1. HIRA IN DOCKS FOR TRANSPORT OF HAZARDOUS CHEMICALS
S. S. Gautam, Director (IH)
Major Hazard & Chemicals Safety Division
Central Labour Institute
Sion, Mumbai

2. CHEMICAL HAZARDS IN DOCKS
Perpetual increase in the number of chemicals in ports.
Many of these are toxic, explosive, flammable, radioactive etc.
Each class of chemical needs specific precautions.
Scenarios are changing every day depending upon the types of goods handled.

3. STATUTORY COVERAGE ON CHEMICAL HAZARDS
Manufacture, Storage and Import of Hazardous Chemicals Rules 1989 –
For isolated storages and pipelines containing Hazardous substances in the quantities exceeding prescribed threshold quantities.
Dock Workers (Safety, health and Welfare) Regulations 1989 –
Provisions for hazard environment in holds and other confined areas.
Provisions for Handling of Dangerous Goods

4. RESPONSIBILITIES ENTRUSTED TO DGFASLI UNDER MSIHC RULES
Rule 5: Notification of major accidents.
Rule 7: Notification of MAH sites.
Rule 8: Updating of site notification on any change in relevant details.
Rule 9: Transition Provisions.

5. RESPONSIBILITIES ENTRUSTED TO DGFASLI UNDER MSIHC RULES
Rule 10: Safety Report.
Rule 11: Updating of reports under Rule 10.
Rule 12: Information to prosecuting authorities
Rule 13: On site emergency plans & mock drills
Rule 14: Participation in the preparation of off site emergency plan.

6. EP Act has empowered the following officers of the DGFASLI
Director General
Deputy Director General
Director (Dock Safety)
Joint Director (Dock Safety)
Deputy Director (Dock Safety)
Assistant Director (Dock Safety)
Additional assistant Director (Dock Safety)

7. LIMITATIONS
Responsibility to report on the following items not included:
Rule 4: General responsibilities of the occupier.
Rule 15: information to the persons liable to be affected.
Rule 16: Disclosure of information.
Rule 17: collection, development and dissemination of information

8. LIMITATIONS (Contd.) No power to prosecute:
Prosecuting powers retained with MOEF, Central & State Pollution control Board, district collector.
DGFASLI to forward the lack of compliance to the MOEF for further action.
Minor Ports remain unattended as DGFASLI covers only major ports.

9. INSTRUCTIONS TO INSPECTING OFFICERS by DGFASLI
Directives of DGFASLI to inspecting officers:
Inspection of identified MAH installations once in a year
Report of inspection to Chief Inspector within a fortnight
Annual report every year
Improvement advice in consultation with Chief Inspector

10. INSTRUCTIONS TO INSPECTING OFFICERS (Contd.)
Scrutiny of documents for identification of site and its forwarding to Chief Inspector within 30 days.
Information to Chief Inspector on any major accident.
Report of accident analysis to the Chief Inspector within 45 days.
Scrutiny of mock drill report and forwarding to the Chief Inspector with remarks within 15 days.
Liaise with district emergency authority for preparation of off site emergency plan.

11. IDENTIFIED MAH INSTALLATIONS IN MAJOR PORTS
Sl. No.
Port
Type of installation
Substances
Number
Remarks 1
Mumbai
Pipelines
Naphtha, LPG, Ammonia, Orthoxylene 5
Ammonia storage 2.5 km away 2
J.N. Port 3
Kandla
Pipeline & Storage
Orthoxylene,Ethyl alcohol, Ammonia.
Bezene, cyclohexane, acrylonitrile, Butadiene, ATF 6
storages nearby. 4
Morumgao
Motor Spirit, Phosphoric acid, Class A Petroleum
Isolated storages nearby.

12. IDENTIFIED MAH INSTALLATIONS IN MAJOR PORTS
Sl. No.
Port
Type of installation
Substances
Number 5
Kolkata
Pipeline
Ammonia, LPG, Crude 3 6
Paradeep
Ammonia, Phosphoric acid. 2 7
Vishakhapatnam
Pipeline & Storage 8
Chennai
Orthoxylene, Phosphoric acid
Naphtha, Styrine

13. IDENTIFIED MAH INSTALLATIONS IN MAJOR PORTS
Sl. No.
Port
Type of installation
Substances
Number 9
Cochin
Pipeline & staorage
Ammonia, Phosphoric Acid 2 10
New Manglore
Pipeline
Ammonia, Orthoxylene, LPG, Alcohol, Phenol 6 11
Tuticorin
Pipeline & storage
Naphtha, ammonia, phosphoric acid
LPG, VCM, Ethylene di chloride 3

14. NUMBER OF INSPECTIONS IN MAH SITES DURING 2007
Mumbai 00
J.N. Port 00
Kandla 18
Morumgao 03
Kolkata 12
Paradeep 08
Vishakhapatnam 02
Chennai 00
Cochin 12
New Mangalore 13
Tuticorin 00

15. PUBLICATION OF “GUIDE TO INSPECTION OF MAJOR ACCIDENT HAZARD INSTALLATIONS IN PORTS”
A comprehensive document was released during the year 1997 to all the inspecting officers which provides all the necessary information for effective inspection of MAH installations.

16. Contents of the Guidelines
General Guidelines for inspecting.
Standard formats have been provided for
Isolated Storages
Pipelines
Checklists have been provided for use during inspections.
After the inspection if improvement notice is required to be issued draft imprrovent notice should be sent to the chief inspector of dock safety.

17. Checklists & Formats Isolated storage inspection form.
Isolated storage inspection checklist.
Pipeline inspection form.
Pipeline inspection checklist.
Guidelines to the checklists.
Checklist for inspection of LPG.
Checklist for inspection of Ammonia.
Monthly progress report format.
Checklist for evaluation of onsite emergency plan.
Format for improvement notice.

18. ADDITIONAL INFORMATION IN THE GUIDELINES
Guidance notes on rules and schedules.
Technical information on static electricity, testing of pipelines, corrosion control monitoring.
Problems arising in pumps.
Problems associated with valves.
Prioritisation of MAH installations.
EP Act & MSIHC Rules.

19. PROVISIONS RELATING TO HAZARDOUS SUBSTANCES IN DOCK WORKERS (SAFETY, HEALTH & WELFARE) REGULATIONS 1989
Article 39: Dangerous and harmful environments
Article 76 to 82: Handling of dangerous goods.

20. DANGEROUS AND HARMFUL ENVIRONMENTS
When internal combustion engines are used in holds or confined spaces the conc. of CO should be kept within 50 ppm by adequate ventilation.
Entry into confined spaces where there is possibility of dust, fumes of gases, workers shall not be allowed unless the environment has been declared safe by testing by a competent person.

21. HANDLING OF DANGEROUS GOODS.
Before unloading any dangerous good, the ship owner will provide the statement in writing identifying the goods and nature of hazards likely from them to the employer of the workers, ports authorities and to inspector.
The shippers will also provide similar statements

22. CLASSIFICATION OF THE DANGEROUS GOODS
Explosives
Gases – compressed, liquefied and dissolved under pressure.
Inflammable liquids.
4.1 Inflammable Solids
4.2 Inflammable solids or substances liable to Spontaneous combustion.
4.3 Inflammable solids which in contact with water emit flammable gases.

23. CLASSIFICATION OF THE DANGEROUS GOODS
5.1 Oxidizing Substances.
5.2 Organic peroxides.
6.1 Poisonous (Toxic) substances.
6.2 Infectious Substances.
7. Radioactive Substances.
8. Corrosive Substances.
9. Miscellaneous Dangerous Substances.

24. DANGEROUS GOODS The regulations also provide: General Provisions.
Special Provisions for
Explosive and inflammable cargo,
Tetra ethyl lead
Toxic solvents.
Broken or leaking solvents.

25. CONCLUSIONS
The legal provisions available in the country ensure that the identified MAH installations in the ports require to prepare “Safety Report”, which is a comprehensive document covering most of the aspects of HIRA and emergency planning.
The status of the compliance could not be ascertained due to paucity of time, as the information available only with local Dock Safety Inspectorates.

26. For chemical cargo in packets, and vessels the provisions relating to dangerous goods are if effect. This at least ensure identification of type of hazards the cargo in likely to pose. The safety officers and the Dock Safety Inspectors at the port can subjectively assess the risk involve in the handling process and judiciously decide the safety measures to adopted while storage, handling and other operations involved.

27. There is need for more comprehensive regulations for dangerous goods to match with the internationals standards.
MAH related information for ports should be kept centrally available in website.
The minor ports under the jurisdiction of state governments should also be brought into the fold of MISHC Rules.
The prosecution powers should be extended to DGFASLI officials in order to increase the effectiveness of enforcement.

28. Thanks