Hazard Management Dr. G. B. Soni Environmental Laws RIA The Water Act - 1974 The Water Cess Act - 1977 The Air Act - 1981 The Environment Protection Act - 1986 The Hazardous Waste (M & H) Rules-1989 The Hazardous Chemicals (MSI) Rules, 1989 Environment Impact Assessment-1994 & 2006 Coastal Regulation Zone Notification-1991 The Chemical Accidents Rules, 1998 Recycled Plastics (M & H) Rules-1999 Biomedical Waste (M & H) Rules-1998 Ground Water Management Notification-1997 Fly Ash & Brick Mfg. Rules-1999 Noise Pollution (R & C) Rules-2000 Ozone Depleting Substances (R & C) Rules-2000 Batteries (M & H) Rules-2001 Municipal Solid Waste (M & H) Rules-2000 The Fly Ash & Brick Mfg Rules 1999 Hon High Court Judgments CREP Hon Supreme court judgments Environment Audit Safety related Acts/Rules •· The Factories Act, 1948. •· The Factories Rules, 1963 (of respective state). •· The Safety Officers Rules, 1982 (of respective state). •· The Welfare Officers Rules, 1966 (of respective state). •· The Dangerous Machines (Regulations) Act, 1983. •· The Dangerous Machines (Regulations) Rules, 1984. •· The Indian Boilers Act, 1923. •· The Indian Electricity Act, 1910. •· The Indian Electricity Rules, 1956. •· The Motor Vehicles Act, 1988. •· The Central Motor Vehicle Rules, 1989 (relevant portion only). •· The Petroleum Act, 1934. •· The Petroleum Rules, 1976. •· The Gas Cylinder Rules, 1981. •· The LPG Regulation and Supply and Distribution Order, 1993. •· The Explosives Act, 1884. •· The Explosives Rules, 1983. •· The Explosives Substances Act, 1908. •· The Static and Mobile Pressure Vessels (Unfired) Rules, 1981 (2002). •· The Workmen’s Compensation Act, 1923 •· The Workmen’s Compensation Rules, 1924 •· The Workmen’s Compensation (Venue of Proceedings) Rules, 1996 •· The Workmen’s Compensation Returns •· The Contract Labour (Regulation and Abolition) Act, 1970 And this CORPORATE RESPONSIBILITY FOR ENVIRONMENT PROTECTION ( CREP ) 1 Voluntary initiatives for building a partnership among all 2 Segregation of waste streams 3 Detoxification and treatment of High COD waste streams 4 Effective Waste Management 5 Air Pollution Control 6 Emission Control 7 Self Regulation 8 Organisational restructuring Risk Analysis is a process which provides a complete picture of significant EHS issues / aspects and impacts. In-short, this is a management tool which helps to know about, “how we manage EHS ” and “priorities to address EHS issues/aspects” Scope Database Risk Identification Select aspects/Events Consequence Analysis Likelihood Analysis Actions to Reduce Frequencies Actions to Reduce Consequences Estimate Risk Levels Procedure for Risk Analysis Procedure for Risk Analysis pH After deciding the activity / aspects for which Risk Analysis is to be performed, decide the criteria based on which category of consequence of that activity / aspect can be judged, as illustrated below: CONSEQUENCE Minor CRITERIA (for example) If pH of the Treated Effluent > 6.5 & < 8.5 Medium If pH of the Treated Effluent < 6.5 & > 5.5 0r > 8.5 & < 9.5 Serious If pH of the Treated Effluent < 5.5 & > 4.0 0r > 9.5 & < 10.0 Major LIKELIHOOD / OCCURRENCE (FREQUENCY) If pH of the Treated Effluent < 4.0 or > 10.0 CRITERIA (for example) Almost certain Event could happen ≥ 70% times Likely Event could happen ≥ 50% & < 70 % times Moderate Event could happen ≥ 25% & <50% times Unlikely Event could happen ≤ 25% time Procedure for Risk Analysis…… Now the Risk Ranking of particular activity / aspect can be evaluated with the help of 'Risk Ranking Chart', as illustrated below: Risk Ranking = (Severity of Consequence) × (Likelihood or Occurrence) Risk Ranking Chart: Consequence Likelihood / Occurrence (frequency) Minor Medium Serious Major Unlikely L L M M Moderate L M M H Likely M M H H Almost certain M H H H Legend: H High Risk (unacceptable risk) M Medium Risk (acceptable risk with appropriate risk control measures) L Low Risk (acceptable risk) Risk Ranking of particular Activity/Aspect = H or M or L EHS Quantification Exercise Identification & Selection of EHS Aspects for quantification Environment Aspects – 17 Health & Safety Aspects – 25 Total EHS Aspects – 42 Developing & Establishing about 500 Criteria for quantification individual EHS Aspects Developing & Establishing Scoring Pattern Made presentations & got system approved Continue……… EHS Quantification Exercise Preparation of EHS Ranking Document and EHS Aspects Analysis Sheets Performing EHS Ranking [On-site observation/verification, Interaction with Plant heads, Eng Heads, EHS executives, On-site interaction with employees/workers, Document/records data verification Preparation of EHS Ranking Reports FORMAT FOR ENVIRONMENT, HEALTH & SAFETY (EHS) RANKING No. Environment Aspect (A) 1 Compliance of Statutory Environmental Obligations 2 Compliance of SPCB General Conditions 3 Compliance of the Supreme Court’s directions including Display Board at the Main Gate 4 Provision and Operation of the Effluent (Industrial & Domestic) Treatment Scheme 5 Quality of the Treated Effluent (Industrial & Domestic) 6 Maintaining Log-sheets for Environment Management System (EMS) 7 Provision and Operation of the Air Pollution Control Measures 8 Monitoring & Quality of Flue Gas Stack Emission 9 Monitoring & Quality of Process Stacks/Vents Emission 10 Fugitive Emission Monitoring 11 Fugitive Emission Quality 12 Ambient Air Monitoring 13 Ambient Air Quality 14 Noise Level Monitoring 15 Noise Quality 16 On-site Hazardous Wastes Storage Facility 17 Compliance of the MS&IHC Rules – 1989 as amended till date Score Score Possible Obtained FORMAT FOR ENVIRONMENT, HEALTH & SAFETY (EHS) RANKING No. Health & Safety Aspect (B) 18 Health and Safety Policy 19 Safety Department and Safety Budget 20 Safety Committee 21 Health & Safety Education and Training Score Possible Score Obtained General Working Condition: - House Keeping 22 - Illumination - Ventilation - Noise Safety 23 Hazard Identification and Control 24 Fire Safety 25 Work Permit System 26 Safe Operating Procedures Continue………. FORMAT FOR ENVIRONMENT, HEALTH & SAFETY (EHS) RANKING No. Health & Safety Aspect (B) 27 Emergency Preparedness 28 Electrical Safety 29 Personal Protective Equipment (PPE) 30 First Aid 31 Material Handling Safety 32 Lifting Machines & Tackles Safety 33 Tank Farm (Storage Vessel) Area Safety 34 Pressure Vessels (Fired and Unfired) Safety 35 Static Electricity Safety 36 Workshop Safety 37 On-Site Gas Cylinders Storage and Handling Safety 38 Welding and Gas Cutting Safety Score Possible Score Obtained Continue………. FORMAT FOR ENVIRONMENT, HEALTH & SAFETY (EHS) RANKING No. Health & Safety Aspect (B) 39 Chemical Lab Safety 40 Safety Inspection 41 Accident Reporting, Investigation and Analysis 42 Compliance of the Provisions of Factories Act, 1948 as amended till date Score Possible HEALTH & SAFETY SCORE TOTLE (B): 25 ENVIRONMENT SCORE TOTLE (A): 17 EHS SCORE TOTLE(A+B): 42 Score Obtained To Calculate Final Score Total Score Possible: 42 Final Ranking: (Total score obtained/Total possible score) X 100 = ________% Aspect: Compliance of Statutory Environmental Obligations Score Pattern Not Applica ble (NA) Total Score Conform (C) Partially Conform (PC) Consolidated Consents & Authorization (CC&A) 1 1 0.5 0 - Bio-Medical Wastes (BMW) Authorization 1 1 0.5 0 - Environmental Clearance (EC) or any other clearance 1 1 0.5 0 - Environmental Audit Report 1 1 0.5 0 - Environmental Statement (Form-V) 1 1 0.5 0 - Water Cess Returns (Form-I) 1 1 0.5 0 - Annual Returns of Hazardous Wastes (HWs) (Form-4) 1 1 0.5 0 - Manifest (white copy) for HWs disposal 1 1 0.5 0 - Annual Returns of BMWs (Form-II) 1 1 0.5 0 - Compliance Report of CC&A/ Environmental Clearance/ CRZ Clearance or other approvals 1 1 0.5 0 - Public Liability Insurance (P.L.I.) Policy 1 1 0.5 0 - No Objection Certificate (NOC) from the Airport Authority of India (AAI) 1 1 0.5 0 - Management of used Batteries 1 1 0.5 0 - Phase out the use of Ozone Depleting Substances 1 1 0.5 0 - Criteria Total Score Possible: ________ Final Score = (Total Score Obtained / Total Score Possible) Not Conform (NC) Total Score Obtained: ________ Final Score = _________ Score CLASSIFICATION Colour Code Units Percentage (%) Rating % ≤ 50 % Immediate > 50 & ≤ 60 % Below Average > 60 & ≤ 70 % Average > 70 & ≤ 80 % Good > 80 & ≤ 90 % Very Good > 90 & ≤ 100 % Excellent TOOLS USED TO REDUCE THE RISK • • • • • • • • • • • • • • • • • • • • Gap Analysis & improving through Action Plans Set up EHS Cells at Corporate Office and Individual units In plant Effluent Segregation System (IMPESS) Solvent Recovery Wealth from waste SOP for all EHS related activities ISO 14001 & OSHAS 18001 Certification Training Programs Documentation Daily CMD reporting Monthly reporting to the Executive Committee Action Plans for Resource conservation and Recycling Awareness Program Inviting innovative ideas from the employees Learning's through interplant visits Involvement of EHS cell at planning stage Annual EHS Meet. Celebrations of various Days EHS performance Awards Fixing Accountability EHS RANKING Environment Ranking (%) Unit Jan 2009 Feb 2009 Health- Safety Ranking (%) Jan 2009 Feb 2009 EnvironmentHealth-Safety (EHS) Ranking (%) Jan 2009 Feb 2009 Group EHS-Rank Jan 2009 Feb 2009 Overall EHS-Rank Jan 2009 Feb 2009 1 87.22 87.22 85.21 85.21 85.70 85.70 1 1 1 1 2 73.56 73.56 76.88 76.88 76.03 76.03 2 2 3 3 3 67.67 67.67 69.82 71.29 69.30 70.41 3 3 7 7 4 52.22 55.89 61.71 62.32 59.41 60.76 4 4 8 8 5 58.11 59.11 56.32 56.64 56.76 57.24 5 5 10 9 6 77.11 78.00 82.59 83.00 81.22 81.75 1 1 2 2 7 76.33 77.78 72.29 72.96 73.27 74.14 4 4 6 6 8 74.00 74.56 73.93 74.86 73.95 74.78 2 2 4 4 9 72.78 74.22 72.43 74.68 72.51 74.57 3 3 5 5 10 69.80 70.90 50.27 50.46 55.69 56.14 5 5 9 10 11 42.63 42.63 36.14 36.33 37.93 38.07 6 6 11 11 Legend UP DOWN NO CHANGE 90 90 80 80 70 70 60 60 50 50 40 40 30 30 20 20 10 10 0 0 May-08 Jun-08 Jul -08 Aug-08 Sep-08 Nov-08 Dec-08 Jan-09 Feb-09 YT D (Avg.) Oct-08 M ay-08 Jun-08 Jul -08 Aug-08 Sep-08 Nov-08 Dec-08 Jan-09 Feb-09 YT D (Avg.) Oct-08