INTRODUCTION TO HSE

HSE CHALLENGES INTRODUCTION

The unfriendly Industrial activities of Energy sector in general, and oil sector in particular, affect the quality of environment and are becoming potential threat to the environment.

Hydrocarbon ( oil & Gas) and petrochemical products pose hazard to the environment if not handled in a safe manner e.g., Leakage of toxic material due to faulty design or operation may affect health of people who get exposed to it. Discharge of pollutants can destroy the whole ecosystem as well as pose health hazard. oil and gas being highly flammable can cause explosion if not handled properly. The chemicals that are handled during processing cause health hazards. It can sometimes lead to loss of life.

The crude oil production, processing , handling , storage and transportation of large volumes of hazardous petroleum products pose inherent risks of: 1. 2. 3. 4. 5. Fires Explosions Toxic releases Health hazards Environmental pollution

if adequate precautions are not taken during the Production, design, operation & handling of petroleum installations.

Today, a lot of importance is given towards HSE at every stage of the Hydrocarbon industry. All major international / national oil and gas companies have their own HSE Standards for all activities from the initial stage.

The petroleum operations have been constantly developing, upgrading and improving their design and operating techniques to meet ever increasing demand. Major accidents like Bhopal ( Union Carbide Plant, 3 rd Dec.,1984) , Mumbai High ( 27 th July, 2005), Mexico city ( LPG disaster, 19 th Nov.1984) , Seveso ( Disaster in Chemical plant , 10 th July,1976) , Flixiborough ( Disaster in chemical plant, 1 st June, 1974), Piper Alpha Offshore platform incident in North Sea (6 th July,1988) etc. in the last two decades have shaken the confidence of general public about the safety of the people, property and environment.

The burned-out platform.

Mumbai High (27 th July, 2005)

Piper Alpha Platform, North Sea : 6th July,1988

After these major disasters, Government authorities, human activist groups and corporate houses in many countries including India have taken a number of steps to evolve a strategy to avert major mishaps in the installations which have the potential to cause loss of human life, property and environmental damage. No doubt, health, safety and environment issues are very critical in the petroleum operations in the current scenario.

HSE MODEL AND ITS INTEGRATION WITH BUSINESS:

HSE is an integrated management function comprising disciplines of occupational health, safety, environment and fire protection.

When an industrial hazards leads to an immediate or sudden accidents like an injury, fire, explosion or toxic release, it becomes a safety issues and safety management comes in the picture. When the hazards have chronic health effects like stress, muscular-skeletal disorders etc., it becomes occupational health problems. When the effect is long term and spread over larger areas beyond the boundary limit it becomes an environmental problem.

No doubt, HSE efforts of many organizations are driven by statutory requirements and they do whatever minimum is required to avoid litigation and fines. However an efficient and enlightened corporate see HSE in much broader perspective. They are committed to improve their health, safety and environment and fire protection performance on a continuous basis and on the sustainable way, i.e., meeting the needs of present without compromising the ability of future generations to meet their needs.

For a good Corporate, good HSE performance is an integral part of efficient and profitable business management.

Why???
The compulsion of integrating HSE functions with business can be well appreciated by looking in to the cost of an accident/ incident.

Consider the following direct or indirect costs of major accidents/ incidents: Injury/ loss of life to self or co-workers Cost of injury/ investigation Loss of property and material Loss of profits Punitive sanctions and fines

Closure/ shutdown of the installation Public litigation Environmental pollution Ecological damage Loss of business Shareholders wrath The above does not include the cost of psychological and social factors associated with major accidents.

Thus, it is sensible to integrate HSE as an important management functions like production, maintenance, finance, marketing and human resources etc.

HSE MANAGEMENT FRAMEWORK:

Most of the regulatory agencies lay down rules and regulations, which are the minimum basic requirements for the safe design and operation of an installation. Many organizations try to meet only the minimum regulatory requirements. But this is not enough in todays business and social requirement. Regulations alone can not guarantee the safety of petroleum installations.

Sound and safe engineering practices are equally important but are not adequately addressed in their requirements. The statutory and law enforcing agencies are generally slow in updating their rules and requirements to keep pace with the technological and social changes. Many regulatory agencies do not have adequate infrastructure and manpower to exercise superintendence and control of industrial safety performance on a continuous basis.

The safety inspectors, boiler inspectors and environmental specialist are far less in number than what is required to undertake meaningful inspection visits to various installations under their jurisdiction. Further the background & training that many factory inspectors have, their visits to factories are restricted to checking basic amenities like : First aid facilities, Personal protective equipment Potable water , canteen facilities etc.

The regulatory requirements are just very minimum requirements to obtain license and operate an installation. Lot of self regulatory initiatives by the management are required to maintain a high level of safety in the petroleum operations which is hazardous industry. So, the best framework of HSE management is to comply with the regulatory requirements and must have a highly efficient self regulatory system in house.

How to Deal - HSE Challenges?

Various statutory authorities / agencies like OSHA (Occupational Safety & Health Administration), EPA ( Environmental Protection Agency), NSC (National Security Council), factory inspectorates, Industry representatives etc. reviewed the subject of Industrial safety and environmental protection very seriously. Their collaborative efforts brought forward a number of new design standards, procedures and regulations to make the industry safer.

How to Deal - HSE Challenges?

A new tool called PSM ( Process Safety Management) was introduced. It became obligatory for the Industry to give due weight age to HSE in reshaping the safety image of the industry. Stringent legislation by the industry and Public awareness & concern for Health & Environment brought spectacular improvements to HSE management. Large Investment was pumped into new projects to upgrade many refineries w.r.t. HSE performances.

UNIT 2

REGULATORY REGIME

Since petroleum industry is hazardous industry, a number of regulations have been framed by various statutory/regulatory authorities in the country to safeguard the interest of workers, public and environment.

REGULATORY/ STATUTORY AGENCIES:

The list of various regulatory/statutory agencies having jurisdiction over the petroleum industry are: Central Pollution Control Board (CPCB) under the Ministry of Environment and Forests Respective State Pollution Control Board under the Ministry of Environment and of the State

 Oil Industry Safety Directorate ( OISD) Under the MoPNG

Chief Controller of Factories Of The Respective State (CIF) Under The Ministry Of Labor Chief Controller Of Explosives (CCE) , Ministry of Heavy Industry, Dept of Explosives Chief Inspector of Boilers of the respective State ( CIB) under the Ministry of Labor. Chief Electrical Inspector of the respective state (CEI) under the Ministry of Power. Director General of Civil Aviation ( DGCA) under The Ministry of Civil Aviation, National Air Port Authority Of India.

Tariff Advisory Committee (TAC) Under the Association of Insurance Companies Bhaba Atomic Energy Commission (BARC) Under Ministry of Atomic Energy Director General of Mines Safety (DGMS) under the Ministry of Mines Regional Transport Authority (RTA) under the Ministry of Surface Transport Director General Of Dock Safety (DGDS) under The Ministry of Shipping International Maritime Organization (IMO) under United Nations

REGULATIONS : The different agencies have framed various regulations under their purview to promote industrial safety and environmental protection in the hydrocarbon industry.

PETROLEUM ACT , 1934

The statutory requirements of the petroleum are governed by petroleum Act, 1934 and petroleum Rules 1976 under the jurisdiction of chief controller of Explosives.

The petroleum rules, 1976 detail the procedures and safety norms to be observed for approval of: containers, import, delivery and dispatch, loading, transport, storage, refining and blending petroleum, testing and maintenance of pipelines, of

Transport by ships/vessels in bulk Construction of tanks Manufacture of Safety Fittings etc.

Under the petroleum Act, the petroleum products are classified into: (1) Class A : having flash point below 23C (2) Class B : Flash point between 23C - 65C (3) Class C : Flash point between 63C - 93C The petroleum products with flash point above 93C do not fall under the purview of petroleum rules

THE INDIAN EXPLOSIVES ACT, 1884 The compressed or liquefied gas filled in containers under pressure are notified by the Government of India as explosives and brought under the purview of explosive act., 1884 in 1938. Various rules under this Act are:

(1) INDIAN EXPLOSIVES RULES, 1981

These rules regulate:

Manufacture Possession Use sale transport Export / import

of all types of explosives used for various purposes like mines / rock blasting crackers etc.

(2) THE STATIC AND MOBILE VESSELES (SMPV) RULES, 1981

PRESSURE

These rules stipulate various safety guidelines for the storage and transport of compressed and liquefied gases filled in pressure vessels (exceeding 1000 liters capacity) at a pressure 1.5 kg/cm or 2.0 kg/cm.

(3) THE GAS CYLINDER RULES, 1981

These rules pertain to the filling, storage, handling & transportation of gases in gas cylinders. The rules also regulate the manufacture of cylinders, valves & regulators, marking, stamping and colour coding of cylinders, storage, handling, transportation of gas cylinders etc.

THE FACTORIES ACT, 1948 The provisions of this act are administered by the chief inspector of the factories in the respective state. Each state has its own factories rules. The act was revised in 1987 to include hazardous chemical factories and some other amendments brought in the factories rules in 1995. The Factories Act make the occupier of a factory fully responsible for providing and maintaining the plant and the systems of work without any risks to the health and safety of the workers and general public.

The general responsibilities of occupier of a factory are: Declaring safety policy of the organization. Providing the Material Safety Data Sheet (MSDS) of each hazardous chemicals. (1) Every factory should have a well written onsite Emergency Plan, clearly defining the role of different persons in case of an emergency. (2) The Emergency Plan should be updated from time to time. (3) To maintain the limits of exposure chemicals and toxic substances. of

(4) Disclosure of information to workers, public and authorities. This should include declaration of dangers / health hazards and measures to overcome such hazards. (5) A safety committee having equal representation of workers and management should be in place. The meeting of this committee should be held at least every quarter. (6) Medical checkup of the workers once before the employment and once every six months for health status in case of specific health hazards. (7) Setting up of medical / occupational health center equipped with equipment and qualified medical personnel.

(8) Inspection , testing, examination and certification of equipment, vessels etc. by competent persons approved by CIF ( Chief Controller of Factories). (9) Permit to work system should be in place with approved safety and rescue equipment. All work associated with entry or work in confined spaces, working at heights, hot works, cutting and welding, excavation and other dangerous activities should have predetermined safe work procedure and should be undertaken under a written work permit signed by a qualified supervisor.

(10) Provide adequate fire protection system as per rules. (11) An emergency communication system alarm, siren etc. should be in place and everybody should know what to do in case of an alarm. (12) Safety manual containing the different safety procedures applicable to the installation should be available to the workers. (13) Providing Personal Protective Equipment to workers depending on the nature of hazard involved.

(14) Display necessary precautionary notices and instructions at prominent places to educate and warn the workers and visitors against the hazard involved. (15) Appointing a qualified safety officer in the premises as per rules. (16) Providing welfare amenities like drinking water facilities, washing facilities, mess room, toilets etc. (17) Sending any accidental report and notice of any poisoning or occupational diseases

ENVIRONMENTAL LEGISLATION:
Sustainable development and environmental legislation are important issues for the development of the society. GOI enacted the legislations related activities as below: various environmental to industrial projects/

A. The Water (Prevention and Control of Pollution) Act, 1974 B. The Water (Prevention and Control of Pollution) Cess Act, 1977

C. The Air (Prevention and Control of Pollution) Act, 1981 D. The Environment ( Protection) Act, 1986 The Environment ( Protection) Rules , 1986 Manufacture, Storage, and Import hazardous chemicals Rules, 1989 Hazardous Waste management ( management and handling) Rules, 1989 Environmental Clearance of Project Notification, 1994 Chemical Accidents (Emergency Planning, Preparedness and Response) rules, 1996 of

 Biomedical Waste (management and handling) rules, 1998 E. The Public Liability Insurance act, 1991 and the Public Liability Insurance Rules, 1991

THE INDIAN BOILERS ACT, 1923 The Central Government and the State Government independently, except Jammu and Kashmir where this act does not apply, frame the act . Each state has its own boilers regulations. It is an obligatory for an owner to get his boiler registered under this act. Chief inspector of steam boilers in the state is the registering authority. The act stipulates requirement for safety of steam boilers and steam pipes.
( Boiler- any closed vessel exceeding 22.75 lits. Capacity , exclusively used for generating steam)

THE INDIAN BOILERS ACT, 1923 ( cont.)

The regulations cover : (a) Design (b) Construction & Workmanship of boilers & connected mountings, fittings & piping The regulations also lay down procedures for testing and qualifying welders who are to work on boilers. It also specify the stages and procedures for inspection of new boilers and inspection frequency for boilers in operation.

THE INDIAN ELECTRICITY ACT, 1910

The objective of the I.E rules is to regulate the generation, transmission, distribution and use of electricity in a safe manner.

THE OIL MINES REGULATIONS, 1984

These regulations were enforced in the 1984 in the oil industry. All oil and gas exploration , drilling, production and transport facilities including general safety and health education are governed by these regulations under the Director General of Mines and Safety (DGMS).

THE INDIAN AIRCRAFT RULES, 1937

An installation, which is in the proximity of the Aerodromes, is covered under the purview of this rule. It is mandatory that clearance be obtained from the National Air Port Authority of India, under the ministry of civil aviation, while planning to any tall structure or building. Air warning lights are stipulated in the rules to be complied with by owners of such buildings.

INTERNATIONAL ORGANISATION:

MARITIME

Some important milestones achieved are: Convention on the safety of life at sea in 1974 International convention for prevention of pollution from ships in 1973/78 Convention on standards of training, certification and watch keeping for sea farers, 1978

DOCK WORKERES (SAFETY, HEALTH AND WELFARE) ACT, 1986

The dock workers (safety, health and welfare) regulations were framed in 1990 under the above mentioned act. Factory inspectorate does not have any jurisdiction on the ports and docs. Director general of Dock safety enforces, safety requirements at port/docks where crude and petroleum products moving through ships and barges are handled.

ATOMIC ENERGY ACT, 1962 The atomic energy rules were framed in 1971(revised in 1996) under the atomic energy act, 1962. Under these rules, atomic energy regulatory board, AERB under Bhabha atomic energy commission, regulates the use of any radioactive source in the country.

ATOMIC ENERGY ACT, 1962 ( Cont..) Radioactive sources are used in many petroleum installation in radiography equipment, x-ray machines, smoke detectors etc.. The use of any radioactive source including its storage, handling transportation and disposal must comply with the statuary requirements of AERB. Any installation using radiation sources must have an authorized radiological safety officer ( RSO) trained, validated and certified by radiation protection service division of Bhabha Atomic Energy Commission.

MOTOR VEHICLES ACT, 1988 The transportation of hazardous products by road is governed by Central Motar Vehicles Act, 1988 ( amended in 1993). The salient features of the rules include: Educational qualifications of the drivers of the goods carriages carrying dangerous or hazardous goods. Every drivers of such vehicles must have passed mandatory three days training course from a recognized school in addition to having his heavy vehicle driving license. Every vehicle carrying hazardous goods must display mark of the class label appropriate to the type of dangerous goods. Every vehicle carrying hazardous goods must be equipped with the prescribed safety equipment for the preventing fire, explosion or escape of hazardous goods.

OIL INDUSTRY SAFETY DIRECTORATE:

Oil industry safety directorate , OISD is an advisory body under the ministry of petroleum and natural gas. Set up in the 1986 after Bhopal disaster, the directorate advises the oil and gas industry in India on all matters of health , safety and environment. All public sector ( PSU) oil companies are members of OISD. Private oil companies can also become members in case they desire. Unlike other regulatory agencies, OISD helps the member oil and gas companies to enhance the level of safety through self regulation. OISD has published a number of standard/ recommendations practice in sitting of petroleum operation , philosophies, inspection, maintenance, fire protection etc.

OIL INDUSTRY SAFETY DIRECTORATE ( Cont..)

It is obligatory for the member companies to use these standard and recommended practices for new installations and installation in operations. OISD has also published guidelines for internal and external safety audits. Based on these guidelines, formal safety audits of oil/gas installations of various PSUs under Ministry of P & NG are conducted periodically by an external team under the leadership of OISD. Petroleum organizations can use these guidelines for their own internal audits. OISD has also made a model disaster management plan that can be used by an installation as guidelines for developing its own disaster/ emergency management plan.

TARRIF ADVISORY COMITEE: Tariff advisory committee, TAC, is an advisory body formed to regulate rates, terms and conditions of business of general insurance companies in India. TAC approves and monitors various fire fighting facilities and electrical installations in the industry. Fire fighting manual first brought out in 1903 by Calcutta fire association was revised, updated and issued by TAC in 1982 in two parts- Part I and part II. These manuals lay down guidelines for design and operation of private fire fighting facilities to be maintained by the industry. These guidelines have been used extensively in petroleum installations. Based on the degree of compliance to the recommendations of these manuals. TAC makes periodical inspections of those installations where rebates have been given.

PERMISSIONS AND APPROVALS FOR NEW PROJECTS: Before setting up any oil or gas installations, the following approvals/permission have to be taken by the organization. Some of these approvals/ permission are also applicable for undertaking a major expansions or revamp of existing installations. (A) UNDER FACTORIES ACT - FROM CIF( Chief Controller of Factories)
(1) Permission to construct, extend or take into use any building as a factory. (2) Approval of site and building plans (4) Certificate of stability of factory building (5) Application for registration and notice of occupation (6) Application for License/ Renewals of License of a factory.

UNDER ENVIRONMENT PROTECTION ACT - FROM MOEF AND STATE PCBS

(B) (1) Notification of site in respect of hazardous chemicals (2) Environmental impact assessment (3) Environmental clearance from Ministry of Environment and Forests (4) NOC from state pollution control board (5) Consent for discharge of effluents (5) Consent for operations of plants ( in air pollution control areas) (6)Authorization for handling hazardous waste in quantity exceeding regulatory values.

(C ) UNDER EXPLOSIVES AND PETROLEUM ACTS - FROM CCE ( Chief Controller of Explosives)
(1) License for manufacture, possession, use, sale, transport of explosives (2) License to import/store petroleum (3) License to carry petroleum by land (4) License for filling and possession of gas cylinders with compressed gases (5) License for transporting cylinders filled with compressed gas

(D) OTHER APPROVALS/PERMISSIONS/CLEARANCES (1)Certificate of authorization for use of boilers from the States Chief Inspector of Boilers. (2) Certificate of authorization for use of Electrical Equipments from the States Chief Electrical Inspector. (3) Authorization from BARC (under the Ministry of Atomic Energy) for use of equipment/ instruments using radiation sources.

REGULATORY COMPLIANCE: Various regulations go in a long way to increase the industrial safety standards, which is very important for hazardous industry like petroleum operations. But the regulations will be useful and bring results only when they are implemented in the right spirit. It is the responsibility of the owner/ occupier of an installation and their authorized officials to ensure that the requirements of various regulations are fully complied with. Besides taking the necessary approvals, permission, consents and clearances from the concerned authorities and maintaining the conditions specified therein, it is also required by some of these agencies to send them regular reports of compliance.

REGULATORY COMPLIANCE ( Cont..)

In the recent past, the law has put lot of accountability and liability on the part of senior management of an organization in the compliance of various regulations, and closure of installations. The owner/occupier and other officials may even be put behind the bars in serious violations. The public awareness about the safety hazards and environmental pollution from industrial activities has increased significantly over time. It is very easy these days for any person to file a PIL ( public interest litigation) suing an organization for violation of any regulatory requirement. The affected organization may get involved in lengthy litigation costing lot of money, harassment and loss of image and reputation. The management of every installation therefore should ensue that the required regulations are fully complied with.

LIMITATIONS OF REGULATORY AGENCIES:

Over the years, the regulatory agencies have played a significant contribution in the promotion of industrial safety in the petroleum industry in India. But, some of the inherent limitations of these agencies are: MINIMUM REQUIREMENTS: Most of the regulatory agencies lay down rules/regulations which are the minimum basic requirements that are very important in the safe design and operations of industrial units. They do not go into details of the requirements pertaining to safe management of an installation. E.g. sound and safe engineering practices are equally important but are not addressed in these requirements.

CHANGE IS SLOW:
Technological developments and social awareness bring in new problems and challenges to the industry. Adequate protection of society against new technological hazards would depend upon the speed with which these regulatory agencies can identify the new problems and change the rules. Since the provisions of these agencies cover a wide spectrum of industry and any amendments has to go through a lengthy legislative procedure, the statuary and law enforcing agencies are generally slow in updating their rules and requirements to keep pace with technological and social changes. Some of the requirements set forth in the regulations long ago may not be relevant in the present context. For example, Factory Act, since its inception in 1948, underwent amendments only in 1954,1976 and 1987. Petroleum rules were last revised in 1976. Environment protection act came into being only in 1986. The Indian electricity rules and Indian Boiler Regulations have not seen any revision for more than 15 years.

INADEQUATE INFRASTRUCTURE:

Many regulatory agencies do not have and adequate facilities and manpower to monitor and control the safety performance of the industry on a continuous basis. Further, with the background and training that many factory inspectors have, their visits to factories are restricted to checking the basic amenities like first aid boxes, machine guards, personnel protective equipment, drinking water and canteen facilities, etc. They probably do not have right training and background for identifying many serious process hazards. It is only after Bhopal disaster that some improvements withy respect to quantity and quality of inspectors in these agencies have taken place.

NOMINAL PENALITY FOR VIOLATIONS: Some regulatory agencies provide for penalty to the industry for violating the rules and compensation to the workers in case of injuries and fatalities. Though in the recent past there have been some changes in the amount of these penalties and compensations, still these are nominal in most cases, with the result that there is a little pressure on the industry compelling them to spend more money in making an installation inherently safer and non-polluting. Under the present situation, it appears that the companies prefer to violate the rules and pay the penalty rather than implement these rules by additional investment.

Conclusion:
Certain provisions of regulatory agencies are very general and subjective in nature. & this leads to ambiguities and confusions in their interpretations by users and the inspectors.