MANAGEMENT OF OCCUPATIONAL SAFETY AND HEALTH AT UNIT LEVEL

 

This chapter deals with the management of occupational safety and health at the unit level, i.e. manufacturing units. The state has a total number of 9341  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-3..  In order to have a fair idea, about the safety and health status in these units, the following specific provisions on safety and health have been covered under this chapter: -   

 

6.1       Safety Policy

6.2       Appointment of Safety Officers

6.3       Safety Committee

6.4       Occupational Health Centers (FMO, Ambulance)

6.5       Welfare (WO, Canteen, Crèche, Lunch room, shelter etc.)

6.6       On-site Emergency Plans

6.7       Notification of site and Safety reports

6.8       Safety Audits

6.9       Off-Site Emergency Plan

6.10         Industrial Hygiene Laboratory

 

There are certain statutory requirements as provided under the Factories Act, 1948, and Rules framed there under, for each of the aspects stated above. Items 6.6 to 6.9 are additional requirement exclusively applicable to MAH installations, which are covered by separate set of rules.  Each of the aspect with its status has been discussed in the following paragraphs. 

 

6.1       HEALTH AND SAFETY POLICY  

The provision for the preparation of Health & Safety Policy is mandatory for factories covered under section 2(cb) and factories declared dangerous under section-87 of The Factories Act, 1948 employing more than 50 workers. Government of Rajasthan has incorporated the rule in this regard in Rule-65 MM under section 7-A(3) and section 41-B(2) of The Factories Act, 1948.  The provisions regarding the contents, as to what the policy specifically deal with have been clearly spelt in these rules. Number of factories covered under Section 2 (cb) and Section 87 are 822 and 692 respectively in the State. The managements of such factories have been directed by Chief Inspector of Factories and Boilers to formulate their Health and Safety Policies as per statutory requirements. All MAH installations in the State of Rajasthan have formulated their Health & Safety Policy on priority basis.

 

6.2       APPOINTMENT OF SAFETY OFFICERS

Under section 40-B of The Factories Act, 1948, and Rajasthan Factories Rule 64B, the qualifications, duties and other service conditions of the Safety officers to be appointed in the factories are stipulated.  The State Government by subsequent notification required the occupiers of the factories employing 1000 or more workers to appoint requisite number of Safety Officers. It is also required that  the occupiers of factories covered under Rajasthan,  Control of Industrial Major  Accident hazard (CIMAH ) rules, 1999  & plants manufacturing Sulphuric acid employing less than 1000 workers and wherein involvement of risk of bodily injury, poisoning or disease or any hazard to health may occur, will employ one Safety Officer.

 

The present compliance is 100%. As  all the required  54 number of safety officers have been appointed however records of qualification of  all the safety officers is not made available.

6.3       SAFETY COMMITTEE  

Rule 65 J of the Rajasthan Factory Rules, 1951 framed under the provisions of Section 41 and 41-G of The Factories Act, 1948, require constitution of Safety Committee in the factories meeting the following criteria:-

 

a)         Factories employing 250 or more workers

b)         Factories covered under Section 87 of The Factories Act,1948 ( Amended 1987), and employing more than 50 workers

c)         Factories covered under Section 2(cb) of The Factories Act, 1948, and employing more than 50 workers  275 number of safety committees have been constituted in the factories of the state.

 

6.4       OCCUPATIONAL HEALTH CENTERS

 

As per Rule 65T of the Rajasthan Factory Rules, 1951 framed under the Section 41-C of The Factories Act, 1948, Occupational Health Centres are required to be set up in the Factories carrying out   ‘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.  

 

Compliance of establishment of OHC in the state is 100%.

 

6.5      WELFARE

 

This part of the Chapter deals with the Welfare facilities e.g. appointment of Welfare officer, crèche facilities, canteen facilities, shelters, rest room and lunch room. 

 

The provisions of Section 49 of The Factories Act, 1948, stipulates that any factory employing more than 500 workers is required to employ a Welfare Officer. The State Government has also incorporated in Rajasthan Factory Rule 1951 wherein age, qualification, duties and responsibilities and other service conditions are prescribed. All the required number of the welfare officers is appointed in the state. The number of canteens and crèches in the factories of the state are 160 and 21 against required number 161 and 22 respectively.

 

 

MAJOR ACCIDENT HAZARD CELL

In order to control the major accidents in the State, factories prone to major accident hazards have been identified on the basis of the Rajasthan Factories  Rules 1951, Control of Industrial Major Accident Hazard (CIMAH) Rules, 1999 under section 41-B of The Factories Act, 1948 and Manufacture Storage and Import of Hazardous Chemicals Rules, 1989 (amended 2000), wherein specified industrial activities are categorised as potentially hazardous and prone to major hazard, in the form of storage & use of potentially hazardous substances in five groups exceeding the threshold quantities specified for them in schedule-3 of the above said rules. On the basis of the criteria laid down in the above mentioned, so far 98 factories have been identified as Major Hazard installations in the State.

 

The identified MAH installations are required to comply with specific provisions of the above mentioned rules, such as submission of Notification of Site/Safety Report; Preparation of On-Site Emergency Plan; Material safety Data Sheet; Notification of Major Accidents; and carrying out Safety Audit etc, in the respective schedules specified in the above rules.

 

The on site emergency plans received in the Inspectorate Factories and Boiler  Directorate are subject to scrutiny by a multidisciplinary cell constituted at the head quarter of the inspectorate. Thereafter these on-site plans are sent back to the Occupiers of the concerned factories with directions for further improvement and rehearsal.

 

In the said rules it has also been made essential for the factories to rehearse the On Site Emergency plan once in every six months, so that state of preparedness; is ascertained in terms of men and machines when a disaster strikes.  Practical exercises are, therefore, carried out be creating situations, as close as possible to actual conditions.  The occupiers are directed to remove the weaknesses and vulnerabilities which surface during such simulation drills.  The standard of performance is judged against a set of criteria fixed for this purpose through a checklist assessment by the regional officers.

 

6.6       ON-SITE EMERGENCY PLAN

 

As per the provisions of Rule 65Q of Rajasthan Factories Rules 1951, Control of Industrial Major Accident Hazard (CIMAH) Rules, 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. All 98 MAH units have prepared and submitted these plans to the Inspectorate.

 

All the On Site Plans are being regularly monitored and updated as per the guidelines, which have been circulated to the occupiers so that the plans prepared have a similarity and in the event of emergency these could be easily referred for retrieval of necessary information. The guidelines stipulate all vital information and commitments to not only control the major accidents, but to mitigate the effect in the event of any catastrophe, which includes:

 

-          Preventive measure and plans effecting the factory's safety status currently enforced/practiced and disclosure of information to workers and public and details of public awareness system in existence or anticipated;

-          Development of scope and scenarios on the basis of previous histories and consequence analysis;

-          Material safety data sheet and important components of safety report;

-          Disaster control measures including mutual aid scheme;

-          Plan of coordination and interaction with various external agencies including administrative agencies in the event of major risk occurrence;

-          Action on site;

-          Plans of action for medical management, fire fighting, rescue and relief operation currently available and to be pressed into service at short notice; and much other general information in respect of plant, manufacturing process, neighbourhood, meteorological information etc.

 

6.7  Safety Report

 

As per the provisions of the Rule-10 (1) of Manufacture Storage and Import of Hazardous Chemicals Rules, 1989 ( Amended 2000), 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. 

 

As per information available 20 no. of factories were required to prepare Safety Reports out of which 18 units have prepared such reports and submitted to the the Chief Inspectorate.

 

6.8       SAFETY AUDIT

 

Safety audit is a statutory requirement under the Manufacture, Storage and Import of Hazardous Chemical, Rules (MSIHC) 1989 for upper layer of major accident hazard units. According to the provisions of the Rule-10 (4) of Manufacture Storage and Import of Hazardous Chemicals Rules, 1989 it is mandatory for an occupier to conduct the Safety Audit of industrial activity once in a year with the help on an expert not associated with such industrial activity.

 

The objectives of the safety audit would be  to review  &  critically  assess the existing safety  programmes  to prevent  & control  the hazards in  the   plant  with  a  view  to  suggest  improvement  . The benefit of safety audit is to evaluate the quality & effectiveness of the safety programme, rather than only  quantitative measures of its failure.

 

The  specific  objectives  of  the  safety  audit  would  be :-

 

·        To  study  existing  systems  procedures  plants &  programmes on safety & health;

·        To review implementation  status of the existing safety systems, procedures, plans & programmes; and

·        To recommend the measures for improving  effectiveness for implementation of safety  systems ,procedures, plans and programmes  and also  for improving the existing  procedures/setting  of  new  procedures if  required .

 

The  overall methodology of  safety audit  will consist  the following  stages :-

 

·        Collection of  preliminary information  regarding  manufacturing  process &  hazards etc. through  a  questionnaire developed  by  auditor  before undertaking actual field work.

·        Examination of documents pertaining to Safety procedures/systems.

·        Discussions with key personnel at various levels.

·        Physical inspection of the plant.

·        Preparation of report with recommendations.

 

The scope of the audit is to verify whether the Planned and Documented activities are performed in accordance with written procedures and to verify by examination and evaluation of objective evidence that appropriate elements of a safety management systems have been developed, documented and implemented by units covered under The Manufacture Storage and Import of Hazardous Chemicals Rules, 1989 under The  E.P. Act, 1986.

 

As per IS-14489-1998 some of the relevant points observed during safety audit are being listed below:

 

1.      Health and Safety Policy

2.      Accident Reporting, Investigation and Analysis

3.      Safety Education and Training

4.      Work Permit System

5.      Personal Protective Equipment (PPE)

6.      Emergency Preparedness ( On-Site and Off-Site both)

7.      Compliance with statutory

8.      New Equipments/Process review and inspection system

9.      Prevention of Occupational disease

1.      Safe operating procedure

2.      Fire prevention, protection and fire fighting system

     

 

Safety audit of 20 factories is required to be conducted out of which 18 have done it and reports submitted to the Inspectorate. The recommendations pointed out by the auditor, are being enforced by the Inspectorate by issuing the directions/guidelines from time to time within stipulated period..

 

6.9       OFF-SITE EMERGENCY PLAN

 

The  Rajasthan Control of Industrial Major  Accident Hazards (CIMAH) Rules, 1999 under The Factories Act, 1948  clearly indicates that under Rule 13 or sub-rule (2) of this rule 14(3),the District Magistrate or the District Emergency Authority shall provided with  the information for preparation of the Off Site emergency Plan by the occupier,

 

(a)       It shall be the duty of the District Magistrate or the District Emergency Authority designate by the State Government in whose area there is a site on which an occupier carries upon an industrial activity to which this Rule applies to prepare and keep up-to-date an adequate off-site emergency plan detailing emergencies relating to a possible major accident on that site will be dealt with and in preparing that plan  the authority shall  consult the occupier, the Chief Inspector and such other persons as appear to the authority to be appropriate {Rue 14(1) of MISHC Rules, 1989(amended 2000).

 

(b)       Constitution of State Crisis Group: The State Government shat constitute a State Crisis Group for management of chemical accidents within thirty days from the date of the commencement of these rules 6(1) under Chemical Accidents (Emergency Planning, Preparedness, and Response) Rules, 1996).

 

(c)       Constitution of the District and Local Crisis Group: The State Government shall cause to be constituted within thirty days from the date of commencement of these rules {8(1) under Chemical Accidents (Emergency Planning, Preparedness, and Response) Rules, 1996}

 

The Rajasthan Government has constituted the State Crisis Group. The Government has also District crisis group and Local crisis Groups respectively for the district having Major Accident Hazard Installations.

 

The Chief Secretary of the  Rajasthan Government is the ex-officio chair person of the State Crisis Group. Which is the apex body of the government of Rajasthan and consist of governmental officials, technical experts, and industry representatives. This group is required to deliberate on planning, preparedness and to provide guidance for handling of chemical accidents, with a view to reducing the extent of loss of life, property and ill health. The State Crisis Group will review all the Off-site Emergency Plans for chemical disasters for their adequacy. This group is required to meet one in three months.

 

The State crisis group

 

1.

Chief Secretary

Chairman

2.

Principal Secretary, Labour and Employment

Member Secretary

3.

Principal Secretary,   Paryavaran

Member

4.

Principal Secretary Health & Medical  Department

Member

5.

Principal Secretary, Industries

Member

6.

Secretary Public Health engineering and Geo-water  Department

Member

7.

Chairman State Pollution Control Board 

Member

8.

4  Experts, ( Industrial Safety and Health),  Nominated by state Government

Members

9.

Principal Secretary and Commissioner, Transport

Member

10.

Chief Inspector of Factories and Boilers

Member

11.

Director General Nagrik Suraksha

Member

12.

Director General Police 

Member

13.

Representative from Industries ,

(Nominated by the State Government)  

Member

 

 DISTRICT CRISIS GROUP and functions

The District Magistrate of the districts having Major Hazard Installations are ex-officio chair person of the District Crisis and this group is apex body at the district level and is required to review all On Site Emergency Plans prepared by the occupier of  the Major Accident Hazard Installations for preparation of District Off-Site Emergency Plan, which shall also include hazards due to transportation of hazardous chemicals by road and by pipelines. The District Crisis Group is required to meet once in a 45 days and responsible to conduct one full-scale mock-drill of the District Off-Site Emergency Plan, on the site every year. District crisis groups of all the districts have been constituted according to the Schedule 7 under Rule 8 of the Chemical Accidents( Emergency and Planning, Preparation and Response ) Rules 1996. Similarly Local crisis groups have also been constituted as per Schedule 8 under Rule 8 of the Chemical Accidents( Emergency and Planning, Preparation and Response ) Rules 1996.

 

These rules provide a statutory back up for setting up of crisis groups in districts and states, which have Major Accident Hazard (MAH) Installations and are responsible to plan and respond to chemical emergencies in the Sate of Rajasthan. These rules define the major accident hazard installations to include industrial activity, transport and isolated storages at a site handling hazardous chemicals in quantities equal to or more than the specified quantities in the rules

.

All required factories have submitted information regarding off site emergency plans. 16 districts, where MAH installations are situated, have constituted the District. Crisis Group as below :-

 

Constitution of District crisis group

 

Srl

No

 

 

1

District Collector

Chairman

2

Inspector/ Senior Inspector/Dy Chief Inspector of Factories And Boilers of Factories and Boilers/

Member Secretary

3

Up Khand Adhikari

Member

4

Fire Officer Nominated by District Collector

Member

5

District Public Relation officer

Member

6

Comptroller of Explosives

Member

7

Nagrik Surakcha Adhikari, Nominated by District Collector

Member

8

Representative form Trade, Nominated by District Collector

Member

9

Superintendent of Police

Member

10

Chief Medical officer

Member

11

Commissioner/Executive  Officer of Corporation /Municipality

Member

12

Representative from Public Health Engineering and Geo-water  Department                                                 

Member

13

Representative from State pollution control board

Member

14

District Agriculture officer

Member

15

4, Industrial Safety and health Experts, Nominated by District Collector

Member

16

Representative from Industry, Nominated by District Collector

Member

17

Chairman/Member Secretary of Local crisis

Member

18

District Transport Officer

Member

 

 

The On-site Emergency Plans for all the MAH installations have been got prepared and updating of these plans is  being after every two years. To carry out this task steps are being taken by organising various meetings, seminars and by issuing the guidelines to the Management.

 

It is also been emphasized that management should be vigilant enough to prepare the plans as an effective tool to deal with the various emergency situations and not only fulfilling the legal requirements.

 

6.10    Industrial Hygiene Laboratory

Industrial Hygiene Laboratory established at the Chief Inspectorate of Factories, Jaipur. The equipments were provided through The Directorate General Factory Advice Services and Labour Institute Bombay. Since than this laboratory have been monitoring the work environment during the surveys conducted independently, in the factories in order to secure compliance of section 41-F of The Factories Act, 1948.  So far toxic and hazardous substances like ammonia, chlorine, hydrogen sulphide, carbon monoxide, leather dust, asbestos, pesticides, silica dust, solvents, dyes and pigment dusts, which were present in The work environment, were monitored and analysed to estimate the concentration in the work environment.  The factory management's having the above contaminants in their work environment have been recommended, where the concentration is above the threshold concentration, to adopt specific control measures to restrict the concentration of such toxic and hazardous substances below the threshold concentration stipulated; in Schedule-2 under section 41-F of The Factories Act, 1948 (Amended 1987). In case the concentrations of the hazardous substances are above the threshold limit the management is directed to do the needful in order to safeguard the workers form the exposure.

 

In addition to carry out above works the laboratory is also arranging to carry out the Eye Examination of the crane operators and other workers according to the type of their employment.

 

During discussions it was told by the officials  that most of the equipments were old and obsolete and required replacement by Modern digital / computerised ones.

 

TABLE - 1

EXAMINATION OF HARMFUL SUBSTANCES

Sr. No.

Name of contaminants/ substance

1999-2000

2000-2001

2001-02 (Upto Dec.)

2002-2003

2003-2004

Samples collected

Sample exceeding limits

Samples collected

Sample exceeding limits

Samples collected

Samples exceeding limits

Samples collected

Samples exceeding limits

Sample  collected

Sample exceeding limits

1

 

Ammonia

119

6

180

7

63

-

111

6

91

-

2

Chlorine

72

4

144

-

83

1

157

1

52

-

3

Sulphur

Dioxide

20

1

10

-

8

-

11

-

6

-

4

Hf

18

-

1

-

2

-

6

-

7

-

5

Mercury Vapours

-

-

-

-

-

--

-

-

 

-

6

Oxides Of nitrogen

5

-

9

-

7

-

1

-

3

-

7

Hydrogen Sulphides

12

-

13

-

-

-

-

-

5

-

8

Vinyl Chloride

09

-

18

-

-

-

-

-

18

-

9

Acryl nitrite

-

-

-

-

-

-

-

-

-

-

10

Lead

3

3

-

-

3

-

-

-

-

-

11

BHC Dust

-

-

1

-

-

-

 

--

-

-

12

Cement Dust

9

7

1

-

-

-

-

-

7

6

13

Coal Dust

-

-

-

-

-

-

-

-

2

2

14

Capital SSP Dust

2

-

-

-

-

--

-

-

-

-

15

LPG

3

-

-

-

-

-

-

-

-

-

16

Asbestos

7

1

6

6

1

-

13

10

2

-

17

Sulphuric Acid Fumes

13

-

-

-

-

-

-

--

-

--

18

Methyl Para

-

-

-

-

-

-

-

-

-

-

19

Copper Fumes

-

-

-

-

-

-

-

-

--

 

20

Silica Quartz

3

2

19

14

-

-

 

-

18

10

21

Ore Dust

-

-

-

-

--

-

-

-

-

-

22

Hydrated lime

-

-*

-

-

-

--

-

-

-

-

23

Zinc Fumes

2

-

1

-

-

-

-

-

-

-

24

Hydrogen Chloride

-

-

6

-

1

--

1

-

3

-

25

Carbon Monoxide

-

-

-

-

1

--

3

-

5

-

26

Free Silica

-

-

-

-

-

---

-

---

-

-

27

Rock Phosphate

-

-

-

-

-

-

-

-

-

-

28

Styrene

4

4

-

-

-

-

-

-

-

-

29

Ethanol

-

-

-

-

-

-

-

-

-

--

30

DDVP

-

-

-

-

-

-

-

-

-

-

31

Fenvaleration Dust Thayne

-

-

-

-

-

-

-

-

-

-

32

Carbon Black

-

-

-

-

-

-

1

1

-

-

33

Nuisance

Dust

18

2

9

9

8

1

17

8

16

11

34

Toluene

1

-

-

-

-

-

-

-

-

-

35

Silver Fumes

1

-

-

-

-

-

-

-

-

-

36

Monocrotophos

19

-

-

-

-

-

1

--

-

-

37

Phorate

8

-

-

-

-

-

-

-

-

-

38

Noise

47

-

203

43

-

-

79

28

9

2

39

Ni  Metal

1

-

-

-

-

-

-

-

-

-

40

Chromium

Metal

1

-

-

-

-

-

-

--

-

---

41

Sodium Hydroxide

2

-

-

-

-

-

-

-

-

-

42

TNP

10

-

-

-

-

-

-

-

-

-

Total No Of Samples

-

461

30

622

82

177

2

401

54

244

33

Totat No Of Industries

-

187

 

*

 

*

 

*

 

*