.2.1 (a) Units employing more than 1000 workers,
(b) Wherein in the opinion of the State Government, any manufacturing process or operation is carried on involving any risk of bodily injury, poisoning or diseases or any hazard to health.
As per the details available, 4 Safety Officers were required to be appointed in the units in the State. As against this, 10 Safety Officers were appointed in various units.
7.3 SAFETY COMMITTEE
The Rule 90 of the Goa Factory Rules, 1985 framed under the provisions of Section 41 and 41-G of the Factories Act, 1948 requires constitution of Safety Committee in the factories meeting the following criteria:
a) Units employing 250 or more workers.
b) Units covered under Section 87 of the Factories Act, 1948 and employing more than 50 workers.
c) Units covered under Section 2(cb) of the Factories Act, 1948 and employing more than 50 workers.
As per the information available, 210 units have constituted Safety Committees.
7.4 OCCUPATIONAL HEALTH CENTERS
As per Rule 90(O) of the Goa Factory Rules, 1985 amended (1990) prescribed under Section 41-C of the Factories Act, 1948, Occupational Health Centers are required to be set up in the factories carrying on ‘hazardous process’ as described under Section 2(cb) of the Act. The industries have been divided into 3 categories, i.e. the industries employing up to 50 workers, employing 51 – 200 workers and employing more than 200 workers. No information is available regarding requirement and establishment of Occupational Health Centers in factories. However, in 2 factories submitting complete annual returns, ambulance rooms have been set up.
This part of the Chapter deals with the Welfare facilities, e.g. appointment of Welfare Officers, crèche facilities, canteen facilities, shelters, rest room and lunch room.
As per the provisions of Section 49 of the Factories Act, 1948, any factory employing more than 500 workers, is required to employ a Welfare Officer. As per the details available 3 units were required to appoint the Welfare Officers. However, 3 units have actually appointed the Welfare Officers.
As per the provisions under Section 48 of the Factories Act, 1948, any factory employing 30 or more women workers are required to provide crèche facilities for the use of children below the age of 6 years for the women employees. There are certain requirements under the Section for these crèches which are to be met by the occupier of the factory. In total 53 units are required to provide crèche facility and out of these only 2 units have provided the crèche facilities.
As per the provisions under Section 47 of the Factories Act, 1948, any factory employing more than 150 workers is required to provide adequate and suitable shelters or rest rooms and lunch rooms for the use of the workers employed.
As per the details available 34 units have provided the shelters or rest rooms and lunch room facilities.
As per the provisions under Section 46 of the Factories Act, 1948 any factory employing more than 250 workers is required to provide canteen facilities for the use of workers.
As per the details available, 48 units have provided canteen facilities.
As stated earlier, items 7.6 to 7.9 are the additional items exclusively applicable to Major Accident Hazard units. There are a total of 10 working MAH units in the state. The statutory requirement for the units are covered by “The Goa Control of Major Industrial Accident Hazard Rules, 1993, as amended in 1999”.
7.6 ON-SITE EMERGENCY PLANS
As per the provision under “The Goa Control of Major Industrial Accident Hazard Rules, 1993, as amended in 1999”, an occupier who has control of the industrial activity, as described under the Rule, shall prepare an On-site emergency plan detailing how major accidents will be dealt with on the site on which industrial activity is carried on.
As per the information available 10 number of MAH installations were required to prepare the on-site emergency plan. All the 10 MAH installations have prepared the plans and submitted to the Chief Inspector of Factories and Boilers.
7.7 & 7.8 SAFETY REPORTS AND SAFETY AUDITS
As per the provisions under “The Goa Control of Major Industrial Accident Hazard Rules, 1993, as amended in 1999”, it is mandatory for an occupier to prepare and submit to the Chief Inspector before the commencement of an industrial activity, the Safety Report of the industrial activity to which these rules apply. The Safety Report is to be submitted in the prescribed format. Further it is advisable that all the units after the commencement of the industrial activity shall carry out an independent Safety Audit of the respective industrial activities with the help of an expert not associated with such industrial activities. This will help the management to know the weak points in their system and to take suitable timely remedial measures.
As per the information available, 4 numbers of units were required to prepare Safety Report and all the 4 units have prepared the Safety Report and submitted to the Chief Inspector of Factories & Boilers. Further, 4 units have carried out safety audit and submitted reports to the Chief Inspector of Factories and Boilers.
7.9 RISK ASSESSMENT STUDIES
The HAZOP Studies, i.e. the Hazard and Operability studies are carried out in advance on any plant to examine the process or at least the relevant parts of the process to discover how deviation from the intention of design can occur to decide whether such deviations can give rise to hazardous conditions.
The technique aims to simulate the imagination of designer in a systematic way and is useful in identifying potential hazards in advance and allow the user to take corrective measures.
However, no information is available about the units which have conducted risk assessment studies.