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Safety is Driven by Culture, Not by Compulsion
The Chemistar factory might be a small chemical unit but then together such units employ more than 70 million people in India, and hence it really calls for strict safety measures in micro, small and medium enterprises, says V B Sant, Director General, National Safety Council (NSC). In an exclusive conversation with Harshal Y Desai, he further discusses 'Safety' and highlights the signifi cance of 'Safety Audits.'

A number of accidents in chemical factories have claimed several lives over the past few months. These accidents have raised serious concern over the Occupational Safety in India. May we have your comments?
It is definitely a matter of concern that industrial accidents are claiming so many lives in our country. As per the statistics published by the Labour Bureau, the number of fatalities as well as the frequency rate of fatal injuries in factories is increasing. To quote, the frequency rate of fatal injuries has gone up from 0.05 per cent in 2005 to 0.09 per cent in 2009, an increase of almost 50 per cent. These are disturbing trends.

The investigations into some of the major accidents including the IOCL Jaipur Depot fire in October 2009 have revealed lack of implementation of safety management system and poor safety culture in the organisations concerned. As a result, safety was compromised and short cuts were prevalent. Even the top management was neither aware nor concerned about the risks involved in day-to-day operations. There was a general lack of leadership for safety at all levels.

How do you evaluate the efficiency of safety audits carried out in India?
Safety audits are the means of examining the strengths and weaknesses in the Safety Management systems. The auditors on the basis of their findings make certain recommendations for improvement. The management is free to decide on the implementation of the recommendations. The status of implementation can be checked only if there is a follow-up audit. I cannot really comment on the efficiency of audits conducted by others. But I can certainly vouch for audits conducted by NSC. They are the best, as these are conducted by qualified and well experienced persons having industry's knowledge and expertise. Our auditors are having more than 25-30 years of experience in operations, maintenance and safety. Audits are always conducted by a team of at least 2-3 cross-functional experts drawn from our own organisation as well as from the pool of externals. We maintain highest standards of professional integrity and do not compromise on quality. That is why no major incident has been reported in the units covered in NSC audits during last several years.

Please apprise of safety standards in the country?
The standards of safety in chemical industry in India have come a long way since Bhopal disaster in 1984. A number of organisations have implemented OSHMS standards, some of them have been certified for Responsible Care, and some have received star rating from international agencies like British Safety Council, International Safety Rating System (ISRS) & International Chemical Council (ICC). Even for NSCI Safety Awards, the majority of awardees are from Chemical Industry. However, there is a further scope for improvement particularly in SMEs, which form more than 75 per cent of the chemical units in the country.

Where do we stand in terms of the quality of our safety standards if we compare it with the standards practiced internationally? How do you rank Indian safety standards?
In respect to chemical industry, our safety standards are at par with International standards. The problem is with level of compliance, seriousness and integrity of enforcement and extent of advocacy. This is more so with respect to small and medium scale units.
The National Policy on Safety, Health and Environment at Workplace envisages providing incentives for good OSH performance. However, we are yet to see any incentives for SMEs for OSH compliance and achievements. NSC has devised a separate scheme for this sector known as "NSCI Safety Awards scheme for MSME Sector".
After going through the data for last four years, I must mention here that the majority of the applications are received from chemical units. Thus, even in small scale units, OSH is being taken seriously now. This is a slow process, and large units, industry associations and government need to play a proactive role in promoting OSH in SMEs.

India is now a signatory to international conventions and it is a mandated to comply with the international norms as far as the exports are concerned. What about those who are selling the products only in domestic market?
As I have mentioned above, companies catering to domestic market are also becoming aware about OSH slowly. Particularly, many pharmaceutical, agrochemical and food processing units have adopted Good Manufacturing Practice (GMP) and Responsible Care (RC) approach. As a result, they are catching up with others.

To what extent the safety is compromised in India in the chemical industry in India?
SMEs comprise about 78 per cent of all manufacturing units, employing about 73 million persons and contributing around 9 per cent to our GDP.

These units find it difficult to comply with the international standards (OSH) due to their inherent weakness. Our own national standards also do not differentiate small, medium & large scale units. We need to frame separate standards for SMEs as provided in ILO-OSH 2001 Guidelines.

We need to develop Safe Operating Procedures (SOP) in simple and local language so that all can understand and implement them. The support of the government, pressure of the competition and encouragement from the large industries to whom they supply their products, will definitely go a long way in improving OSH in such small units.

Who tracks the accidents in the chemical industry? Is the industry is addressing the issues in terms of infrastructure, labour laws & environment?
We don't have Chemical Safety Board (CSB) in India. The Union Ministry of Environment & Forests (MoE&F) is the nodal Ministry in respect to chemical safety. Further, there are other Ministries i.e. Ministry of Chemical and Fertilizers (MoC&F), Ministry of Labour & Employment (MoL&E), etc. and Industry bodies like Indian Chemical Council (ICC), which also address these issues.

There is a proposal pending with MoL&E to have legislation on OSH applicable to all sectors of the economy. In this proposed legislation, a board on OSH is envisaged which will have power to investigate, issue guidance and directions etc. on all OSH matters. At present, the proposal is not in the priority list.

What does the law say and when was it revised last time?
There are several acts & rules relating to the subject of chemical safety. The Factories Act 1948; the Manufacture Storage and Import of Hazardous Chemicals Rules 1989; The Explosives Act 1884, the Petroleum Act, 1934, the Environment (Protection) Act 1986, are some of the statutes dealing with the subject. The Factories Act 1948 was amended in 1986 to include provisions relating to hazardous processes; whereas MSIHC 1989 was last amended in 2000/2004. The work on the revision of the Factories Act, 1948 is in progress for last 2-3 years.

How significant it is for Indian industry to raise the bar and meet the global standards for the safety of people and the environment?
As I mentioned earlier, the Indian Industry particularly SMEs need to raise their OSH Standards. The government should come forward and provide incentives, frame suitable standards on OSHMS particularly for small chemical units, issue guidelines on safety culture and establish a system for accreditation of OSH service institutions and professionals who can cater to different categories of chemical industries. Chemical safety rating system can also be introduced to reduce burden of inspection.

May we have your comments on devising a long-term strategy to secure lives of workers in chemical plant and creating inherently safe culture?
ILO have outlined their global strategy on OSH and identified two main pillars, i.e OSHMS and Safety culture. We need to adopt relevant OSHMS standards mandatory in all industries. Following steps may be taken by Government:
(a) Frame OSHMS standards in respect of different types & sizes of industry including chemical, small & medium scale units.
(b) Make these standards mandatory for all industries.
(c) Establish credible system for auditing & accreditation of auditors
(d) Frame standards on safety culture and issue guidelines for meeting those standards.
(e) Making safety culture survey mandatory in all chemical units.
(f) Provide incentive for OSH compliance and performance in OSH to SMEs.
(g) Recognise OSH performance at national level suitably.