About these Guidelines
Responsible Care® programme, originally initiated by the Canadian Chemical Producers Association (CCPA) has now been adopted by the most of the developed and developing nations. The programme rests upon the two major fundamentals. It is necessary to look beyond the law to prevent all the accidents, and the Second and the foremost is that the society has certain expectations from the chemical industry as a Corporate Citizen. The concern for the society has to be paramount in the entire gamut of SHE management.
The booklet "Responsible Care®; A Public Commitment, published by the Indian Chemical Council, is being followed as a guide for the programme by all the signatories, since the adoption of this programme by ICC since 1993.
The present guidelines are not to supplant those given in this booklet; but to supplement them. CCPA at the earlier stages of the programme thought that the prescriptive approach of suggesting all and sundries may not go well with the spirit of this programme. It was expected that the managements of such plants are well aware about the required compliance, as to what exactly is expected, and what is to be done. Perhaps this was an idealistic presumption. As is seen subsequently almost all associations and later even the CCPA itself came out with exhaustive guidelines. The present guidelines are derived from some such, no way overlooking the context. These days many a training programmes are being organised in the developed world, to guide regarding the compliances expected. There are training courses even for the auditors under Responsible Care®.
At present there are 79 signatories to the programme. It is now ripe time that the action is initiated for helping them in compliance as well as assessing the level of compliance these signatories. With the experience of theses many years, behind all of us, at Indian Chemical Council, it was felt that there perhaps exists a need for specific guidelines for certain items. Attempt here is to bridge the gap to an extent, and help the auditor and the compliant. These are expected to deliver not only a better, but a faster compliance.
Declaration of an award by the Aditya Birla Group, to the best compliant, under Responsible Care®, has given much needed boost to this programme. Already some of the signatories have communicated their willingness for getting audited, either as a requirement for obtaining the Responsible Care® logo, or for competing for the award. Modalities for these awards are under the active consideration of the association and very soon it will come out with the specifics.
These item-wise guidelines are about following first four codes only.
These guidelines are to be seen as an attempt to fill the gap. However these are mere and just guidelines and should not deter any, from thinking and performing more and better. To that extent, it is an open proposition and all are welcome to give the suggestions, to improve them.
V G Bukkawar
Advisor, Safety health & Environment
Indian Chemical Council
PROCESS SAFETY - CODE OF MANAGEMENT PRACTICES | |
Management Practices | |
Management Leadership | |
1. Leadership by senior management through policy, participation, communications and resource commitments in achieving continuous improvement of performance. | Expects a written down document of Policies and applicable SHE standards. Top, along with the Line management has to demonstrate leadership in, and commitment to, SHE. Member Company is expected have in place, an appropriate organisation, responsibilities, authority, resources, support services and other arrangements, required to implement SHE Policy and Standards. Employee and other records shall be maintained in a retrievable form. The SHE implications of changes to organisation and activity shall be assessed. Such changes shall not compromise, and where possible, shall improve SHE performance. |
2. Clear accountability for performance against specific goals for continuous improvement. | Line management shall review SHE performance. Programmes to deliver continuous improvement of performance towards defined goals shall be established and monitored. Reviews shall take into account the outcome from audits and risk-assessments, and learning from incidents. For example regarding accident prevention, decide the target and identify the areas to be tackled. Accordingly plan for supervision, training, auditing, introducing the incentives, and improving or changing work practices/procedures. Wherever necessary review standards, improve the maintenance practices and procedures. Ensure the commitment at highest levels and also from staff, workers, trade union and contractors. |
3. Measurement of performance, audits for compliance and implementation of corrective actions. | For all the departments and activities on the site; record and report SHE performance, in line with the policy and standards. Incidents and complaints are to be investigated, recorded and action taken to prevent recurrence. Learning shall be shared across the entire cross-section. Enquire even about all the near-miss incidents having potential for damage. Formal auditing and assurance procedures shall be defined and implemented to ensure that the systems and behaviours' adopted to meet these Standards are soundly established, maintained and observed. Deficiencies identified and opportunities for improvement shall be recorded and actions implemented. |
4. Investigation, reporting, appropriate corrective action and follow-up of each incident that results or could have resulted in a fire, explosion or accidental chemical release. | See 2 & 3 above. |
5. Sharing of the relevant safety knowledge and lessons learned from such incidents with industry, government and the community. | Establishment and collective use of systems and mechanisms such as MARG ( Mutual Aid & Response Group), Local Crisis Group or any other informal mechanism for sharing the lessons from. Within the factory, it could be a duly constituted and properly functioning Safety Committee, in agreement with the letter as well as the spirit of the law. The mechanisms so established should be valid for trade unions, factories in the neighbourhood and also the community around. List of the targeted stakeholders can include opinion makers in the society such as neighbouring Housing society Chairman/Secretary, Doctors, Bhajan Mandals (List is infinite. One can include Municipal Councillors, Panchayat Members and Sarpanch, School teachers etc), over and above the statutory agencies such as Local and District Crisis Groups, off-site agencies, authorities, etc. Organising meetings/trainings/site tours specifically catering to these audience groups would be of a great help while complying this issue. |
6. Use of the Emergency Response process to ensure that public comments and concerns are considered in design and implementation of the facility's process safety systems. | The concern for the neighbouring community should reflect in the safety, risk reduction related activities and emergency planning. |
Technology | |
7. Current, complete documentation of process design and operating parameters and procedures. | |
8. Current, complete documentation of information relating to the hazards of materials and process technology. | The documentation under Item 7 above should include the necessary information on the hazards of the substances stored, handled, used, processed and manufactured along with the safety related aspects of the technology. |
9. Periodic assessment and documentation of process hazards and implementation of actions to minimize risks associated with chemical operations, including the possibility of human error. | Depending upon the past performance, technology, plant and chemistry related specifics a schedule is to be evolved for such an assessment. This will include the periodicity and justification for the same. To have a broad judgement about a hazard as to whether it is moderate or higher an assessment is to be made using the Dow or Mond index. If the index shows that the hazard is moderate or higher, then it is to be subjected to a further review that includes detailed examination of critical process systems, plant and equipment, by using typical and appropriate Hazard Evaluation Techniques those are HAZOP study, What If Analysis, Failure Mode and Effect Analysis, Fault Tree Analysis, Event tree Analysis, Human Reliability Analysis and Risk Analysis . The depth of the approach will be governed by the rank and severity of the consequences of the hazard. Any major deficiencies to be corrected by equipment modification where practical. Safe limits to be established for all appropriate parameters and a combination of engineering/supervisory systems to be put into place to control operation of processes, within those limits. However consequences analysis giving damage distance for fire, explosion, toxic release and spillage involving hazardous substances will be necessary to know the damage zones, and their severity and type. Additionally the consequences foot print on a real time basis will be necessary for conducting the mock drills in realistic manner. It is also a requirement for compliance of item nos. 1 to 5 of subgroup Emergency Response under Emergency Response Code. Written procedures to be updated and expanded to the point where all critical hazards can be properly controlled during normal and abnormal conditions, including emergencies, and systems have to be established for control of maintenance and minor modifications not covered by the capital project review process. Skill requirements to be established for all operating personnel including maintenance staff, and training to be provided to ensure that a qualified minimum human resource pool exists for each operation regardless of vacations, absence, etc. Responsibilities to be assigned to ensure that these standards are met, any exceptions being documented along with the requiring written authorization. |
10. Management of changes to chemical operations to maintain or enhance the safety originally designed into the facility. | Any modifications to facilities and the arrangements for operation, Including changes to personnel, shall not compromise, and where reasonably practicable, shall improve SHE performance. Proposals for changes shall be documented and assessed, and modifications shall be authorised. Necessary hazard studies and risk assessments shall be carried out, appropriate design considerations made and all changes properly implemented and recorded. Management of change is to be interpreted as any change in hardware or software (including the change in composition of contingent manpower involved in various manufacturing operations. For e.g. a change of an operating person, who is not properly trained/acquainted, has to be treated as a change). Changing the quality related norms or even a supplier of a raw material needs to be treated as a change. |
Facilities | |
11. Consideration and mitigation of the potential safety effects of expansions, modifications and new sites on the community, environment, and employees. | For new sites or expansions or changes in old sites, it is expected that a due consideration is given to the concerns of the local community and employees, while selecting a particular technology, or a site or even a layout or equipment, over and above the applicable legal requirements. |
12. Facility design, construction and maintenance using sound engineering practices consistent with recognized codes and standards. | A mention in the policy regarding the design, construction and maintenance practices and a statement that the management is adhering to sound engineering practice and recognized codes and standards is necessary. This has to be evident in day-to-day operation and the necessary documentation confirming the same would be necessary. The justification for the choice of these codes and standards would be in line. |
13. Safety reviews on all new and modified facilities during design and prior to start-up. | This is in conjunction to Item No.10 and the same is equally applicable at the design and start up stage. |
14. Documented maintenance and inspection programs that ensure facility integrity. | Over and above legal requirements it is expected that the maintenance schedules are decided on the basis of hazard and risk. The suitable documentation is expected to be in place for these activities. Site shall be equipped, maintained and managed, so far as is reasonably practicable, to ensure continued safe and secure operation, the health of the people, the effective protection of assets and to prevent adverse environmental impact. There shall be operating procedures, pre start-up checks and routine Inspections of plant, equipment and buildings and structures of engineering construction, in the premises, to ensure their fitness for the purpose, in accordance with relevant Standards, Codes of Practices and Guidelines decided. These checks and inspections shall take into account engineering integrity, containment of materials, fire protection systems and other measures, so that there is continued conformation with controls and reduction of risks so far as is reasonably practicable. Appropriate records relating to equipment, plant or facilities and their processes shall be maintained. |
15. Sufficient layers of protection through technology, facilities and employees to prevent escalation from a single failure to a catastrophic event. | More the layers of protection, lesser the probability of any or for that matter catastrophic event. Some of these could be Inter-locks, Pressure Releasing System, Inter distances, Baffle Wall, etc. Depth of the approach and their Multiplicity would be in proportion to Hazard Potential and risk/s involved. A Proper Risk Analysis as suggested at S. N. 9 above would be necessary to justify the layers of protection provided. |
16. Provision for control of processes and equipment during emergencies resulting from natural events, utility disruptions and other external conditions. | Indicate the provisions made in hardware for Isolation/Safe shutdowns, for those emergencies those are likely to be triggered by natural events like flood/earthquake or domino considerations etc. Also obviously expected provisions are those made for situations of failure of electricity or any other critical utilities. |
Personnel | |
17. Identification of the skills and knowledge necessary to perform each job. | The SHE behaviour expected shall be defined. SHE competencies and expertise shall be taken into consideration in the selection and placement of all personnel. The accountabilities of all employees for SHE performance shall be established. Training needs shall be identified and satisfied to ensure that all employees have the necessary skills and awareness to behave with proper regard for risks, safety and the protection of the health of themselves, others and the environment. Training and validation arrangements shall be regularly reviewed. They shall be conversant with the MSDS of substance and also the use of PPEs. There shall be regular consultation, communication and dialogue with employees on SHE matters. Employees shall be encouraged to participate in improvement programmes. |
18. Establishment of procedures and work practices for safe operating and maintenance activities. | Standard Operating Practices, often called as Safe Operating Procedures are to be formulated and followed. Permit to work system for all maintenance and other non-regular activities is expected to be in place. |
19. Training for all employees to reach and maintain proficiency in safe work practices and the skills and knowledge necessary to perform their job. | Please see Item No.17. |
20. Demonstrations and documentation of skill proficiency prior to assignment to independent work and periodically thereafter. | As above. |
21. Programs designed to assure that employees in safety critical jobs are fit for duty and are not compromised by external influences, including alcohol and drug abuse. | Integration of activities discussed in Item No.17 along with monitoring of the health of workers, for Chronic And Acute Problems is a requirement under this programme. It is also expected that suitable administrative measures are taken to prevent the drug and alcohol abuse. |
22. Provisions that contractors either have programs for their own employees consistent with applicable sections of this Code or be included in the member company's program, or some combination of the two. | The programme does not expect any distinction to be made between a direct employee and a employee of a contractor. It is expected that either the principle employer or the contractor ensures SHE aspects under this code. |
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