OISD-GDN- 206

First Edition, September, 2001

Guidelines on Safety Management System

in Petroleum Industry

OISD-GDN- 206

Oil Industry Safety Directorate

Government of India
Ministry of Petroleum & Natural Gas

1
 NOTE

OISD publications are prepared for use in the oil and gas
industry under Ministry of Petroleum & Natural Gas. These
are the property of Ministry of Petroleum & Natural Gas and
should not be reproduced or copied or loaned or exhibited to
others without a written consent from OISD.

Though every effort has been made to assure the accuracy

and reliability of the data contained in these documents, OISD
hereby expressly disclaims any liability or responsibility for
loss or damage resulting from their use.

These documents are intended to supplement rather than

replace the prevailing statutory requirements.

2
 FOREWORD

The oil industry in India is over 100 years old. As such, various
practices have been in vogue because of collaboration/association with
different foreign companies and governments. Standardisation in
design philosophies and operating and maintenance practices at a
national level was hardly in existence. This, coupled with feed back
from some serious accidents that occurred in the recent past in India
and abroad, emphasised the need for the industry to review the
existing state of art in designing, operating and maintaining oil and gas
installations.

With this in view, the Ministry of Petroleum and Natural Gas in 1986
constituted a Safety Council assisted by the Oil Industry Safety
Directorate (OISD), staffed from within the industry, formulating and
implementing a series of self regulatory measures aimed at removing
obsolescence, standardising and upgrading the existing standards to
ensure safer operations. Accordingly, OISD constituted a number of
functional committees comprising of experts nominated from the
industry to draw up standards and guidelines on various subjects.

OISD have brought out a number of documents on various topics like

layouts of installations, design, engineering, maintenance and
operations of various facilities / equipment etc.

In an economic environment of rising cost of various inputs to the

industry, in the form of man, material , machine and increasing cost of
health care, it is vital for an organisation to effectively manage
occupational safety and health. Benefit may be derived from such
management in the form of increased productivity and morale. These
benefits are a direct consequence of the reduction in workplace
accident, injuries and illness. If workmen are to remain productive,
they must be protected from injuries and illness.

There is an obvious effort to protect our facilities including personnel

and managing the issue of safety and health in totality. The present
document outlines the areas, in the form of elements, which need to
be given due attention with a view to enhance productivity, morale of
personnel and image of the organisation.

This document will be reviewed periodically for improvements based on

the experience and better understanding.

Suggestions from industry members may be addressed to :

The Coordinator,
Committee on " Safety Management System",
Oil Industry Safety Directorate,
II Floor, Kailash,
26, Kasturba Gandhi Marg

3
 New Delhi - 110 001

COMMITTEE

ON

SAFETY MANAGEMENT SYSTEM

------------------------------------------------------------------------------------------------------------
NAME ORGANISATION
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Leader

A.A.Raichur Hindustan Petroleum Corpn. Ltd. ( R), Mumbai

Members

C.S.Chakrabarti Bharat Petroleum Corpon. Ltd. (R), Mumbai

T.S.Lamba Oil & Natural Gas Corpon. Ltd, Kolkata
N.Rengaswamy Engineers India Ltd. , New Delhi
S.Thangavelu Chennai Petroleum Corpn. Ltd., Chennai
R.C.Pandey, Bongaigaon Refinery & Petrochemicals Ltd.,
Bongaigaon
N.Dasgupta Bharat Petroleum Corpon. Ltd. (M), Mumbai
T.K.Kumar Indian Oil Corpon. Ltd. (PL), New Delhi
S.S.Maji Indian Oil Corpon. Ltd. (R), New Delhi
Dr. D.Buragohain Gas Authority of India Ltd., New Delhi

Member Co-ordinator

Shri S.N.Mathur Oil Industry Safety Directorate, New Delhi

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(In addition to the above, several other experts from industry

contributed in the preparation, review and finalisation of this
document).

4
 SAFETY MANAGEMENT SYSTEM

INDEX

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S.No. Content Page No.
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1. Introduction 6
2. Scope 6
3. Definitions 6
4. Safety Management System 7
4.1 Safety Organisation 8
4.2 Employees Participation 9
4.3 Process Safety Information 10
4.4 Process Hazard Analysis 13
4.5 Operating Procedures 17
4.6 Training 18
4.7 Contractors 19
4.8 Pre-start up Safety Review 20
4.9 Mechanical Integrity 21
4.10 Work Permit 28
4.11 Management of Change 28
4.12 Incident Investigation and Analysis 29
4.13 Emergency Planning and Response 33
4.14 Compliance Audit 36
4.15 Occupational Health 37
4.16 Off-the-job Safety 38
4.17 Customers and Products 38
4.18 Road Transportation 43
4.19 Trade Secrets 48
5.0 References 49

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5
 SAFETY MANAGEMENT SYSTEM

1.0 Introduction
An effective Safety Material Safety Data Sheet
Management System is (MSDS):Data sheet
required to prevent hazardous incorporating safety
incidents and eliminate or information / properties of a
mitigate their consequences. chemical / product and useful
A number of catastrophic for handling the material
incidents in hazardous
process industry have drawn Incident : An unplanned
attention to the safety of event (occurrence, condition
processes. Employees have or action) which did or could
been and continue to be have resulted in personal
exposed in their workplace to injury or damage to the plant,
the hazards of chemicals community or environment.
which may be toxic, reactive,
flammable or explosive. The Near-miss : An incident
present document which does not result any
emphasises the application of injury or damage to property
management controls for but has the potential to result
tackling the risks associated in injury and / or property
with handling / working with or damage.
near to hazardous substances
in petroleum industry. Process : Any activity
involving a highly hazardous
chemical including any use ,
2.0 Scope storage, manufacturing,
This document provides handling, or on the site
guidelines for development of movement of such chemicals ,
detailed procedures for Safety or combination of these
Management System and activities.
covers the petroleum
industry as a whole. For the purpose of this
definition, any group of
vessels which are
3.0 Definitions interconnected or separate
vessels which are located
Competent Person : A such that a highly hazardous
person duly designated / chemical could be involved in
authorised by the potential release should be
management to carryout a considered as single process.
specified job

6
 Catastrophic release : A equipment, material and
major release involving one or environment. Objective of
more dangerous substances developing such a system is
that leads to serious danger to to standardise the procedures
persons as well as which should continue to be
environment both within and followed by one and all unless
outside the workplace and a change in the system is duly
results from uncontrolled authorised by a competent
developments. person. Such a Safety
Management System should
Critical equipment : refers to comprise the following basic
columns, vessels, machinery, elements :
piping, interlocks, and
controls determined by 1. Safety Organisation
management to be vital for 2. Employees Participation
preventing the occurrence of 3. Process Safety
a catastrophic release. Information
4. Process Hazard Analysis
Facility : Buildings, 5. Operating Procedures
containers, piping and 6. Training
equipment that could 7. Contractors
reasonably be expected to 8. Pre-startup Safety Review
participate in catastrophic 9. Mechanical Integrity
release as a result of being 10. Work Permit
physically interconnected or of 11. Management of Change
their proximity and in which 12. Incident Investigation and
hazardous substances are Analysis
used, stored , manufactured , 13. Emergency Planning and
handled or moved. Response
14. Compliance Audit
Process Hazard Analysis : 15. Occupational Health
Process Hazard Analysis 16. Off-the job Safety
(PHA), sometimes called 17. Customers and Products
process hazard evaluation, is 18. Road Transportation
an organised and systematic 19. Trade Secrets
effort to identify and analyse
the significance of potential Each of the these elements
hazards associated with the should be taken care of as
processing or handling of given below:
highly hazardous chemicals.

4.0 Safety Management System 4.1 Safety Organisation

System for managing safety
intend to cover all aspects of 4.1.1 Safety Policy
plant and facilities like to Every organisation should
control loss to personnel, have safety policy duly

7
 approved by the Board of 4.1.3 Enforcement of Safety
Directors of the organisation. In the organisation, Safety
It should contain intentions should be ensured through
and commitment from the top repeatedly highlighting it's
management. It should be utility in preventing loss of life
made available to all and property and providing
employees in a language training / retraining to
easily understood. employees in safe working.
Following modes should be
It should be displayed at followed for enforcing safety :
various locations in the
organisation. a) Work Permit System
b) Job safety analysis
Organisational set-up for c) Training of employees and
implementation and contractors
monitoring of safety policy d) Surprise checks
should be in place. Safety e) Drills
target and objectives for each f) Operating manuals /
position in the organisation Safety manual
should be set and pursued. It g) Periodic MIS reports for
should be revised as and monitoring by top
when required. management

4.1.2 Safety Committees 4.1.4 Monitoring of Systems

Safety Committees should be Following systems should be
formed in the organisation. monitored regularly for
The Committees should effective implementation :
encourage employees
participation. a) Checking of safety
interlocks
It should meet at least once b) Internal audits of plants
in a quarter and minutes of /facilities in line with
the meetings should be OISD-STD-145
recorded. c) Management of change
d) Testing / Inspection of
Deliberations of safety equipment
reports, audits, incident e) Checking of fire detection
enquiries should be a part of and protection system
agenda of safety meetings.

For implementation of safety 4.1.5 Safety Promotion

committee recommendations, Visuals play an important role
time bound programme in reminding personnel of
should be enforced. safety information. Therefore,
display of following

8
 information should be done in safety & health hazard
the premises: associated with products &
work environment.
(a) Safety precautions for
critical operations at 4. Employees should be
strategic locations trained on use of personal
(b) Safety posters and protective equipment
slogans (PPE).
(c) Safety records
(d) Do's and Don'ts at toxic 5. Means & methods should
chemicals be established to keep
handling/storage/operation employees informed about
areas relevant safety & health
(e) Wearing helmet and other issues.
Personal Protective
Equipment (PPEs) 6. Safety & health committee
(f) Labeling of chemicals at floor level should be
(g) Material Safety Data Sheet formed with participation of
(MSDS) employees & employer's
(h) Safety manuals, Rules and representatives to review
Regulations safety & health related
(i) Safety News Letters & issues of the plant. The
bulletins committee should meet
(j) Dissipation of incident periodically to discuss the
information relevant issues & suggest
and implement remedial
measures.
4.2 Employees Participation
Following activities should be 7. Written information about
undertaken to involve process, chemicals
employees in the working of including MSDS and
the plants / facilities : equipment should be
accessible to employees.
1. Company should develop
a written action plan to 8. Critical procedures &
implement the employees' instructions should be
participation. prepared in English and in
a local language,
2. Employees should be understood by employees.
involved in Internal Safety
Audits and Job Safety 9. Employees should be
Analysis. involved in management of
change related to process
3. Employees should be & equipment.
explained about operation
of the plant, including

9
 10. Safety quiz / suggestion verification of drawings to
schemes / competitions ensure consistency with the
etc. should be conducted actual process equipment and
to enhance participation of arrangement may be made.
employees.
Information should be so
located that it can be easily
4.3 Process Safety Information available at the time of need.
Process safety is defined as Computerisation of the
the operation of facilities that information is desirable. It
handle, use, process or store facilitates easy up-dation and
hazardous materials in a retrieval. It may be put on
manner free from episodic or local network for easy
catastrophic incidents. accessibility by all concerned.
Knowledge of chemicals,
process and plants is one of A master-index indicating the
the prime asset. This location of information and the
knowledge is required for medium in which it is
developing other modules of available should be prepared.
the management system like
process hazard analysis,
operating procedures, 4.3.2 Process Chemicals
training, emergency Process chemicals should
preparedness plans etc. include all raw materials,
intermediates / finished
products and chemicals
4.3.1 Process Information used in the process. Data
Complete and accurate pertaining to process
written information should be chemicals should help in
compiled for the following assessing fire and explosion
three categories: characteristics, reactive
hazards, safety and health
1) Process chemicals hazards to workers and the
2) Process technology corrosion and erosion effects
3) Process equipment on the process equipment.
Complete inventory of the
This information should process chemicals should be
represent current operation. prepared. For each process
All data sheets, drawings, chemical, following
specifications and other information should be
documents should be available wherever applicable:
updated / revised based on
the present condition of the (A) Physical properties:
process. Care should be Physical state, calorific
taken for incorporation of all value, heat of
modifications. Field vapourisation, Boiling

10
 point, Vapour pressure, protective equipment
Melting / Freezing point, (PPE), emergency
Vapour density & treatment for exposure
specific gravity and release / spill
containment.
(B) Fire & explosion Hazards:
Flash point, Auto-ignition Note:
Temperature, Explosive Material Safety Data Sheet
limits, Burning rate (MSDS) : OISD-STD-114 on
'Hazardous Chemicals and
(C) Reactive Hazards : Their Handling' may be
The tendency of the referred.
material to react violently
when subjected to heat
or the presence of other 4.3.3 Process Technology
process chemicals,
water, air (oxygen) or Process technology
other possible information should include
contaminants. the following:

Hazardous a) Written process

combustion/decompositi descriptions
on products.
b) Process chemistry
(D) Health Hazard Data:
c) Process Flow
Personnel exposure Diagrams (PFD)
hazard properties (long
term & short term) d) Safe operating limits of
process parameters
Information of toxicity of like pressure,
the material and temperature, flow rate
exposure limit values etc. and the
such as Threshold Limit consequences or
Value (TLV), Short Term results of deviation that
Exposure Limit (STEL), could occur if operating
Permissible Exposure beyond the established
Limit (PEL), Lethal Dose process limits
50 (LD 50) etc.
e) Maximum inventory
(E) Corrosive properties of levels for process
the chemical, runaway chemicals
reaction and over-
pressure hazards f) Material and energy
(F) Information on fire fighting balances
media, use of personal

11
A block flow diagram (BFD)
showing major process
equipment and pipelines is a 4.3.4 Process Equipment
preliminary tool for Process equipment include
understanding about the columns, vessels, heat
process. Flow rates, exchangers, reactors, pumps
pressures, temperatures and & compressors, valves,
stream composition may be piping; drilling rigs & work-
indicated for better clarity. over rigs; cross country
pipelines; tanks, loading & un-
Process flow diagrams (PFD) loading facilities and other
are more elaborate than equipment that contain
block flow diagrams. PFD process chemicals. Design
should indicate all main data of process equipment
streams including critical should be documented and
valves. Major process should include the following:
parameters like flow rate,
temperature and pressure a) Materials of
should be indicated at the construction
ins and outs of major process
equipment and at the control b) Design specifications
points. Whenever necessary,
pump capacities, compressor c) Codes, standards and
power and other such relevant industry accepted
information may be engineering practices
mentioned. Major control used for design and
loops and key utilities may be fabrication
preferably shown in the PFDs.
d) Electrical classification
Piping and instrument
diagrams (P&ID) are the 4.3.5 Design basis for the pressure
detailed representation of the relief system and
plant. Each and every piece of arrangement of shut-down &
equipment, pipelines, valves interlock system should be
and instrument along with documented.
their interconnection are
shown and most appropriate 4.3.6 For the existing plants where
to show relationship between the codes used for design are
equipment and instrument. no longer in general use,
Information mentioned under design and construction of
PFD and all the components such equipment should be
of the control loops are documented. It should be
depicted to enhance clarity. ascertained that the
P&IDs should be updated equipment is still suitable
whenever any modification is for its intended use and
carried out. testing/inspection carried out

12
 for this purpose should be In performing the PHA for a
documented. new process or facility ,
special consideration should
4.3.7 When process technology be given to previous
requires departure from experience with the process
applicable codes, it should be and design circumstances ,
documented that the such as shorter- than - normal
equipment is suitable for the design periods or changes in
intended use. the design team or the design
itself after the project is under
way.
4.4 Process Hazard Analysis
The purpose of Process
Hazard Analysis (PHA)) is to 4.4.1 Conducting Process Hazard
minimise the likelihood of the Analysis ( PHA)
occurrence and the Following considerations
consequences of a dangerous should be taken into
substance release by account for conducting PHA :
identifying, evaluating and
controlling the events that 1) A process hazard analysis
could lead to the release. should be performed for all
facilities and processes.
A PHA provides information
which assists in making 2) The process hazard
decisions for improving safety analysis should be
and reducing the appropriate to the
consequences of unwanted or complexity of the process.
unplanned releases of
hazardous chemicals. 3) The priority order of
conducting process hazard
The PHA of existing facilities analysis should be
should be performed in order determined and
of priority in terms of hazards documented based on a
of the process. A preliminary rationale which includes
hazard analysis may be useful such considerations as
in determining the coverage of extent of the process
the process safety hazards, number of
management standard. The potentially affected
factors like quantities, employees , age of the
susceptibility to failure, mode process, and operating
of failure, proximity, severity, history of the process.
process complexity, operating
history etc. should be 4) A PHA is directed toward
considered while establishing analysing potential
priority. causes and consequences
of fires, explosions,

13
 releases of toxic or failure scenarios should be
flammable chemicals and assessed using qualitative
major spills of hazardous or quantitative techniques
chemicals. judged to be appropriate.

5) The PHA focuses on c) Alternatives- Feasible

equipment, changes to reduce the risk
instrumentation, utilities, of occurrence and the
human action ( routine and consequences of the
non-routine), and external failure scenarios should be
factors that might impact identified.
the process. These
considerations assist in
determining the hazards 4.4.3 Methodology and Technique
and potential failure points The selection of PHA
or failure modes in a methodology or technique
process. should be influenced by many
factors including the amount
6) The process hazard of existing knowledge about
analysis should also the process, age of the
address to : process, operational
a) Human factors experience of the process,
b) A qualitative evaluation changes, limitations and
of a range of the assumptions
possible safety and
health effects of failure The PHA should take an
of controls on orderly , systematic approach.
employees in the One or more of the following
workplace. methodologies that are
appropriate to identify,
4.4.2 Basic Steps determine and evaluate the
Steps to be incorporated in hazards of the process being
PHA should include : analysed should be used.
What if, checklist, Hazard
a) Identification - Based on and Operability Study
the process safety ( HAZOP), Failure Mode and
information, expertise and Effects Analysis, Fault Tree
experience with similar Analysis, an appropriate
facilities, failure scenarios equivalent methodology.
that could result in
catastrophic release The application of PHA may
should be identified. involve the use of different
methodologies for various
b) Assessment - The parts of the process. A
likelihood and process involving a series of
consequences of the unit operations of varying

14
 sizes, complexities, and ages specifications, and
may use different regulations applicable to
methodologies and team the process being studied.
members for each operation.
The conclusion can be c) The selected team
integrated into one final study members need to be
and evaluation. compatible.

When there is large d) The PHA team can vary in

continuous process which has size from two people to
several control rooms for number of people with
different portions of the varied operational and
process such as for distillation technical back ground.
tower and blending operation ,
each segment can be done e) The team members should
separately and then integrate be fully knowledgeable in
the final results. the proper implementation
of PHA methodology that
is to be used and should
4.4.4 The Team be impartial to the
The process hazard analysis evaluation.
should be performed by a
team with expertise in
engineering and process 4.4.5 Frequency
operations , and the team The process hazard analysis
should include at least one should be updated and
employee who has revalidated by a team, having
experience and knowledge requisite back ground, at least
specific to the process being every 5 years after the
evaluated . Also, one member completion of initial process
of the team must be hazard analysis.
knowledgeable in the specific
process hazard analysis The PHA for a new process or
methodology being used. facility or modification in
Following aspects should be existing facility and
considered while constituting recommendations resulting
such teams : from the PHA should be
completed before start-up.
a) The team conducting the
PHA should understand
the methodology being 4.4.6 Recommendations and
used. Follow up
Following approach should be
b) The team should have adopted once
intimate knowledge of the recommendations of Process
standards, codes,

15
 Hazard Analysis are made taken. Written down
available: operating procedures should
be available for all process
1. System to promptly plants for safe operation.
address to the team's
findings and 4.5.2 Operating procedures should
recommendations should be based on process safety
be established. information so that all known
hazards are taken care of.
2. Recommendations should Operating parameters
be resolved in a timely should be consistent with the
manner and resolution process safety information.
should be documented.
4.5.3 The operating procedures
3. Written schedule should should provide specific
be drawn for completion of instructions on what steps to
the recommendations and be taken or followed while
should be monitored. carrying out the following:

4. The actions taken should (a) Startup - including

be communicated to the procedure for initial
operating, maintenance startup of the process or
and other employees who equipment as well as
may be affected by the startup after normal and
recommendations or the emergency shut downs.
actions.
(b) Normal operation -
5. Process hazard analysis, including limits of the
updates or revalidation for "normal" operating
each process as well as ranges for parameters
the documented such as pressure,
resolutions of temperature and flow,
recommendations should the consequences of
be retained for the life of operating outside these
the process. limits, and the actions
that should be taken to
correct or avoid deviation
4.5 Operating Procedures from the normal ranges.

4.5.1 Operating procedures (c) Temporary operation -

describe tasks to be including special
performed, data to be requirements while
recorded, operating conditions operating in the
to be maintained, samples to temporary mode and the
be collected and safety & acceptable duration of
health precautions to be the temporary operating
mode.

16
 IV. Fire protection/fighting
(d) Normal shut-down - facilities
including actions to be
taken to safely shut 4.5.6 Manuals should be available
down the process or to the employees. All
equipment and operators must understand
conditions to be avoided. thoroughly and should be
fully conversant with the
(e) Emergency operation operating manual. Training
and shut-down - should be imparted to the
including the conditions operators on operating
under which an procedures and should be
emergency shut-down is certified as competent.
required. This should
also include 4.5.7 Computerisied process
assignment of authority control system has added a
and responsibility to new dimension. Logic of the
qualified operators to software and relationship
ensure that shutdown is between the equipment and
executed in a safe and the control system should be
timely manner. described.

4.5.4 Operating instructions should 4.5.8 Operating manuals should be

be specific to the plant / facility. updated as often as
necessary. Every year,
4.5.5 Operating manuals should operating manuals must be
contain hazards of exposure certified as updated by
of the chemicals being competent person.
handled. Preventive methods
and control measures
adopted for exposure 4.6 Training
protection should be clearly Personnel in the plant /
brought out. These facilities should be trained and
information may be provided retrained for improving their
in a separate volume of the understanding and up
operating manual. MSDS grading skill in their area of
provides majority of such work based on identification of
information. Operation their training needs.
manuals should also describe
the following:

I. Purpose and function of 4.6.1 Initial Training

safety interlocks Each employee, before being
II. Equipment handing over involved in operating a newly
procedure assigned process, should be
III. Work permit system

17
trained in an over view of the e) Safety systems and
process and in the their functions

a) operating procedures f) Each employee should

viz., initial startup, be given training on
normal operations, operating procedures &
temporary operations, safe work practices,
emergency shutdowns emergency
including the conditions preparedness or
under which disaster management
emergency shutdown plan, safety
is required, emergency procedures, work
operations, normal permit system and
shutdown and startup areas pertinent to
following a turnaround process safety &
or after an emergency health.
shutdown.
g) Each employee should
b) Operating limits viz. be explained action to
consequences of be taken in the event
deviation and steps of unwanted release
required to correct or of hazardous
avoid deviation. chemicals.

c) Safety and health

considerations viz. The training should also
properties of, and include/reflect
hazards presented by,
the chemicals used in I. current operating
the process, practice, changes that
precautions necessary result from changes in
to prevent exposure, process chemicals,
including engineering / equipment and
administrative controls facilities;
and PPEs.
II. on safe work practices
d) control measures to be to provide for the
taken if control of hazards
exposed(physical, air during operations such
borne), Quality control as lockout / tagout,
for raw materials and confined space entry,
control of hazardous opening process
chemical inventory equipment and piping
levels and and maintenance.
special/unique hazards

18
4.6.2 Refresher Training 1) Management should
Refresher training should be ensure that contractor
provided at-least every three personnel are trained in
years and more often, if the work practices
necessary to each employee necessary to perform their
involved in operating a job safely.
process to assure that the
employee understands and 2) Contractor should provide
adheres to the current & maintain work places,
operating procedures of the plant, equipment, tools,
process. machinery and so
organise construction
work that as far as
4.6.3 Training Documentation reasonably practicable,
Record should be prepared there is no risk of accident
containing the identity of the or injury to workers.
employee, the date of training
and the means used to verify 3) Contract personnel are to
that the employee understood be informed about the
the training. known potential fire,
explosion or toxic release
Refer OISD-STD-154 for hazards related to their
further information. job & the process and in
the applicable provisions
of the emergency
4.7 Contractors preparedness plan.
In petroleum industry where
contractors are deployed to 4) Contractor must ensure
accomplish various types of that each of their
jobs of different nature, it is personnel has received
very much essential to and understood their
formulate an elaborate system roles in safe working
for ensuring their safety at practices by preparing a
work place. Suitable space for record and should verify
contractors camp, if required, the efficacy of
inside factory area for any dissemination of the safety
construction activities to be information. He should
made available at a safe also ensure use of PPEs
distance from hazardous at work place.
area. The camp should be
dismantled on completion of 5) Contractor should ensure
the job. To meet the that each of their
requirement, following personnel follows the
measures should be safety rules of the owner's
incorporated in the system : facility including safe work
practices.

19
 reviewed , items needing
6) Contractor should keep attention from PHA's have
owner informed about any been resolved and personnel
unique hazard presented have been trained. The main
by their personnel's work. purpose of the review is to
reduce chance of some item
7) Management should being overlooked that could
ensure for regular safety create a hazard or introduce
inspection of its own as un-expected safety problem
well as contractors' as process is brought to
construction equipment / normal operating conditions.
tools & tackles by
competent person The management should
perform a pre startup safety
8) Contractor should assign audit for new facilities, for
workers only that job for modified facilities when the
which they are suited by modification is significant
their age, physique, state enough to require a change in
of health and skill. the process safety information
as well as for startup of
9) Contractor should be existing facility / plant after
made responsible for turn around.
application & enforcement
of safety & health Pre startup safety review
measures in respect of should confirm that
the workers at site and construction is in accordance
should maintain constant with design specifications,
liaison with management. Safety, operating,
maintenance and emergency
10)Management, while procedures are in place and
selecting a contractor, are adequate.
should obtain information
regarding their safety For new facilities, process
performance. hazard analysis is performed
and recommendations have
been resolved or
4.8 Pre-startup Safety Review implemented before start up
One of the most critical and modified facilities meet
period in an operation is the the requirements contained in
start up of the process. Before management of change
a new or modified unit is
started, a systematic check
should be made to ensure 4.9 Mechanical Integrity
that the equipment has been Mechanical integrity of the
installed properly, operating plant or the facility need to be
procedures have been ensured so as to perform

20
intended activities without the
chances of its failure. (a) Annual plan
Following aspects should be (b) Tasks and
taken into considerations: responsibilities
(c) Manpower (number
1. Applicable requirements and type)
of the codes of practices (d) Contractors, if any
should be met or (e) Equipment control and
exceeded & mechanical calibration
integrity should be (f) Control of spare parts
maintained by use of (g) System of work
clearly defined permits, records
maintenance, inspection (h) Recording of conditions
and corrosion control of parts during use and
procedures. replacement
(i) Incident reporting
2. Equipment used to
process, store or handle 6. The procedures, methods
hazardous materials and techniques should be
should be designed, so selected as to eliminate
constructed, installed and risk in carrying out
maintained to minimise the maintenance activities.
risk of releases of such
materials.
4.9.1 Mechanical Integrity
3. The overall maintenance Program
plan should be drawn Mechanical integrity program
taking into consideration should be in place to assure
the safety, reliability and continued integrity of process
quality objectives. equipment. The appropriate
working procedures, methods
4. Feedback from and techniques should used,
maintenance activities which are considered most fit
should be given to other for the purpose and in line
elements of safety with the codes of practices.
systems i.e. design &
operations for up-dation of Elements of mechanical
P&IDs and operating integrity program should
manuals as required. include:

5. Safety aspects with regard (a) Identification and

to organising categorisation of
maintenance activities equipment and
should be focused in the instrumentation, inspection
maintenance plan and and tests, training of
prioritised as below : inspection personnel,

21
 testing and inspection
frequencies, development Information should be
of maintenance documented covering
procedures, the following:
establishment of criteria 1. The list of process
for acceptable test results, equipment and
documentation of test and instrumentation should be
maintenance results, and compiled and categorised
documentation of to be included in the
manufacturer mechanical integrity
recommendations as to program. The list should
meantime to failure for include pressure vessels,
equipment and storage tanks, process
instrumentation. piping, relief and vent
systems, fire protection
(b) The information pertaining system components,
to process equipment emergency shut down
design should be systems, and alarms and
documented as to what interlocks and pumps.
were the codes and
standards relied on to 2. The list of equipment
establish good engineering should be prioritised to
practice. determine which piece of
equipment requires closer
(c) Documented system scrutiny than others.
should be in place to
confirm that equipment 3. Information pertaining to
complies with recognised the equipment in the
and generally accepted process should include
good engineering material of construction,
practices. piping and instrumentation
diagram, electrical
(d) For existing equipment classification, relief system
designed and constructed design and design basis,
in accordance with codes, ventilation system design,
standards or practices that design codes and
are no longer in general standards employed.
use, it should be
determined and
documented that the
equipment is designed,
maintained, inspected,
tested and operating in a 4.9.3 Inspection and Testing
safe manner. This should consider the
following :
4.9.2 Equipment Data

22
1. Inspection and testing
should be done on all 7. The relevant OISD
process equipment. standard and guidelines
should be used for
2. Inspection and test developing inspection and
procedures should follow maintenance systems.
recognised and generally
accepted good 8. Frequency of testing /
engineering practices. inspection should be
based on following
3. Each inspection and test considerations :
done on equipment and its
components should be a) Meantime between
documented. failure of various
instrumentation and
4. The applicable national / equipment parts would
inter-national codes and be known from
standards provide criteria manufacturer's data or
for external and internal operating experience
inspections including with the parts which
frequency and will influence the
methodology which inspection and testing
should be adhered to. frequency and
associated
5. Procedures should be procedures.
developed and be in place
to ensure that tests and b) Failure data from
inspections are conducted operating experience
properly and that should be documented
consistency is maintained and analysed.
even where different
employees are involved. c) The frequency and
methodology of test of
6. Internal inspections should process equipment
cover items such as vessel should be consistent
shells, bottom and head, with applicable
metallic linings, thickness manufacturer's
measurement for vessels recommendations,
and piping, inspection for national/international
erosion, corrosion, codes,OISD standards
cracking and bulge, / recommended
internal equipment like practices / guidelines,
trays , baffles, sensors and good engineering
screens for erosion , practices. Such
corrosion, or cracking and inspections/testing
other deficiencies. should be done more

23
 frequently if 1. The maintenance
determined to be procedure should address
necessary by prior to the safety aspects with
operating experiences. regard to organisation of
maintenance (system of
work permit and non-
4.9.4 Non-routine Work routine work), determining
Authorisation whether execution should
be on line/off- line,
Following issues should be regulations to be followed,
considered : harmonising with
1. All non-routine jobs should operation, incident
be carried out in line with reporting system,
OISD-STD -105. maintenance analysis, do
it one self or contract out.
2. List of non-routine jobs
should be prepared and 2. Use of personal protective
procedures defined to equipment should be laid
carry out them. down for specific
maintenance activities.
3. Roles and responsibilities
for work authorisation, 3. The task, role and
issue/receipt of permit, responsibilities should be
handing over, taking over defined
should be documented
and implemented. 4. Records of trend analysis
of machine and
4. In case of any change in equipment should be
procedures and practices taken into consideration.
system of proper
authorisation should be 5. The risks associated with
instituted. different phases of
maintenance should be
established.
4.9.5 Maintenance Procedures
The maintenance programs 6. All maintenance
and schedules should be procedures should be duly
reviewed and analysed to see authorised.
if there are areas where break
down maintenance is used 7. Maintenance manual
rather than an ongoing should be formulated,
mechanical integrity program regularly certified, updated
consisting predominantly of and approved.
preventive & predictive
maintenance.
4.9.6 Inspection and Test Results

24
 2. Criteria for acceptable test
Inspection programme should results should be well
cover the following : defined taking into
a) Each inspection and test consideration codes of
performed on the process practices, manufacturer's
equipment should be recommendation,
documented. anticipated life and
operating experience.
b) The list of process
equipment, components, 3. Any deviation accepted
instruments should be should be approved by
made for inclusion in the competent person.
mechanical
integrity/maintenance 4. Equipment deficiencies
program. which are outside
acceptable limits as
c) The documentation defined by the process
should identify the date of safety information should
inspection or test , the be corrected before further
name of the person who use or in safe and timely
performed the inspection manner when necessary
and test , the serial means are taken to assure
number or other identifier safe operation.
of the equipment on which
the inspection and test 5. Proper records for handing
was performed , a / taking over of equipment
description of the to be maintained.
inspection or test
performed and the results 4.9.8 Documentation of
of the inspection or test. Manufacturer's
Recommendations
4.9.7 Criteria for Accepting Documentation should cover :
Equipment after 1. Manufacturer's
Maintenance recommendations for
Following considerations periodic inspection /
should be taken into account testing / maintenance of
while accepting equipment equipment supplied by
after maintenance : them should be
1. Equipment that has been documented
out of service for
maintenance should be 2. In case of any deviation
taken over after due from the inspection
testing and procedure as
documentation. recommended by
manufacturers reason for

25
 the same should be of defence which is the
documented. controlled release of
materials through venting
to scrubbers or flares, or to
4.9.9 Training of Maintenance surge or overflow tanks
Personnel which are designed to
prevent unwanted
Training aspects should releases.
consider :
1. Appropriate training is to 3. The above two are the
be provided to primary line of defence or
maintenance personnel to means to prevent
ensure that they unwanted releases. The
understand the preventive secondary line of defence
maintenance program would include fixed fire
procedures, safe protection system like
practices, and the proper sprinklers, water spray or
use and application of deluge systems, monitors
special equipment or etc. Dykes, designed
unique tools that may be drainage systems and
required. other systems will control
or mitigate hazardous
2. Maintenance training chemicals once an
should be integrated with unwanted release occurs.
overall training program
and records should be 4. The primary and
documented secondary lines of defence
should be protected by
3. The frequency and mechanical integrity
contents should be in line program and strengthened
with OISD -STD-154. where ever necessary.

4.9.10 Line of Defence 4.9.11 Quality Assurance

Following aspects should be The quality assurance

considered for safety of plant : program is an essential part of
1. The first line of defence is mechanical integrity program
to operate and maintain and will help to maintain the
the plant and the process primary and secondary line of
as designed and to keep defence that have been
the hazardous materials designed into the process to
contained. prevent / control / mitigate
unwanted chemical release.
2. This line of defence is This require following :
backed up by the next line

26
1. In the construction of new assure that qualified
plants and equipment, it craftsmen are used to do
should be ensured that the job.
equipment as it is
fabricated is suitable for 7. Use of appropriate
the process application for gaskets, packing, bolts,
which they will be used. valves, lubricants and
welding rods should be
2. Appropriate checks and verified in the field and
inspections should be documented.
performed to ensure that
the equipment is installed 8. The procedures for
properly and consistent installation of safety
with design specifications devices should be verified
and the manufacturer's such as torque on the
recommendations. bolts on rupture disc
installations, uniform
3. The quality assurance torque on flange bolts,
system is needed to help proper installation of pump
that the proper materials of seals etc.
construction are used, that
fabrication and inspection 9. If the quality of the parts is
procedure are proper , and a problem, it may be
that installation procedures appropriate to conduct
recognise field installation audits of the equipment
concerns. supplier's facilities to better
assure purchase of
4. The maintenance required equipment which
materials, spare parts and is suitable for intended
components should be use.
suitable for the equipment
for which they will be used. 10. Any change in equipment
that may become
5. 'As built' drawings, necessary will need to go
together with certifications through the management
of coded vessels and other of change procedures.
equipment and materials
of construction need to be 11. Calibration /
verified and retained in the standardisation of all
quality assurance equipment required for
documentation. fabrication.
6. Equipment installation jobs 4.10Work Permit
should be properly In case work is required to be
inspected in the field for performed in the plant / facility
use of proper materials, by any person other than the
and procedures and to operating personnel of that

27
 area, a duly authorised written reduce downtime, reduce risk
permit should be obtained by to public, enhance knowledge
the person / agency executing of plants and process
the work before activities.
commencement of the work.
The procedure for
Based on the nature, the management of change
work would be undertaken should cover review of the
under different types of specification of piping and
permits. For example, equipment, process
following jobs should be engineering, instrumentation,
undertaken with the duly maintenance, relief, safety,
issued hot work permit : health, environment etc. After
implementation of the
Cutting, Welding, Excavation, changes, the training of
Road/Dyke cutting, Electrical personnel in accordance with
lock out / Energising, the changed process,
Confined space entry, Boxing updation of document,
up of a vessel, Working on equipment history cards, data
fragile roof structures, sheets etc. to be taken care of
Radiography, Material before commissioning of plant
Handling in operational areas, / facilities.
Crane operation etc.
The modifications may require
Refer OISD-STD-105 on Work changes in process /
Permit System for details. technologies, hardware,
addition, alteration or removal
of an equipment or a part of it
4.11 Management of Change from the plant, in piping
Management of Change system and process
refers to implementing any equipment, replacement of
change intended to bring in equipment or machinery that
any of the inputs to the plant / differs from the original
facility. equipment, change in
metallurgy, change in
Primarily, plants are modified instrument which may include
or changed in order to pressure, temperatures, flow,
achieve higher efficiency, set points, alarm points,
improve operability and safety, speed, logic and control
reliability, to accommodate parameters.
technical changes etc.
Another objective of carrying The procedure should be
out such modifications / established and documented
changes may be to prevent for implementing a change
mishaps, improve utilisation covering all the stages like
and optimisation of facilities, commissioning, operation,

28
 inspection, maintenance, A nearmiss incident is a little
review of performance of the better situation in that it is a
plant / facility. warning given before actual
injury. It gives an opportunity
Refer OISD-GDN-178 for concurrent control which
"Guidelines for Management has the advantage of
of Change" for details. This permitting corrective action
should be followed by all before an injury, illness, death
plants and facilities. or property loss.

Therefore, every incident and

4.12Incident Investigation and nearmiss incident must be
Analysis recorded and thoroughly
For the management, an investigated.
incident investigation is a
critical feedback about the 4.12.1 When to investigate
system of control of a hazard. Incident investigation should
Feedback control involves be initiated as promptly as
gathering information about possible but not later than 24
an occurrence or completed hours following the incident.
activity, evaluating that
information and taking steps 4.12.2 The Objectives of the
to improve the situation in the Incident Investigation
future. This form of control is The basic purpose of an
valuable as it helps prevent incident investigation is to
recurrence of the incident. determine the cause of the
incident and to formulate a
An incident is a failure in the system to prevent
control of any hazard that reoccurrence of such
results in un-planned event incidents.
like fire, explosion, run away
reaction release of toxic or
flammable material, injury or 4.12.3 Who Should Investigate
fatality. A workplace incident The immediate and first level
is an indication that investigation should be
prevention was ineffective and performed by the immediate
that prompt changes need to supervisor of the effected
be made. area. The immediate
Feedback control gives supervisor is closest to the
management the capability to scene, knows the nature of
use information on past the work, the employees who
performance to improve upon do the work, and the nature of
future performance and to the hazards associated with
meet planned objectives and the work.
acceptable standards.

29
4.12.4 What should an factors are elusive, an outside
Investigation Report expert can be engaged to
Contain provide additional knowledge.
A detailed investigation report, For accidents involving
prepared at the conclusion of hazardous chemicals or
the investigation, should exposure to toxic substances,
include at a minimum the date the services of an industrial
of incident, date that the hygienist may prove valuable.
investigation began, a
description of the incident ,
the factors that contributed to 4.12.7 Investigation by the
the incident and Committee
recommendations resulting In case of major incident,
from the investigation. Refer management should establish
OISD-STD-107 format for multi-disciplinary team to
further details. enquire into the incident. Such
safety Committee for an
4.12.5 Review of the Initial accident investigation has the
Investigation advantages of bringing in a
The results of the good mix of knowledge /
investigation should be viewpoints as also injects a
presented to and reviewed new dose of objectivity into
with the next higher level the investigation.
supervisor.
In case of catastrophe or
4.12.6 The Role of the Safety disaster where the losses are
Professional very large and the
A Safety professional should consequences are severe, a
also be called in to review the senior level of inquiry or
investigation. An independent investigation may be instituted
review and a second opinion and assigned with completing
in such situations will help. an independent investigation.

If necessary, a second
investigation should be 4.12.8 Salient Parameters for
performed. The safety Incident Investigation
professional can conduct a The incident investigator's job
joint investigation with the is to gather all available
primary investigation. information to essentially
explain how the accident
The primary safety happened and how the
responsibility still rests with occurrence may be
the immediate line prevented.
management. When the
nature of the accident is The investigation should be
complex and the causative open to input from all

30
persons who were directly or Where did the incident
indirectly involved in the happen? Where was the
accident. The primary thrust of immediate supervisor /
the investigation should not operating personnel at the
be to cast blame but should time of the accident?
be to prevent it's reoccurrence
(4) "When" Questions
The six key questions that When did the incident
should be asked and happen? When did
answered are who, what, controls fail to protect?
where, when, how, and why This question should not
as below : be answered by a simple
hour, day, and month
(1) "Who" Questions answer. The time of
Who was injured? Who occurrence in
witnessed the accident? relationship to the
Who was involved in process cycle and
responding to the equipment timing must
accident? Who contributed be determined. So is the
to causing the accident, if time in relationship to the
any? Who has immediate work activities of other
responsibility for safety workers in vicinity /
and health of the work related functions.
area?
(5) "How" Questions
(2) "What" Questions How did the incident
What occurred (the happen? How did all the
complete sequence of physical conditions and
events should be human behavior come
determined). What together and combine to
equipment, process, or cause the accident? How
facility was involved? What well did the safety
chemicals or energy was controls (all types from
involved? What Safety engineering to
controls failed to protect? administrative) work or
What did the injured fail? How was personal
worker do or not do? protective equipment
What did others do or not used or not used?
do? What did
management do or not (6) "Why" Questions
do? What Safety factors Why did the incident
did management fail to occur? Why the controls
recognize and evaluate? fail to protect? Why did
the workers not recognize
(3) "Where" Questions the hazard. Why did the
worker fail to evaluate the

31
 hazard. Why was the accident has been
management unable to obtained.
prevent the incident from
taking place? 4.12.11 Findings Should be Put
into a Written Report
Some of the above A major accident or exposure
questions overlap, but the will generate a significant
investigation must be amount of investigative work.
thorough. Regardless of The effectiveness of the
the investigation is being investigation is enhanced by a
done by the first line well written report. A written
supervisor or by a report is a permanent record
Committee , the above of the results of the
questions should be investigation.
raised and the best
answers found. The 4.12.12 Communicating the
accident can then be Report
properly analyzed after One of the basic purposes of
getting the above the written report is to
questions answered. communicate the findings of
the investigation within and
outside the organization.
4.12.9 Analysis of the Incident Thus, careful thought must be
After all the facts and data expended to determine to
have been gathered, the whom the written report
information must be should be released. Additional
analyzed . The function of thought must be given to the
analysis is to organize the legal ramifications of such
information and mentally records and documents.
synthesize the raw
information into useful ones to 4.12.13 Legal Ramifications of the
arrive at conclusion. Accident Report
Every written report,
document, and physical
4.12.10 Follow-up Questions record have legal
If necessary, after the initial ramifications as they have
facts have been collected and legal significance. The most
digested, a set of follow-up obvious is that they constitute
questions may be raised. Like evidence which may be used
a computer routine, the same during a trial to prove or
Who, What, Where, When, disprove a fact that is under
How, and Why questions may dispute. For this reason alone,
be pursued except with a report should be prepared
greater accuracy. The basic with the realization that it can,
idea is to fine-tune the inquiry one day, be used as evidence
until the sharpest picture of or proof in a legal proceeding.

32
 Incident investigation reports
4.12.14 Post Investigation Actions to be retained for minimum
A system should be period of five years in order to
established to promptly determine if an incident
address and resolve the pattern develops or exists.
report findings and implement
recommendations. Resolution
and corrective actions should 4.13Emergency Planning and
be documented. Response
The basis for the Emergency
The report should be Preparedness Plan should be
reviewed with all affected derived from the hazard
personnel whose job tasks analysis and the
are relevant to the incident consequences of identified
findings including contract Maximum Credible Accident
employees when applicable. scenario. The objective of the
emergency plan is to provide
Findings should be accessible a measures to contain and
to all departments and minimise the effects of such
personnel concerned. incidents.
Communication methods may
be safety bulletins, newsletter, 4.13.1 On-site Emergency Plan
meetings, revision of should contain the following
procedures etc. It is important key elements :
to prepare information in
suitable form for the intended a) Early warning/alarm
recipient. system
Providing an early
There should be a system of warning system is
maintaining an incident data recommended as a
base wherein information is standard procedure as it
properly recorded in a form has an advantage of
suitable for easy use. initiating basic action to
control over the
Trend analysis of causes of emergency situation. The
incidents is vital and help in warning system can be
setting priorities to reduce risk via telephone, fire sirens
potential. Information etc. Alarm system should
gathered on various incidents have distinctive signal for
provides immediate lessons. fire & other
In long term, it useful in emergencies.
monitoring performance
changes, building up a data b) Immediate response
base on plant history and Procedures / Measures
trend analysis . It is essential to list down

33
 immediate action in case their duties should be
of an emergency and identified in the plan. The
nominate people / control room will be
positions to perform the activated in case of an
initial task. The people emergency to direct and
and positions coordinate the
nominated for such task operations to handle the
must be available round- emergency. It should be
thc-dock at the site. This furnished with external
goes long a way in and internal telephone
mobilising further connections, PA / Paging
resources in controlling / VHF etc.; list of
the emergency. essential telephone
numbers; list of key
c) Manpower / personnel and their
Organogram and their address; fire fighting
responsibilities system and site plan.
The organogram should Depending upon site
be drawn by appointing requirements, additional
key personnel and control room can be
defining their specific considered.
duties, which will be
handy in case of an e) Resource Mobilisation
emergency. The number Plan (internal /
of coordinators at a external)
location would depend The emergency plan
on the manpower in must contain resource
location. The roles mobilisation scheme so
identified for the that key personnel will
positions should be be able to activate the
consistent with the scheme to mobilise the
normal day-to-day internal & external
responsibilities of the resources within shortest
personnel. time available. Such
plan must contain
d) Emergency Control identified resources
Room needed and its
The emergency control availability, location and
room location should be activation methods.
identified in the plan. The
emergency control room f) Mutual Aid
should be set up at a It is one of the major
safe location and resources for fire fighting
marked on the site plan. and emergency handling.
The personnel manning Mutual aid arrangements
the control rooms and are to be worked out in

34
 the plan to facilitate Sketches
additional help in the
event of fire fighting or in i) Layout showing various
rescue operation by way facilities, fire fighting
of rendering manpower, system, hazardous
medical aid or fire zones and
fighting equipment etc. accompanying
assembly point(s) and
g) Evacuation control room.
procedures / Assembly
Points ii) Address and telephone
In a major emergency, if numbers of Emergency
it is essential to evacuate coordinators and key
the non essential persons in the location;
personnel from affected Mutual aid members;
area it is advisable to Fire Brigade; Police
have a plan for and Hospitals; Higher
evacuation. There officials at region / zone
should be pre- / HO; Government
designated areas where officials like District
the personnel like Collector, Inspector of
workers, staff, Factories,
contractor workers etc. Commissioner of
not involved in Police; Local controller
emergency operations of Explosives.
(as per Emergency
Preparedness Plan) iii) List of fire fighting &
should assemble in case safely equipment
of an emergency. available at location.
Depending on the
location of the iv) List of Do's and Don'ts
emergency, the during emergency
assembly point can
vary. For each potential v) Formats for reporting to
hazardous zone, a Govt. Authorities, Local
specific assembly Agencies, Police and
point(s) should be Hospitals.
identified and marked on
the zones/maps. During vi) Material Safety Data
emergency, Pre- Sheet (MSDS) for
designated persons each hazardous
would take charge of this product handled in
point and plan for the location.
necessary evacuation.
4.13.2 Information to public
h) List of Attachments,

35
 The safety measures to be provides management with
taken in the event of an the status and measurement
emergency should be made of effectiveness of the various
known to the general public safety system elements and
who are likely to be affected. activities and leads to the
appropriate control over these
4.13.3 Training / Drills and efforts.
Updating of the On-site
plan Following three types of
Mock drills activating the safety audits should be
Emergency Preparedness carried out:
Plan should be conducted 1. Internal Safety Audit
periodically for ensuring its 2. External Safety Audit
efficacy during emergency as 3. Safety Management
well as for refinement and System Audit
updation. The above drills
based on the plan will help to
achieve the following 4.14.1 Internal Safety Audit
objectives :- Internal Safety Audit is
important as it is carried out
a) to familiarize emergency by the personnel who are
response personnel with deeply involved in the
their roles and duties to operation / maintenance of
be performed. the facility, thus are aware of
each and every aspect of it.
b) to ensure the efficacy of Therefore, such audit can
the emergency response best bring out any
mechanism. shortcoming in the work area.
Following methodology should
c) to check the coordination be followed for such audits:
of reactions and
response of emergency a) Processing, storage,
services. handling and
transportation facilities
d) to gain experience and should be audited once
confidence, in a year.

4.14 Compliance Audit b) A calendar containing the

Safety Audits are the periodic area, names of auditors
examination of the functioning and period of audit should
of safety system. It gives an be prepared for every
idea about how effectively the calendar year in advance
safety system is implemented and be circulated to all the
and how they are being departments and
accomplished. It is the feed concerned area managers.
back mechanism that

36
 c) Areas to be audited should committee
be logically grouped based recommendations of fires and
on functions. incidents. The audit team
should give more
d) Audits should be carried emphasis on system audit as
out through a multi- safety survey is carried out by
disciplinary team. the internal safety audit
team. Environment and
e) Detailed guidelines occupational health aspects
including checklists as may also be included in ESA.
given in OISD-GDN-145 Report of the audit team
on 'Internal Safety should be submitted within a
Audits' should be reasonable time frame.
followed.
Time bound action plan
f) A time bound action plan should be prepared for
should be prepared for implementation of the
implementing audit recommendations and the
recommendations. same should be closely
monitored.
g) Implementation status of
the recommendations Board of Directors should be
should be reviewed in the appraised about the
Management Safety implementation status of the
Committee Meetings. recommendations twice in a
year. Whenever, any
recommendation cannot be
4.14.2 External Safety Audit (ESA) implemented, specific
External Safety Audits are approval should be obtained
carried out by a team of from the Board of Directors.
experts. The duration of the
audit may be two to five days.
Location management 4.14.3 Safety Management System
should make a presentation Audit
for the audit team giving brief Compliance of the Safety
description of the process Management System, as per
plants / other facilities and the this document, should be
safety management systems. assessed by carrying out
The audit team should study compliance audit once in 3
the different manuals, years. Companies should
technical documents, develop their own
implementation status of methodology for such audits.
recommendations of internal Care should be taken to
and external safety audits, select team member /
risk analysis / HAZOP members who have adequate
studies and enquiry experience and training for

37
 auditing safety management
system. Such audit report 4.16 Off-the job Safety
should be reviewed at an Off-the-job safety is a worthy
appropriate level with a view goal in its own right. Analysis
to update the procedures. of the off-the-job injuries and
rates normally shows that
4.15 Occupational Health they are more costly than lost-
The successful time on-the-job injuries.
implementation of Encouraging employees to be
management plans and safe away from the work help
polices greatly depend on its to preserve skills that could be
adaptability by the personnel temporarily or permanently
(employees) and maintaining lost. It has added advantage
their health is vital for of keeping the absenteeism
productivity and effectiveness. low.
As such, their health should
be strongly emphasised in the Further, being careful
organisation's strategic plan. everywhere creates good
Promotion of health of mindset. Individual's
employees in the widest concentration on the job is
sense, should, therefore, be a likely to be enhanced by ones
high priority, both a goal and a concentration off-the-job and
challenge for the organisation. the plant or office is a
healthier and safer
To meet the above objective, environment because of it.
it is necessary to have a The benefits also are widely
structured Occupational shared throughout the plant or
Health Monitoring so as to
have a scientific basis for office communities. Following
decisions aimed at protection measures should be adopted
of human health from any to encourage off-the-job
possible adverse safety :
consequences of exposure to
the hazards in the (a) The company should
occupational environment. have policy to
encourage covering
Necessary engineering / off-the-job safety of the
administrative controls should employees.
be exercised to prevent
personnel from undue (b) The reporting and
exposure to various hazards analysis of the off-the-
at the work place. job injuries to
employees and their
Refer OISD-GDN-166 families should be
"Guidelines for Occupational encouraged.
Health Monitoring in Oil and
Gas Industry" for details.

38
 (c) Findings of the analysis liability risks associated
of the off-the-job with every product sold ,
injuries should be every service offered
known to all the should be recognised and
employees through dealt with.
news letters / bulletins
(b) The organisation policy
(d) There should be topics and objectives should
covering off-the-job focus on long term
safety incorporated in commitment to
the news letters / continuously improve
magazines. performance in health,
safety and environmental
(e) Safety quiz, contests quality.
and competitions
should be organised for (c) Product and customer
the family members of safety should be managed
employees to motivate as an integral part of the
them towards off-the- business and marketable
job safety. feature of product and
services.
4.17 Customers and Products
Primary objective of the (d) Demonstration to the
management should be to public , government and
make available their customer customers of the
the intended product without organisation's intention to
causing any harm to human be socially responsible
and the environment. supplier of products and
services
It can further be elaborated
as below: (e) All statutory guidelines
with regard to health,
4.17.1 Customer and Product safety and environmental
Safety Goals aspects of products in their
manufacture, processing,
The product and customer storage, transportation and
safety goals of the marketing should be
organisation should be incorporated in the safety
defined to ensure that every procedures and manuals
product is manufactured, and updated as and when
transported, used and there is a change.
disposed off safely. It should
cover the following : (f) Intermediate custodians
including transporters,
(a) The potential safety, dealers and distributors
health, environmental and should understand and

39
 accept the safety policy (iii) Existing products
and commitment to New uses or markets for
product and service safety existing products should
of the organisation. be evaluated to ensure
that health, safety and
(g) Roles and responsibilities environmental hazards
should be defined with and risks are identified and
appropriate procedure. addressed.

(iv)Records and
4.17.2 Products Safety documentation
Procedures Records of assessment ,
background information
Risk associated with the and conclusions should be
product should be kept up to date through out
analysed, defined, the product's life and
controlled and instructional retained as appropriate.
material should be
developed for the same. It
should cover the (v) Product Information/
following : Material Safety Data
Sheets
Up-to-date information on
(i) New products health, safety and
Assessment should be environmental hazards
made for new products and risks relating to use ,
prior to marketing and storage , handling,
distribution to identify transport and disposal of
health , safety and products should be
environmental hazards available to the workforce ,
with normal use and customers and community.
foreseeable misuse. The database on products
should cover following
(ii) Periodic reassessment of aspects:
products
Synonyms of chemical
Periodic reassessment names, target organs of
should be conducted for all chemicals, first aid
manufactured, rebranded requirements for skin, first
products and intermediate aid requirements for eye,
streams. This includes a first aid requirements for
review of adverse effects swallowing, first aid
reported or experienced by requirements for
those handling these breathing, symptoms of
products. exposure, protective
clothing requirements,

40
 washing instructions, to these programs. The
clothing change quality standards and
requirements, clothing system should be
removable requirements, documented and updated.
protective eye gear
requirements. OISD-STD-
155 on Personal 4.17.3 Customer Service ,
Protective Equipment Education & Awareness
should be referred to.
The following system
(vi) .Reporting adverse effects should be in place:
of product
(a) Receiving and
System should be documenting customer
developed and in place complaint with regard to
to collect and review safety, health and
adverse effects reported environmental aspects of
or experienced by those the products and
handling the products. services:
Causes for concern All customer complaint
should be identified and should be reviewed at
actions should be taken. appropriate level and
action taken for
(vii)Product quality manufacturing,
certification: distribution and
Products should be inspection process to
properly classified, prevent its recurrence.
described, packaged,
marked and labelled and (b) Formal system for
should be in proper responding to the
condition for complaint to the
transportation in satisfaction of the
accordance with the customer:
applicable regulations. An effective recall
system should be in
(viii)Environmental and place for products and
Quality standards / services where defects
systems: could give rise to health,
Environmental and quality safety and environmental
systems should be in hazards.
place to assess hazards to
employees, community Education should be imparted
and environment and to to the customer on the
take corrective measures following:
by defining compliance
programs and commitment

41
 1) Dissemination of Product safety management
product knowledge should be a line responsibility
and aligned with the business
2) Establishing effective goals. Activities should
method/channel/mediu include :
m of communication
a) System for disposal of
3) Safe use of product product found not meeting
laid down standard/
4) Critical information to specifications should be in
be furnished on the place.
product / package
b) Training tools and
5) Emergency action and communications including
first aid labels and material safety
data sheets should be
6) Identification of prepared ,kept up-to-date
target/vulnerable and distributed.
customers
c) Applicable environmental
7) Inspection of product/ guidelines and other
packaging on receipt standards should be in
by the customer place

8) Information on crisis d) All product safety records

communication/emerge should be maintained.
ncy cells
e) System should be in place
9) Do's and Donot's in to respond on 24hr basis
understandable fashion to emergency requests
and calls. Emergency Cell
10) Creating customer for handling emergency
interest involving products and
services at customer
11) Formation of customer premises should function
council round the clock

f) Excellence in product and

service safety should be
rewarded.

4.17.5 Investigation of Incidents

4.17.4Activities related with during Product Handling,
Product and Customer Transportation and at
Safety Customer Premises

42
 1) Establish accident as per standards and driven
investigation policy & by competent personnel. To
procedures meet the objective, following
aspects should be taken into
2) Establish team, level, task considerations :
and authority for accident
investigation.
4.18.1 Vehicle
3) Set up check list, guide
lines for identifying the Design of the vehicle should
immediate and under lying be in accordance with
causes Petroleum Rules, SMPV
Rules 1989 and OISD
4) Control coordination with standards.
others involved police, fire
brigade, CCOE, insurance Periodic Inspection of vehicles
5) Set up communication should cover the following :
procedure and collect
relevant information 1. Periodic statutory
inspection in line with
6) Activate investigation as SMPV rules, petroleum
quickly as possible. rules should be carried
out by competent person .
7) Support
investigation/analysis by 2. Inspection at the loading /
tests and checks of unloading locations should
equipment and product. be carried out and
documented in line with
8) Analyse all incidents for the provisions of SMPV
common causes- Rules, Petroleum Rules
management system, and OISD standard.
installations, technical
systems, materials , tools , 3. System should be in place
procedures , tasks. to correct the deviations
observed during inspection
9) Implement preventive of vehicles through the
measures. contractors with corrective
actions for non-
4.18 Road Transportation implementation.
Large volumes of petroleum
products are transported The relevant provisions of
through road in tank trucks. To Central Motor Vehicles Rules
ensure safety of product and should be adhered to.
human beings involve directly
or indirectly, it is essential that
such vehicles are designed

43
4.18.2Creating a Road Safety driving and how to reduce
Culture them.

Following actions would help g) Focussed training to the

creating road safety culture : crews in line with CMV
Rules 1989 and OISD
(a) Motivation to improve road standards
safety performance
h) Inspection/audit,
(b) Assigning responsibility corrective action
and accountability to
improve road safety
performance 4.18.4 Transport Safety Activities
This should cover the
(c) Participation and following :
involvement at all levels
i.e. transporter, crew, I. Establish transportation
organisation. safety standards,
procedures and
(d) Prioritising road safety controls

II. Ensure compliance to

4.18.3 Transport Safety System standards/specification
Following aspects should be s for vehicle,
considered : accessories, fittings
and spare parts
a) Develop activities in line
with company HSE III. Prepare and implement
policies and strategies procedure and
schemes for inspection
b) Organisation with defined of vehicles and fittings
responsibilities.
IV. Establish driver/helper
c) Implementation of competence
standard / specifications / requirements and
practices, monitoring and responsibilities
corrective action
V. Assess/review training
d) Raise awareness and needs of drivers based
standards on performance and
provide necessary
e) Accident analysis and training
corrective measures
VI. Develop performance
f) Improving awareness of indicators for the
drivers to the risks of

44
 vehicle, drivers,
contractors XVI. Thorough investigation
of all accidents and
VII. Establishment of road follow-up measures.
safety committees for
identification and XVII. Inspection/audit of
mitigation of risk in transport operations
road transportation. and follow up on action
items.
VIII. Select, assess, qualify,
contract and XVIII. Feed back from
periodically re-evaluate contractors on matters
contractors affecting their safety
performance.
IX. Monitor contractor
performance XIX. Prepare and ensure
that relevant TREM
X. Co-ordinate with cards are provided to
contractors to improve transporters.
safety performance.

XI. Discontinue use of

poor performers 4.18.5 Defensive Driving
By exercising the defensive
XII. Continuously survey driving skills, the drivers
the market to identify maintain a safety zone around
new contractors who the vehicle. The defensive
can provide services driving skill is intended to
with required quality make allowance for the
and HSE standards. followings-

XIII. Create movement a) Handling characteristics of

schedules , monitor the vehicle
journey times and
routes b) A lack of skill and
knowledge or
XIV. Constitute road safety unpredictable actions on
committees with the part of other drivers
company employees ,
contractors and crews. c) Vulnerability and
unpredictable behaviour
XV. Set target and measure of pedestrians and cyclists
road safety
performance for d) Unpredictable behaviour
employee, crew and of animals
contractors.

45
 e) Hazardous climate
conditions (b) Knowledge and
understanding of
road safety
The skill and art of defensive legislation /rules /
driving should be inculcated regulations.
with the drivers by
management through - (c) Emergency
response
(i) Improving awareness including fire
fighting.
(ii) Sharpening the skill of
observation, (d) General vehicle
perceptions and operations and
anticipation mechanics of the
vehicle.
(iii) Providing time for the
driver to correctly (e) Vehicle
assess and respond to inspection
a developing situation.
(f) First aid
(iv) Educating on
Hazardous road (g) Product safety
features, e.g. curves, knowledge
hills, narrow roads,
bridges, absence of
signs, or signals and (II) Management should
obstructions. ensure the following :

(v) System of assessment a) Legal requirements

of driver training
program in line with b) Emergency response
OISD-STD- 154 and crisis
should be in place. management

4.18.6 Safe Driving Assurance c) The main causes of

road accidents
(I) Competence profile of
drivers transporting d) Product knowledge
hazardous products
should be as follows : e) Evaluation of
contractor's
(a) Defensive performance
driving skills
should be f) Safety inspections of
identified vehicles and drivers

46
 concentration,
g) Accident investigation attitude.
techniques and
analysis (g) Attitude -
tendency to over
h) Scheduling ,routing speed,overtaking,
,and journey positive/negative
management
(h) Documentation/re
(III) Assessment of cords- Available,
driving skill should up to date,
include : authentic

(a) Use of controls - 4.18.7 Performance Measurement

Accelerator,
clutch, brakes, Following indicators should
gears, steering, be pursued for performance
mirrors measurement :

(b) Reversing - a) Number of potential

Control, accuracy, incidents reported
observations
b) Setting targets for
(c) Road procedure - transport safety activities
Move off/stop, and its realisation
signalling,
positioning and c) Implementation of audit
cornering, use of recommendations
speed, lane
discipline, d) Reported near misses
overtaking.
e) Follow up of non-
(d) Reaction to - conformances found in
Signs, hazards, inspections related to
traffic lights vehicle / fittings during
loading, unloading
(e) Judgement - operations, non- standard
Distance, items / maintenance
length/width f) Cases of speed
violations/over taking
(f) General - resulting into accidents
maintenance of
progress,
temperament, 4.18.8 Emergency Rescue
observation, Operations
vehicle sympathy,

47
 This should cover the way that both employee and
following : contractor personnel will
(a) Each loading/unloading understand any hazard that
location should develop may be present and what
emergency rescue plan in precautions are necessary to
line with the OISD protect them from exposure to
standard. these hazards. Such
information is required for
(b) Such plan should broadly compiling process safety
include limits of individual information , developing
plants, emergency PHAs, developing operating
response preparedness, procedures, incident
communication linkages, investigations, emergency
emergency organisation planing and response etc. If
structure for required, confidentiality
transportation, emergency agreement may be made with
action plan action to the supplier.
handle specific scenarios.
Its objective is to prevent
(c) Mutually agreeable casual access to critical
emergency action plan for technical information about a
road transportation should process by limiting the access
be drawn in consultation to certain proprietary data.
with the neighbouring oil
industry and should be 5.0 References
implemented. I. OISD-STD-105 "Work
Permit System"
(d) Mock drill on emergency II. OISD-STD-107 "Format
handling in road for Incident Reporting"
III. OISD-STD-114
transportation should be
"Hazardous Chemical
carried out once a year. Data"
IV. OISD-STD-154 "Safety
4.19 Trade Secrets Aspects in Functional
Trade secrets means any Training"
confidential formula, pattern, V. OISD-GDN-145
process, device, information "Guidelines on Internal
or compilation of information Safety Audits"
that is used in the business VI. OISD-STD-155 "Personal
and that gives the employer Protective Equipment"
an opportunity to obtain an VII. OISD-GDN-166
"Guidelines on
advantage over competitors
Occupational Health
who do not know or use it. Monitoring"
VIII. OISD-GDN-178
The information needed about "Guidelines on
a process or chemicals must Management of Change"
be made available in such a

48
IX. 29 CFR Part 1910 OSHA
Rules, Process Safety
Management of Highly
Hazardous Chemicals
X. AIChE Guidelines on
Technical Management of
Chemical Process Safety,
1995

49