HIRA IN DOCKS FOR TRANSPORT OF HAZARDOUS CHEMICALS S. S. Gautam, Director (IH) Major Hazard & Chemicals Safety Division Central Labour Institute Sion, Mumbai 400022
CHEMICAL HAZARDS IN DOCKS • Perpetual increase in the number of chemicals in ports. • Many of these are toxic, explosive, flammable, radioactive etc. • Each class of chemical needs specific precautions. • Scenarios are changing every day depending upon the types of goods handled.
STATUTORY COVERAGE ON CHEMICAL HAZARDS • Manufacture, Storage and Import of Hazardous Chemicals Rules 1989 – • For isolated storages and pipelines containing Hazardous substances in the quantities exceeding prescribed threshold quantities. • Dock Workers (Safety, health and Welfare) Regulations 1989 – • Provisions for hazard environment in holds and other confined areas. • Provisions for Handling of Dangerous Goods
RESPONSIBILITIES ENTRUSTED TO DGFASLI UNDER MSIHC RULES • Rule 5: Notification of major accidents. • Rule 7: Notification of MAH sites. • Rule 8: Updating of site notification on any change in relevant details. • Rule 9: Transition Provisions.
RESPONSIBILITIES ENTRUSTED TO DGFASLI UNDER MSIHC RULES • Rule 10: Safety Report. • Rule 11: Updating of reports under Rule 10. • Rule 12: Information to prosecuting authorities • Rule 13: On site emergency plans & mock drills • Rule 14: Participation in the preparation of off site emergency plan.
EP Act has empowered the following officers of the DGFASLI • Director General • Deputy Director General • Director (Dock Safety) • Joint Director (Dock Safety) • Deputy Director (Dock Safety) • Assistant Director (Dock Safety) • Additional assistant Director (Dock Safety)
LIMITATIONS • Responsibility to report on the following items not included: • Rule 4: General responsibilities of the occupier. • Rule 15: information to the persons liable to be affected. • Rule 16: Disclosure of information. • Rule 17: collection, development and dissemination of information
LIMITATIONS (Contd.) • No power to prosecute: • Prosecuting powers retained with MOEF, Central & State Pollution control Board, district collector. • DGFASLI to forward the lack of compliance to the MOEF for further action. • Minor Ports remain unattended as DGFASLI covers only major ports.
INSTRUCTIONS TO INSPECTING OFFICERS by DGFASLI Directives of DGFASLI to inspecting officers: • Inspection of identified MAH installations once in a year • Report of inspection to Chief Inspector within a fortnight • Annual report every year • Improvement advice in consultation with Chief Inspector
INSTRUCTIONS TO INSPECTING OFFICERS (Contd.) • Scrutiny of documents for identification of site and its forwarding to Chief Inspector within 30 days. • Information to Chief Inspector on any major accident. • Report of accident analysis to the Chief Inspector within 45 days. • Scrutiny of mock drill report and forwarding to the Chief Inspector with remarks within 15 days. • Liaise with district emergency authority for preparation of off site emergency plan.
NUMBER OF INSPECTIONS IN MAH SITES DURING 2007 • Mumbai 00 • J.N. Port 00 • Kandla 18 • Morumgao 03 • Kolkata 12 • Paradeep 08 • Vishakhapatnam 02 • Chennai 00 • Cochin 12 • New Mangalore 13 • Tuticorin 00
PUBLICATION OF “GUIDE TO INSPECTION OF MAJOR ACCIDENT HAZARD INSTALLATIONS IN PORTS” • A comprehensive document was released during the year 1997 to all the inspecting officers which provides all the necessary information for effective inspection of MAH installations.
Contents of the Guidelines • General Guidelines for inspecting. • Standard formats have been provided for • Isolated Storages • Pipelines • Checklists have been provided for use during inspections. • After the inspection if improvement notice is required to be issued draft imprrovent notice should be sent to the chief inspector of dock safety.
Checklists & Formats • Isolated storage inspection form. • Isolated storage inspection checklist. • Pipeline inspection form. • Pipeline inspection checklist. • Guidelines to the checklists. • Checklist for inspection of LPG. • Checklist for inspection of Ammonia. • Monthly progress report format. • Checklist for evaluation of onsite emergency plan. • Format for improvement notice.
ADDITIONAL INFORMATION IN THE GUIDELINES • Guidance notes on rules and schedules. • Technical information on static electricity, testing of pipelines, corrosion control monitoring. • Problems arising in pumps. • Problems associated with valves. • Prioritisation of MAH installations. • EP Act & MSIHC Rules.
PROVISIONS RELATING TO HAZARDOUS SUBSTANCES IN DOCK WORKERS (SAFETY, HEALTH & WELFARE) REGULATIONS 1989 • Article 39: Dangerous and harmful environments • Article 76 to 82: Handling of dangerous goods.
DANGEROUS AND HARMFUL ENVIRONMENTS • When internal combustion engines are used in holds or confined spaces the conc. of CO should be kept within 50 ppm by adequate ventilation. • Entry into confined spaces where there is possibility of dust, fumes of gases, workers shall not be allowed unless the environment has been declared safe by testing by a competent person.
HANDLING OF DANGEROUS GOODS. • Before unloading any dangerous good, the ship owner will provide the statement in writing identifying the goods and nature of hazards likely from them to the employer of the workers, ports authorities and to inspector. • The shippers will also provide similar statements
Explosives Gases – compressed, liquefied and dissolved under pressure. Inflammable liquids. 4.1 Inflammable Solids 4.2 Inflammable solids or substances liable to Spontaneous combustion. 4.3 Inflammable solids which in contact with water emit flammable gases. CLASSIFICATION OF THE DANGEROUS GOODS
5.1 Oxidizing Substances. 5.2 Organic peroxides. 6.1 Poisonous (Toxic) substances. 6.2 Infectious Substances. 7. Radioactive Substances. 8. Corrosive Substances. 9. Miscellaneous Dangerous Substances. CLASSIFICATION OF THE DANGEROUS GOODS
DANGEROUS GOODS The regulations also provide: • General Provisions. • Special Provisions for • Explosive and inflammable cargo, • Tetra ethyl lead • Toxic solvents. • Broken or leaking solvents.
CONCLUSIONS • The legal provisions available in the country ensure that the identified MAH installations in the ports require to prepare “Safety Report”, which is a comprehensive document covering most of the aspects of HIRA and emergency planning. • The status of the compliance could not be ascertained due to paucity of time, as the information available only with local Dock Safety Inspectorates.
For chemical cargo in packets, and vessels the provisions relating to dangerous goods are if effect. This at least ensure identification of type of hazards the cargo in likely to pose. The safety officers and the Dock Safety Inspectors at the port can subjectively assess the risk involve in the handling process and judiciously decide the safety measures to adopted while storage, handling and other operations involved.
There is need for more comprehensive regulations for dangerous goods to match with the internationals standards. • MAH related information for ports should be kept centrally available in website. • The minor ports under the jurisdiction of state governments should also be brought into the fold of MISHC Rules. • The prosecution powers should be extended to DGFASLI officials in order to increase the effectiveness of enforcement.