On-site Emergency Preparedness National Workshop on Disaster Management 24-26 Sept 08 at Secunderabad, A.P. A.Y. Sundkar NATIONAL SAFETY COUNCIL As compared to natural disasters, industrial disasters represent a relatively new threat. Sine 1974 (Feixbrough Explosion) indl. Accidents have been increasingly in the news. The Itali, Seveso Dioxine leakale in 1976 concern the EC authorities leading to first Directive on MAHC For the first time, the focus of protection was made comprehensive to include community, env. and property instead of narrow focus on employees. In India the MAHC remained un-knwon concept till the Bhopal Disaster Bhopal Disaster – A Turning Point Rapid growth in use of Hazardous Chemicals leads to accidents, results in loss of life, property and damage to environment.

FEW MAJOR DISASTERS IN WORLD Sl. No Name of Chemical Involved Death Injury Place & Year 1 Methane 136 77 Cleveland, Ohio, USA 1944 2 LPG (BLEVE) 18 90 Feyzin, France, 1966 3 LNG 40 - Staten Island, New York, 1973 4 52 Mexico, 1985 2

EXPLOSION Sl. No Name of Chemical Involved Death Injury Place & Year 1   Sl. No Name of Chemical Involved Death Injury Place & Year 1 Dimethylether 245 3800 Germany, 1948 2 Kerosene 32 16 Germany, 1954 3 Cyclohaxane 28 89 Flixborough, UK, 1974 4 Propylene 14 107 Beek, Netherlands, 1975  

TOXIC RELEASE - Sl no Name of Chemical Involved Death Injury Place & Year 1 Phosgene 10 - Poza Rica, Mexico, 1950 2 Chlorine 7 Germany, 1952 3 Ammonia 30 25 Colombia, 1977 4 Methyl Isocyanite 2500 250000 Bhopal, India, 1984   4

Typical Layers of Protection Off-site Emergency Plan On-site Emergency Plan Physical Protection (Dikes) Physical Protection (Relief Devices) Automatic Action (Sprinkler, etc.) Critical Alarms, Operator Supervision, Manual Intervention Basic Controls, Process Alarms, Operator Supervision Typical Layers of Protection Mitigation system responses

Chemical Accidents in India (2002-06) Fire in LPG fired oven 28.10.04 Anil Enterprises, Zakhira, Rohtak 8. 5 8 Explosion 25.11.03 IDL Gulf Oil, Kukkatpally, Hyderabad 7. 19 Toluene 11.6.03 Ranbaxy Lab Ltd., Mohali, Punjab 4. - LPG leak - Tank lorry 5.10.03 BPCL Bottling Plant, Dhar 5. 88 Liquid Chlorine 13.10.03 Orient Paper Mills, Amla, Shahdol, MP 6. Toluene fire 6.7.04 HIL Udyogmandal, Kerala 9. Fire in Motor spirit Tank 7.3.03 IOC Refineries, Digboi 3. 18 W (300 vill) Chlorine Release 20.12.02 IPCL, Gandhar 2. 20 4 Chlorine Gas 5.9 02 GACL, Vadodara 1. Injury Death Impact Source Date Industry Sl. No. Product loss of Rs.11.5 crore

Chemical Accidents in India (2002-06) Sl. No. Industry Date Source Impact Death Injury 10. Shyamlal Industries, Vatva, Ahmedabad 12.04.04 Benzene fire - - 11. Chemplast, Metture, TN 18.7.04 Chlorine leak - 27 12. Chemical Factory, Dombivilli, Maharashtra 31.5.04 Hexane release & fire 1 8 13. Gujrat Refinery, Vadodara 29.10.04 Explosion in slurry settler 2 13 14. Ranbaxy Laboratories Ltd., Mohali, Punjab 30.10.04 Fire in Dryer room 1 2 15. Kekule Pharma Ltd. 23.11.04 Explosion 1 - 16. PWD premises 1.12.04 Chlorine release - 20 17. Gujrat Refinery 15.6.05 Fire - - 18. Coromondal Fertiliser, Ltd., Ennore 22.7.05 Ammonia - 5

Chemical Accidents in India (2002-06) Sl. No. Industry Date Source Impact Death Injury 19. Gulf Oil Corporation Ltd., Hyderabad 4.10.05 Explosion/ Fire 2 2 20. Orchid Chemicals & pharmaceuticals Ltd, TN 3.11.05 Explosion 1 4 21 IOCL, Mathura 29.12.05 Fire 1 - 22 Kanoria Chemicals & Industries Ltd , UP 29.3.06 Cl release 6 23 23 Anjana Explosives Ltd, AP 18.07.06 Spillage of haz chemical 5 - 24 Ravi Organics Ltd , UP. 19.9.06 Gas Release 1 - 25 RIL, Jamnagar 25.10.06 Fire 2 -

MSIHC Guidelines by MoEF, 1996 EMERGENCY … “A situation created by an accidental release or spill of hazardous chemicals which poses a threat to the safety of workers, residents, the environment or property” MSIHC Guidelines by MoEF, 1996

EMERGENCY PLAN … “A formal written plan which, on the basis of identified potential accidents together with their consequences, describes how such accidents and their consequences should be handled, either on-site or off-site” Guiding Principles: Chemical Accident Prevention Manual, OECD, 2003

Disaster Management … means a continuous and integrated process of planning, organising, coordinating and implementing measures which are necessary or expedient for: Prevention of danger or threat of any disaster; Mitigation or reduction of risk of any disaster or its severity or consequences; Capacity building; Preparedness to deal with any disaster; Prompt response to any threatening disaster situation or disaster; Assessing the severity or magnitude of effects of any disaster; Evacuation, rescue and relief; Rehabilitation and reconstruction The DM Act, 2005

EMERGENCY may caused by 1. Process and Safety System failure - Technical Errors (Design defects, fatigue, metal failure, corrosion, etc.) - Human Errors (neglecting safety instructions, deviating from specified procedure, etc.) 2. Natural Calamity 3. Sabotage/Terrorist Attack Natural Calamity – Orissa Super cyclone in 1999 damaged Phosphoric Acid Sludge containment Bhuj earthquake in 2001 leads release of acrylonitrile from tank

Emergency normally manifest in three basic forms Fire Explosion or Toxic Emergencies with chemical industry concern are : 1. Plant Emergency (On-site) Off-site Emergency 2. Transport Emergency

EMERGENCY PLANS To mitigate effects of Emergency requires – - Thoughtful Planning - Better Preparedness - Quicker Response Emergency Planning not substitute for maintenance of good safety systems, procedures and practices Accident Prevention through good design, operation, maintenance and inspection Efforts to reduce the scale and frequency of hazards Emergency Planning integral part of safety

EMERGENCY PLANS Emergency Planning is an important element of mitigation On-site & Off-site emergencies are separate but are to be consistent Transport Emergency requires different treatment The Plan should be kept simple and flexible, but capable of being scaled up or down as circumstances demand

EMERGENCY PLANNING STATUTORY FRAME-WORK

FACTORIES ACT, 1948 Section 41 A to H – Hazardous Processes Section - 41 B (4) Occupier to draw up an On-Site Emergency Plan & Disaster Control Measures for his factory Make safety measures to be taken in the event of an accident known to- - Workers - Public in the Vicinity

MSIHC Rules, 1989 MAH Installations – Threshold Quantity Industrial Activity at a Site Handling Hazardous Chemicals and Isolated Storage Equal to or in Excess of Threshold Quantities.-Schedules-2&3 column 3 Unit Isolated Storage AMMONIA : 50 T 60 T LPG : 15 T 50 T CHLORINE : 10 T 10 T

MANUFACTURE, STORAGE AND IMPORT OF HAZARDOUSCHEMICALS, RULES,1989 (MSIHC RULES) 13. PREPARATION OF ON-SITE EMERGENCY PLAN BY THE OCCUPIER (1) Occupier to prepare and keep up-to- date an On-Site Emergency Plan with specified details (Schedule11) detailing– - dealing with major accidents on site - name of the Person responsible for Safety on site - names of authorised persons to take actions as per the Plan in case of an Emergency.

MANUFACTURE, STORAGE AND IMPORT OF HAZARDOUSCHEMICALS, RULES,1989 (MSIHC RULES) (2) The Occupier to ensure that the On-Site Plan includes modifications and all persons on site affected by the Plan are informed accordingly. (4) The Occupier to ensure to conduct a mock drill of the On-Site Emergency Plan every 6 months. (5) Detailed report of mock drill to be made immediately available to the authority.

ELEMENTS OF ON-SITE EMERGENCY PLAN (Based on APELL Model) Elements are given in 11 broad headings APELL – A Process for responding to Technological Accidents - Developed by UNEP in 1986 - Implemented in India in 1992 in six-high risk Industrial Areas

Introduction Basis of the Plan Purpose and objective Legal Requirement Basis of the Plan Purpose and objective About Factory – location; name & address of the person furnishing the information, no. of people and brief process description This chapter suggests organisation for emergency preparedness. No Plan succeed without Emergency Organisation Key Personnel to combat emergency to be nominated with specific responsibilities according to set procedure – Incident Controller, Site Main Controller, other key personnel and essential workers

2. Plant Emergency Organization Designated person in-charge/alternates - SC, IC, Leader of communication, Fire & Rescue, Medical, Security, Logistics Functions of each key individual and group Telephone numbers (office and home) for key people/alternates Emergency Control Centre /alternate (ERC) Assembly Points This chapter suggests organisation for emergency preparedness. No Plan succeed without Emergency Organisation Key Personnel to combat emergency to be nominated with specific responsibilities according to set procedure – Incident Controller, Site Main Controller, other key personnel and essential workers

3. Plant Risk Evaluation Quantity of hazardous materials Location of hazardous materials (on Factory Layout) Properties of each (MSDS sheets) Likely Dangers to the Plant – Emergency Scenario (s) summary location-wise Location of isolation valves Special fire fighting procedures (if any) Special handling requirements Identification, analysis and assessment of hazards and risks provide vital information to risk management that what should be the type and capacity of its on-site and off-site emergency plan and what type of safety measures and maintenance are required. Listing of Hazardous materials – Raw material, finished, intermediate and bye products Process and vessel hazards and controls Hazards which are not classified as storage, process and vessels then hazards due to boilers, non-chemical pressure vessels, spills from pipeline or vessels, structural collapse, bad housekeeping

4. Area Risk Evaluation Properties of hazardous materials at nearby plants Nearby residence and population centre Contacts (names, telephone numbers) at other sites. Established procedures for notification of chemical releases at other sites in area Natural Calamities which can lead to emergency – Flood, Cyclone, Earthquake MSIHC Rule 14(2) – Occupier can seek any information from the Off-site Emergency Plan for preparing the on-site.

5. Notification Procedures & Communications Systems ● Declaration of Emergency ● Communication System Alarm Systems Communication equipment (radios, hot lines, etc.) Designated person for media contacts Procedure for notifying families of injured employees Central reporting Office (ERC)

6. Emergency Equipment and Facilities Fire fighting equipment Emergency medical supplies Toxic gas detectors (where needed) Wind direction/speed indicators Self-contained breathing apparatus Protective clothing Other on-site equipment to be specified according to local conditions Containment capabilities

7. Procedure for Returning to Normal Operations ● Authorisation ● Declaration of the end of emergency ● Communication of the Declaration of end of emergency

8. Training and Drills Training of Team Leadres Training of Emergency Responders Emergency Drill - Frequency and Responsibility (MSIHC – 6 months)

9. Regular Tests of Emergency Organization/Procedures Simulated emergencies Documented, frequent alarm system Frequent tests of fire fighting equipment Evacuation practice On-going emergency preparedness committee MSIHC Rule 13(4) – Mock drill of the on-site emergency plan conduced every six months

10. Plan Updates Annual or more frequent if needed Reflect results of drills and tests Review of the Plan Responsibility for updating the Plan

11. Emergency Response Procedures Communications Evacuation or safe haven Medical (include handling of multiple injuries) Special procedures for toxic gas releases (chlorine, etc.) Hurricane procedures (coastal areas only) Utility failure procedures Individual unit emergency procedures Bomb threat procedures

12. Detailed Operating Manuals (for each process unit and utility system) Start-up / Shut-down emergency procedures Analysis of potential incidents Emergency response and action to be taken for each incident

On-Site Emergency Plan – Separate Section “Information for use in the Off-Site Emergency Plan” which may include : Summary of Risk Analysis, vulnerability zone for those scenarios which can escalate into off-site emergencies. List of resources required to handle the off-site emergencies foreseen in the On-site Plan, their assessment of the adequacy. If own resources (such as equipment, trained man-power, medical help, etc.) are not adequate to meet such off-site emergencies, what is the arrangement (formal or informal) made to get the additional resources (e.g. Mutual Aid or arrangement with the Public Response Agencies) mentioning the salient terms of such arrangements.

Contents of the separate section contd… What resources can be spared by the industrial unit for use in the Off-site Emergency arising out of on-site emergencies of other units and what is the arrangement for releasing such resources. How Community awareness programme has been planned? How the community has been identified (from which zone-part or full vulnerability zone)? Have the key opinion makers who can play active role have been identified? (Give list alongwith their contact details). Has the selection of the community or that of key persons in the community been done in consultation with the District Authority? etc.

Contents of the separate section contd… Has Insurance under the Public Liability Insurance Act been obtained? Give summary. Designate a Contact person who would be authorised to co-ordinate for Off-site Plan and his contact details Technical Team (chemical-wise) in case of an Off-site Emergency taken place due to escalation of an On-site incident, contact details of its members.

THANK YOU

ORGANISATION CHART Security Gate No.2 or Security Gate No.4 Works Main Controller (WMC) Security Gate No.2 or Security Gate No.4 Support Team to WMC Logistics Team Leader - Traffic Control Team Incident Controller Communication Team Leader (Head – ER&D) Area In-charges of the Affected Areas Medical Team Leader - Plant Control and Shut Down Team Fire & Rescue Team Corporate Office at”

Cinema Hall Hospital Facility where Accident Take Place School

Alarm/communication System OISD Standard – 117 Fire Protection Facilities for Petroleum Depots, Terminals and Pipeline Installations Alarm/communication System Electrical/hand operated Fire Siren with code 1. Small Fire - No Siren 2. Major Fire - A wailing siren for 2 min. ( 3 times for 30 sec with an interval of 15 sec in between 3. Disaster - Same as above but interval of 2 min 4. All Clear - Straight run for 2 min. 5. Test - Straight run for 2 min.

Ref : Factories Act, 1948 MSIHC Rule, 1986 CA(EPPR) Rules, 1996 PLI Act Major Hazard Control – A Practical Manual by ILO Hazardous Material Emergency Planning Guide by National Response Team, USA

ON-SITE EMERGENCY PLANS GAPS OBSERVED IN THE ON-SITE EMERGENCY PLANS

Introduction Developed Off-site Emergency Plans - Tuticorin - Haldia On-site emergency if uncontrolled become off-site emergency Better on-site preparedness and therefore planning can avert off-site emergency. For preparation of Off-site Emergency Plan, On-site Emergency Plans (OEP) is the basis as there is close relation between them. Decided to scrutinise on-site plans 1. Rightly & legally preparation of OEP is the responsibility of the Occupier as he has necessary knowledge & expertise 2. Well developed and tested (rehearsed for its effectiveness, the OEP constitutes a good foundutaion for the Off-site Plan 3.Responsibility lies on Occupier 4.Responibility to submit information to authorities 5. On-site emergency lead to off-site

For scrutinising the OEPs checklist developed Introduction Contd. Scrutinised on-site Emergency plans of MAH Units by a team of NSC Officers and experts Tuticorin - 13 Plans Haldia - 16 Plans For scrutinising the OEPs checklist developed

In Plant Emergency Organization following were missing Gaps observed in OEPs In Plant Emergency Organization following were missing Alternative member to Designated persons Functions of key individuals/groups 24 hrs. telephone numbers for key persons and their alternates Emergency Control Room facility

quantity, type of storages and locations of hazardous materials Gaps observed in OEPs Plant Risk Evaluation Absence of information on: quantity, type of storages and locations of hazardous materials characteristics, dangers, toxicological data and emergency response of Hazardous Chemicals. Location of isolation valves Special fire fighting procedures (if any) Identification/ description of representative scenarios Development of the scenarios on real time basis Marking of Vulnerability Zone on layout plan including those which may escalate into Off-site emergences Listing of Hazardous materials – Raw material, finished, intermediate and bye products Process and vessel hazards and controls Hazards which are not classified as storage, process and vessels then hazards due to boilers, non-chemical pressure vessels, spills from pipeline or vessels, structural collapse, bad housekeeping

Consideration of Natural calamites triggering on-site emergencies Gaps observed in OEPs contd…. Area Risk Evaluation Emergency Scenario Consequences of accidents in neighbouring plants creating on-site/off-site emergency as a part of Area Risk Evaluation Consideration of Natural calamites triggering on-site emergencies Security arrangements to combat threats (sabotage, terrorist attack, etc.) i) Identification, analysis and assessment of hazards and risks provide vital information to risk management – process (vessel hazards), storage, or any other ii) Mass of release – Range for evacuation – Time required for contaminated air to reach

Notification Procedures and Communication System Gaps observed in OEPs contd…. Notification Procedures and Communication System Absence of information on: - Communication equipment (hot lines, Walky- Talky, etc.) - Neighbouring industry - Nearby residents - Designated person for media contacts - Procedure for notifying families of injured

Assessment of the resources by the Plant Management Gaps observed in OEPs contd…. Assessment of the resources by the Plant Management Absence of information about Trained Manpower (Technical, Medical & Fire fighters) ii) Emergency Equipment and Facilities: Fire fighting equipment Emergency medical supplies Toxic gas detectors (where needed) Wind direction/ indicators Self-contained breathing apparatus Protective clothing iii) Arrangement with organizations (formal or informal) for additional resources required to handle the emergencies Arrangement with organisations :

Types vis-à-vis level of participation, frequency of training Gaps observed in OEPs contd…. Training Types vis-à-vis level of participation, frequency of training

Simulated emergencies Testing and Documentation of alarm system Gaps observed in OEPs Regular tests of emergency organization/ procedures – Information not available Types vis-à-vis target groups, frequency, documentation, methodology of Drills Simulated emergencies Testing and Documentation of alarm system Frequent tests of fire fighting equipment Evacuation practice MSIHC Rule 13 (4) – Mock Drill every six months

In general there is no coverage of plan updates. In specific : Gaps observed in OEPs Plan Updates In general there is no coverage of plan updates. In specific : Frequency Reflect results of drills and tests History Sheets giving details of updates/revisions including date of Preparation of the Plan Responsibility on a person to update the Plan MSIHC Rule 13 (4) – Mock Drill every six months

Medical response procedure for handling multiple injuries Gaps observed in OEPs Emergency Response Procedures Not mention about Medical response procedure for handling multiple injuries Procedure for arrangement in case of utility failure Bomb threat procedures Location of Assembly Points and marking on the Layout Plan Escape routes

General Pages not numbered Absence of contents page Gaps observed in OEPs contd…. General Pages not numbered Absence of contents page Some cases the content does not match with the matter in the plan