1.

Executive Summary
2. Factory Information Sheet
3. HSE Management System
4. Fire Safety Management
5. Plant Site Safety
6. Emergency response & trainings
7. Security Control
8. Miscellaneous Points
9. Risk Rating
10. Graphical Representation
11. Conclusion

1. There is no Hazard Identification study or process specific safety study conducted for
individual processes. The BPR document covers the quality related aspects but does not
cover the hazards associated with the activities. A dedicated Hazard Identification and risk
assessment must be conducted for all the processes and the same must be mapped to
prepare SOPs for individual activities.

2. The fire detection system did not cover all the areas and it is not possible to add further
detectors to the wireless fire detection system. A FRLS wired fire detection system must be
provisioned with an addressable fire alarm panel provided in the security control room. All
the areas mentioned in the report must be covered while planning for detection system.

3. Health and Safety trainings were limited and were covered as part of other trainings. During
the site visit, some workers were unaware of the hazards associated with the chemicals they
were handling. A dedicated HSE training calendar must be prepared covering electrical
safety trainings, chemical handling trainings, hazardous material handling trainings, Static
charge hazards and control measures trainings and BBS trainings (Top to lower
management) as separate.

4. Over storage of chemicals were observed in the Badminton court area and Liquid chemical
storage area. The storage of some chemicals was observed outside directly under sunlight
due to lack of space. Storage of chemicals must be moved to another location or warehouse
with proper detection and suppression system.

5. An emergency response plan was available, however was found to be incomplete and did
not cover all the emergencies’ scenarios in the plant. The emergency response plan must be
updated as mentioned in the ensuing report covering all possible scenarios.
6. Firefighting systems were under capacity and only a jockey pump is available for firefighting.
There are only 4 hydrant points provided covering the complete plant and there are no
internal hydrant points for the plant area. A dedicated main pump and DG pump of
sufficient capacity must be available for firefighting as mentioned in the ensuing report. The
number of hydrant points must also be increased and provision for internal hydrant points
and first aid hose reels for the plant area.
1. HSE Management System
Sr.
Area/Process Observation
No.
A basic health and safety
policy statement and manual
has been made commonly for
both the units. Some of the
observations are as follows:
1. The health and safety
policy manual are
incomplete and can be
improved. The policy
manual did not cover the
sections for the process
Health and safety
1 safety identification and
Policy the hazards associated
with the process in the
plant.
2. The health and safety
policy were not displayed
at prominent locations like
at the entrance of the
plant and reception area.
Legal
Reference/Other
Objective Evidence Criticality Recommendation
requirement
(If Any)
1. The policy statement contains the
vision of the plant. Specific targets or
achievements can also be mapped in
the policy statement for each year
and can be updated every year.
A health and safety policy manual
must have the following sub
segments:
ISO 45001: Health a. Statement of intent mentioning the
and safety visions and goals of the management
Management
towards health and safety, it must be
system
Low counter signed by the top
IS 18001: Health management for accountability
and Safety b. Roles and responsibilities of all the
Management employees must be mentioned in the
System manual
c. Arrangement sections: All the Safe
operating procedures including
hazards associated with individual
activities and control measures,
procedure to conduct HIRA, EAIA,
Accident investigation, Management
of change etc. must be mentioned in

A safety committee is
available for the facility, and it
includes members from all
levels of workforce.
2 Safety Committee
3 Hazard A hazard identification and
Identification and risk assessment study has not
Risk Assessment yet been conducted for all the
activities.
the manual
2. The health and safety policy should be
displayed at prominent locations like
at the entrance of the plant and
reception area to show the
management towards health and
safety.
Currently, the pending points from the
previous safety committee discussion is
ISO 45001: Health carried on to the next safety committee
and safety meeting minutes, however it is suggested
Low Management to prepare an excel sheet of all the
system pending observations under one single
sheet for easy access and follow up of the
open points.
High System:
1. A cross-functional team (CFT)
including the production team,
safety team, QA team needs to be
formed and individual activities in
IS 18001 each of the plant area starting from
ISO 45001 raw materials storage and liquid
chemical storage needs to be
Health and Safety identified. (or can be done with
Management
external help)
System
2. All the types of hazards identified
for each activity need to be
addressed and the risk rating for the
hazards needs to be finalized by the
 CFT.
3. Prepare an action plan to complete
the control measures and the status
of the HIRA report can be discussed
in the safety committee meeting.

People:
Training must be provided to the selected
members of the health and safety team
on Hazard Identification and risk
assessment.
Awareness to the supervisors and
operators on the identification of risks
associated with their respective activities
like hot work, work at height etc.to be
provided.
Environmental Aspect Impact System:
study has not yet been done 1. An environment aspect impact
for the facility. analysis must be carried out.
2. It must quantify the impact on the
Environmental Environmental
environment due to different
4 aspect impact Low Protection Act,
analysis ISO 14001 activities.
3. Risk rating must be provided both
before and after the application of
control measures.

5 Accident/ incident Accident investigation was System:

reporting available in excel format. Medium 1. An accident investigation team can
ISO 45001 and be formed which can be same as the
Some of the observations are Factories Act safety committee members, by
1948
as follows:
1. Accident investigation
reporting was not readily
used.
2. A separate near-miss
reporting format is also 2. A simple format must be created for
not available
3. There is no culture of
reporting unsafe act and
unsafe conditions at the 3. A culture to report unsafe acts and
site by the
operational/process team.
4. Trend analysis study was
not conducted at the end
of the year.
4. Trend analysis study must be
providing specific training on
accident investigation using why-
why analysis or fishbone analysis.
This must also be added to the
training calendar
reporting unsafe acts and unsafe
conditions/ near miss in the plant
separately.
unsafe conditions needs to be
developed by sensitization and also
by providing Behavioral Based
Safety (BBS) Trainings from top to
bottom level
conducted at the end of the year to
identify the area or department with
maximum hazards and to identify
the focus areas.
(Safety indicators for analyzing
safety at site include the number of
accident/incidents, staff turnover,
absenteeism, employee workplace
grievances. All these indicators can
be analyzed for individual plant for
identifying the safety culture)

People:
 Training on Accident investigation can be
provided to selected people – to identify
root causes and methodology to device
control measures from why-why analysis.

6 Contractor Safety Contractor Safety Medium System:

management Management (CSM) document A contractor safety management
is not available for the plant. document must be created specific to the
aspects of the facility to ensure safe
working at site. The following points must
be checked while preparing contractor
safety management document.
1. Pre-qualification and contractor
selection
ISO 45001: Health  Pre-qualification criteria for the
and safety
contractors
Management
system  contractor selection criteria based
upon various safety parameters
 contract safety requirements
Contracted  Violation codes for contractors
Labour  Standardized HSE contract
(Regulation and
agreement
Abolition) Act
 Contractor liability insurance
2. Designing and Planning for Safety
 assessments tools for the pre-
planning and design phase
 procedures and protocols for the
pre-planning and design phase
3. Training and Orientation
 procedures and protocols for site
 inductions
 procedures and protocols for task
specific trainings
 Safe work procedures
4. On-site Contractor Monitoring
 procedures and protocols for
monitoring and evaluation of
contractors HSE performance
based on a schedule.
 Roles, responsibilities and formats
for reporting and evaluation of
Accidents / Incidents / near miss
 Handover / Takeover protocols
 procedures and protocols for
Contractor site management
safety meetings
 Protocols for Toolbox talks /
meetings on-site
5. Post-Contract Evaluation
 Procedures and protocols for post
work evaluation of contractors HSE
performance

7 Safe Operating 1. Standard Operating System:

Procedures procedures were available 1. Map the risk assessment study to
for all process activities Medium identify hazards pertaining to
Global Best individual activities. A section on
and Fire Equipment. The
Practice
Standard operating Hazards must be part of the SOPs.
procedures need to be The Procedures must also include
further upgraded as the
hazards associated with
individual activities were
not identified in the SOPs.
control measures for each of the
hazards mentioned.
2. SOPs must be included in the main
HSE manual. Categorization of SOPs
can be as follows:
1. General SOPs – Accident and injury
response, Equipment mounting and
dismounting, fire safety, first aid,
traffic control, managing hazardous
material, Housekeeping and
sanitation, lifting, vehicle operations,
working near high voltage lines, ETP
etc.
2. Fire Equipment – operating different
fire extinguisher, Fire alarm etc.
3. Work activities – Process based SOPs,
Boiler operations, SOP for reactors,
Handling of Class A chemicals,
Handling of Class B chemicals etc.
4. Special Activities – Work at Height,
Manual handling, hazardous waste
handling and storages, chemical
storage, loading and unloading, duct
cleaning, night work, lone working,
5. Equipment – tractors, trucks,
Portable hand tools, Air compressor,
Generators etc.
People:

8 Emergency A basic emergency response
Response Plan plan is available for the plant.
Some of the areas that needs
improvement are as follows:
1. Scenario for
Toxic/flammable gas
leakage. Spillage of
chemicals in large
quantities depending on
the type of chemicals has
not been properly
developed.
2. Evacuation map was not
made as a part of the
annexure.
3. The plant has not been
divided into zones and has
not been updated in the
emergency response plan
The concerned HODs with their team
members must be trained on the
developed procedures.
High System:
The current emergency response plan can
be further improved by focusing on the
following parameters mentioned below:
1. All the accidents and scenario of fire
and explosion due to
toxic/flammable gas release,
chemical spillage, static charge must
be made a part of the emergency
response plan
2. Evacuation map of the facility to be
added as an annexure to the ERP
The Factories Act 3. The zonal division like Zone 0, Zone
1948 1, Zone 2 must also be updated in
the ERP and a dedicated Emergency
response team and Emergency
Management team must be
identified to cater to the zones
identified.
4. Emergency response plan must be
updated at least once in every 2
years or whenever new activity-
related scenario is identified
People:

Procedure for permit to work
system was available. 5 types
of permit systems were
available. Some of the areas
that require improvement are
as follows:
1. There is only one copy of
the permit
9 Permit to Work 2. There are only common
checkpoints for all types of
permits whether it is for
hot work permit or
confined space permit
activity
The Emergency response team and
Emergency management team of
individual identified zones must be
briefed about their roles &
responsibilities. Simulation drills to be
planned and conducted for each zones
covering all identified scenarios in the
ERP.
System:
1. Provide at least 3 copies of the
permit system - one with safety
officer, one at the work site with the
worker and a third copy with the
IS 18001: Health area owner
and safety 2. The checkpoints for different types
Medium Management of permits must be separate and
system elaborate to individual work
permits.
 1. An yearly health check-up
records were available.
2. Lung function test has not
been done for the
Health Records and
10 employees.
Health Check-ups
The license for storage of
chemicals in the facility is
obtained currently for 2.5 KL
Petroleum License class A storage, however
for storage of onsite storage exceeded the
11
flammable limit.
materials (Application for extension of
quantity has been applied for
from 2.5kL to 12 KL, the final
license is yet to be obtained)
System:
As per Factory rules, for workers involved
in hazardous areas, health check-ups
must be carried out every 6 months and
must also include a lung function tests to
Medium The Factory Rules
identify any hazards due to inhalation of
the harmful chemicals.
System:
The final license for the storage of
chemicals must be obtained from PESO.
High Petroleum Rules
2. Fire Safety Management
Sr. Legal Reference
Area/Process Observation Objective Evidence Criticality Recommendation
No. (If Any)
Emergency lights have been System:
provisioned in the plant areas An exercise to be conducted by the plant
however the staircase team for the following:
illumination lights were not 1. Identify the exact requirement of all
functional. emergency evacuation lamps required
for the areas where they are missing.
E.g., Security room, Emergency
Assembly area and Main LT room
2. Create a documented record of the
emergency lights.
Emergency Lighting
1 NBC 2016 3. Recheck all the emergency lights for
System Medium
Volume1, part 4 their functioning and rectify any
Electrical safety issues if observed
4. Recheck the alignment of the existing
emergency lights to ensure that the
lights are focused on the exit
pathways and doors
5. Provide marking on the emergency
lights for easy identification.

2 Fire Pump Room, Information: System:

Pumps, Fire Hose 1. Underground Fire water 1. As per NBC, part 4, table 7 for an
reel and Sprinkler tank capacity of 50000 Industrial building in (G3- category), A
system liters was available. facility with covered area more than
2. There is no overhead fire 500 sq. meters must have an
 water tank
3. Sprinkler system has not
been provided inside the
plant for the office areas or
the RM storage areas.
Observation
1. There is no main pump or
DG pump available for the
facility.
2. The current pump capacity
is 7 cubic meter per hour
or 116.6 LPM which is
under capacity and cannot
be used for long term
firefighting.
4. There are no internal
hydrant points or first aid
hose reels available for the
plant.
5. There is only 4 external
hydrant point provisioned
for the facility.
6. It was observed that there
is no hydrant point
available for fighting liquid
fires near the CLASS A
storage and diesel storage.
underground fire water tank of
150000 liters capacity and an
overhead tank of 20000 liters
capacity.
2. Provision for a number of set of
pumps consisting of 2 electrical
pumps and a DG pump (stand by) of
capacity 2280 liters/minute each and
two electrical jockey pumps for
IS 3844: 1989 leakage correction of capacity 180
Extreme NBC 2016 Table 7
liters/ minute as per table 7.
3. Overhead fire water tanks to be
interconnected with each other. All
the fire water tanks to be labelled
with storage capacity.
4. Provision of internal hydrant point
and first aid hose reels for the plant
floors near the exit staircase on
individual floors.
5. External hydrant points must be
provisioned around the plant, with at
least one hydrant point for every 30-
meter distance. Provision for one
near the pantry area between the
two entrance gates and on the rear
side, as there is no space for
movement of fire tender in case of an
emergency.
6. Sprinkler system can be provided for
 the office areas and the RM storage
areas. Above chemical storage,
reactive to water, separate gas-based
suppression system can be provided.

7. An additional Fire hydrant point along

with foam trailer and multipurpose
combination nozzle for jet spray and
fog arrangement to be planned near
the liquid chemical storage area
(Class A), so that it can be used for
both the chemical storage area.
8. Installation of firefighting pumps
must be as per standard IS 15301:
Installation and Maintenance of
firefighting pumps
9. Certain good practices which must be
sustained are:
a. Cleaning of fire water tanks to be
done on yearly basis and the same to
be displayed on the tanks
 b. Individual fire pump operational
pressure charts to be displayed
c. Pressure gauge to be provided at the
farthest end of the hydrant line and
one more at any intermediate place
to record the pressure in the hydrant
line

People:
Safety sensitisation training needs to be
provided to the maintenance team on the
importance of firefighting equipment and
maintenance.

3 Portable Fire Information: High System:

extinguisher The plant has a total of 62 fire 1. Conduct a fire mapping of the plant
extinguishers to find the exact additional
requirement (quantity and type) of
Observation: fire extinguishers. Follow the below
1. Foam type fire guidelines for selection of fire
extinguisher are not IS 2190:2010 – extinguishers:
provided near the Selection,
 Transformer area has high oil
Installation and
transformer & DG area spill fire risk for which Foam
Maintenance of
along with CO2 based extinguishers are must,
Fire extinguisher
extinguishers because foam- based
2. There is no inspection tag extinguishers are utilized in
provided on the fighting surface fire (the kind of
extinguishers fire that spreads rapidly on oil
surface). Provision for a fire point
3. External extinguishers
outside the DG set area covering
were not provisioned
the DG area and the transformer
under proper shade which area. The fire point must have a
could lead to shelf-life
 deterioration.
4. There is no automatic
suppression system in the
server room
2. Provide inspection tags for all the
foam type extinguisher, CO2 type
extinguisher and sand buckets
 Electrical panels and electronic
items are sensitive so, in case of
an emergency, a CO2 extinguisher
will leave no residue and will not
cause further harm to the
equipment
 ABC extinguishers are the best-
known extinguishers to fight all
types of fire.
extinguishers for the ease of
identification of the date of
inspection and for periodic checking

3. Gas based clean agent automatic

suppression system is good for the
server room
4. As per IS 2190, extinguishers should
be placed every 15-meter radius even
in the plant area

People:
The Department In charge needs to make
ensure that the maintenance of fire

4 Smoke detectors Information:
and Fire Alarm Currently, the premise is
Control panel equipped with the wireless
type detection system
Observation:
There are many cons of these
wireless detection units:
 Additional number of
detectors cannot be added
to the loop, in case of an
expansion
extinguisher is based on the following:
 Location in designated place
 No obstruction to access or visibility
 Operating instructions on nameplate
legible and facing outward
 Safety seals and tamper indicators
not broken or missing
 Fullness determined by weighing or
lifting
 Examination for obvious physical
damage, corrosion, leakage, or
clogged nozzle
 Pressure gauge reading or indicator
in the operable range or position
Condition of tyres, wheels, carriage,
hose, and nozzle checked (for
wheeled units).
 Any observation identified must be
immediately reported to the safety
department
System:
To avoid such issues there are two
methods:
1. It is recommended to replace the
wireless detection unit system with a
FRLS cable wired fire detection
system integrated with a fire alarm
control panel that must be placed in
the security room (Emergency
Control Room) for 24 x 7 monitoring
and repeater panel at the reception.
2. An addressable panel is
 Battery Run out issues in
the detection unit
 Intermixing of detection
unit with the base and
resulting in wrong
indication in the panel
 Wireless alarm range
restriction and Power
backup
 Monitoring of detection High
units
1. There is no detection
system provisioned in the
electrical panel rooms,
servo room, office areas,
record rooms, UPS &
Battery storage rooms,
Raw Material storage
room 1 & 3.
2. AHU unit in plant area is
not connected to fire
detection system
3. Heat detectors were not
provisioned in the liquid
chemical storage area.
4. Manual call point was not
installed in the storage
room in block 58.
(Badminton Court)
5. The existing fire alarm
panel is not integrated
recommended considering the
number of detectors required.
Manual call points, Smoke detectors
can be connected to the same panel
and hooters.
IS 2189: 2009
Selection,
Installation and
Maintenance of
Automatic Fire·
Detection and
Alarm System-
Code of Practice
3. The fire alarm panel must be
connected with the fire dampers in
the ducts, access control doors &
AHU supplying multiple floors. In case
of an emergency, the fire dampers
must be in closed position and AHUs
eeshould be turned off to prevent the
spread of smoke.
4. Access control doors must be free to
open for easy evacuation during an
emergency
5. Heat Detectors are suitable for clean
burning fires, such as those involving
 with the access control
doors in the plant areas
and the fire dampers or
the AHU.
6. A log register is not
maintained at the security
room to record the alarms
and false alarms.
6.
7.
8.
9.
certain flammable liquids. Areas
subject to smoke, steam, dust or dirt
during normal use, fire that evolves
heat and flame rapidly, suitable for
rooms where heat producing
equipment like DG Area, class A
chemical storage, storage containing
any flammable chemicals,
kitchen/pantry.
Smoke detectors can be provisioned
in the electrical panel rooms, record
rooms, UPS & battery storage rooms
and office areas.
Manual call points must be
provisioned in all the building blocks
such as QC building & storage
building in block number 58.
(Badminton court)
The fire alarm panel must be
connected with the access control
doors in the plant area and the Air
Handling units. As soon as the fire is
detected, the access control doors
must disengage, and the air handling
units must turn OFF automatically to
prevent smoke from travelling to
different floors.
A log register must be available to
record all the alarms, to identify
 areas with maximum false alarms. It
will help in providing permanent
solutions to the false alarm.

Maintenance after Installation, As Per IS

2189
Daily inspection by User
A check should be made every day to
ascertain that:
a. The panel indicates normal
operation; if not, fault indicated is
recorded in the logbook and is
receiving urgent attention; and
b. Any fault warning recorded the
previous day has received attention.

Weekly Inspection
a. Once a week, at least one trigger
device or end of line switch on one
zone circuit should be operated to
test the ability of the control, further
indicating equipment to receive a
signal and to sound the alarm and
operate other warning devices.
b. A visual examination of the battery
and connection should be made to
ensure that they are in good
condition.
c. Any defect noticed should be
recorded in the logbook and reported
to the responsible person, and action
should be taken to correct it.

5 Exit Doors and 1. Only a single exit is
Evacuation available from the QC &
Office building blocks
2. The emergency exit from
the second floor in plant 2
was observed to be
obstructed due to AHU
ducts and other utilities.
3. Photoluminescent floor
marking not available for
exit routes.
4. Photoluminescent
evacuation maps were not
displayed anywhere at
prominent locations in the
plant.
Manual Call Points and Alarms
Every floor area must be provisioned with
Manual call points and fire alarms
installed near the exits and staircases.
These must be integrated to a common
fire alarm panel which can be installed in
the security control room at main gate.
Medium System:
1. Provision for alternative exit route
from QC building
2. The exit route from the second floor,
(plant-2) must have sufficient width
for the movement of people to the
exit staircase.
3. All the exit to be identified with
NBC 2016, Part 4
Fire and Life photoluminescent type exit marks and
Safety kept unobstructed. The routes to the
exits can be provided with photo
luminescent floor markings too.
4. Evacuation maps to be updated and
displayed throughout the plant area
 for individual areas. This can be of
Photoluminescent type

People:
The Department In-charge should be
made responsible to ensure that all the
exits are kept unobstructed and
unlocked.

Firefighting PPEs including System:

SCBA set, and fireman suit is in The plant must have SCBA set and
the stage of procurement and fireman suit. All fire-fighting equipment
is not yet available. Global Best must be available in the security control
6 Fire-fighting PPEs High Practice room or Emergency control room.

People:
The firefighting team must be trained in
the use of SCBA set.
3. Plant Site Safety

Sr. Legal Reference

Area/Process Observation Objective Evidence Criticality Recommendation
No. (If Any)
1. There is no secondary System:
containment for the diesel 1. Provision for secondary containment
storage area for the diesel storage area
2. Spillage of diesel was 2. Spillage of diesel must be cleaned
observed outside the open soon after any maintenance work in
Global Best
DG sets (Unsafe act) Practice the DG sets
3. The capacity of the diesel & 3. The capacity of the diesel tank must
1 DG Area High
tank was not displayed Petroleum Rules be displayed and the quantity of
outside and was observed storage inside must also be limited to
to exceed the licensing 990 liters.
limit.

2 Gas Cylinder 1. There is no mandatory High System:

Storage signage provisioned 1. As per Gas cylinder rules, Signage
outside the gas cylinder must be provisioned like “NO
storage area. SMOKING”, “FLAMMABLE GAS”,”NO
2. There was no lock and key MOBILE PHONES ALLOWED” must be
arrangement for the Gas cylinder Rules displayed.
cylinder storage outside 2. Provide lock and key arrangement for
the QC building. the gas cylinder storage

Note: There is a requirement for gas

cylinder license when the flammable gas
 storage exceeds 200kg and the number of
cylinders exceeds 25 in number
(Hydrogen cylinders)
3 ETP Area 1. Chemical labelling on the Medium System:
chemicals provided was 1. Chemical labelling on the chemicals
not as per the standards. must be as per standards. Sample
2. Secondary containment below.
was missing for the liquid
chemicals in the ETP area.
3. Lime storage in the storage
room was in contact with
the walls of the storage
room, which will
deteriorate the quality of
the walls. Global Best 2. Secondary containment or spill trays
Practices can be provided for the liquid
chemicals in the ETP area.

3. Lime storage must be separated from

the walls using acrylic sheets to
prevent deterioration of the walls.

People:
Training on handling chemicals and
dozing chemicals must be provided based
on the MSDS. Training on hazards
 associated with the chemicals must also
be known to the ETP operators.

4 Hazardous waste There is a dedicated High System:

storage (ETP sludge hazardous waste storage area The storage of the hazardous waste to be
and Used Oil) where the sludge waste was upgraded to meet the minimum legal
observed to be kept in the standards. The guidelines that must be
Badminton court area but it followed for storage of hazardous waste
was not build as per standards at site are as follows:
1. All the hazardous waste to be taken
and was not well ventilated.
out of the plant premise within 90
days from the last disposal
Hazardous Waste 2. Hazardous waste storage area should
(Management incorporate the following (sample pic
and shown below):
Transboundary  The storage area should have a
Movement) Rules
proper containment system. The
containment system should have a
collection area to collect and remove
any leak, spill, or precipitation
 It should be designed in such a way
that the floor level of the storage area
is at least 150mm above the
maximum flood level
 No open storage is permissible, and
the designated hazardous waste
storage area shall have proper
enclosures, including safety
requirements
 Proper stacking of drums/storage
 with wooden frames shall be
practiced
 In case of spills/leaks, sand and cotton
shall be used for mopping. NO WATER
to be applied
 Signboards with precautionary
measures to be displayed at
appropriate locations for normal and
emergency situations to be
introduced
 Manual operations within storage
area to be avoided to the extent
possible. In case of personnel use,
proper precautions need to be taken,
particularly during loading /unloading
of liquid hazardous waste in drums
 Portable extinguishers to be provided
 Storage areas should be provided with
adequate number of spill kits at
suitable locations. The spill kits should
be provided with compatible sorbent
material

The operators were not
provided with correct PPEs
5 Boiler area while working on the boiler
6 Badminton Court 1. The storage of chemicals in
Area (Chemical the badminton court was
storage) – plot observed to be unsafe,
no.58 (there were lighting
fixtures with joints above
the chemical storage).
2. Maximum quantity of
chemicals was not
displayed.
3. There is no electrostatic
dissipator provisioned
outside the storage area.
4. Secondary containment is
not provided for the
People:
Training on the hazards of the waste at
site and the handling of the waste must
be provided.
System:
The boiler operators must be provided
Medium The Boilers Act with boiler suits, goggles and heat-
resistant gloves while working on the
boiler
System:
1. All the lighting fixtures or electrical
fixtures in the storage area must be of
flame and dust proof
2. The maximum quantity of chemicals
stored must be displayed.
Extreme
3. Provision of electrostatic dissipator
outside the chemical storage area to
Petroleum Rules,
be done.
4. Secondary containment must be
provided for the chemical storage
 chemicals stored in the
area
5. Safety signages were not
provisioned for the
badminton court area.
6. Class A chemicals storage
was not as per standards.
7. Chemical compatibility
study was reported to be
completed however, not
displayed in the
badminton court area and
the liquid chemical storage
areas.
8. There is no automatic
detection or suppression
system in the badminton
court storage area.
7 Liquid chemical 1. Over-storage of chemicals
Storage Area was observed in the liquid
chemical storage area in
plot no. 58.
2. There is no secondary
containment for the
chemicals stored inside.
3. There are no Electrostatic
dissipation devices outside
to ensure that the people
handling the class A liquid
5. Provide warning signage like “No
Smoking”, “Danger – Flammable
chemicals” and mandatory signage
like the PPEs required for the area etc.
6. Class A chemical storage areas must
be well ventilated and must be as per
the storage in the liquid chemical
storage area.
7. Provision for heat detectors and
suppression system in the badminton
court storage area to be done.
System:
1. The chemical storage in plant
Extreme exceeded the capacity of storage and
were observed unsafely in the
badminton court area and in the
liquid chemical storage area. The
Petroleum Rules
storage must be taken to dedicated
warehouse area with proper
detection and suppression system.
2. Provision to be made for secondary
spill containment for class A storage
 are statically discharged.
4. Some containers of the
class A chemicals were
observed to be exposed
directly to the sunlight.
The containers were also
kept close to other
chemicals like HCL and
ammonia.
5. There was no safety
signage provisioned
outside the liquid chemical
storage area
and ensure that the containers are
properly earthed.
3. Electro-static dissipators with display
should be provided outside the class A
storage areas (Chemical storage areas
and plant areas wherever flammable
chemicals are handled). The earth pits
provided must be dedicated for static
charge dissipation and must not be
connected to other equipment
earthing.
4. The chemical containers (class A)
must be stored in a well-ventilated
area and away from direct sunlight,
external environment and all other
chemicals.
5. Provide warning signage like
“Flammable chemical storage”, “No
Smoking”, “No Mobile Phones
allowed” etc.
6. There are foam type extinguishers
provided outside. However, provision
 of foam type trailer can be made
which could be connected with the
hydrant system. (The capacity of class
A storage is more than 2000 liters)
covering both the liquid chemical
storage areas.

8 Raw Material 1. There was only single AC Medium System:

Storage running in the raw 1. In all raw material and FG storage
& Engineering material storage and was areas, it is recommended to provide 2
Store not provid\ed with auto- ACs with auto change over, so that
change over. (Running of a single AC would not function for 24
single AC for 24 hours over hours
time could result in 2. Storage and stacking of materials
Global Best
overheating of the must not be directly done under the
Practice
fan/compressor resulting
ACs or any other electrical fixtures.
in fire)
3. The maximum height for stacking
2. In Raw Material storage
must be set and the maximum height
area 2, Raw materials were
limit must be marked in the storage
observed to be stacked
directly under the AC room
3. Stacking height was not set 4. The chemicals must be stored away
in RM storage 1 from other combustible materials and
 4. The chemicals were not
segregated from other
combustible materials in
the engineering store
The workshop equipment
needs improvement. Some of
the observations are as
follows:
1. There was no flashback
arrestors provided for
the welding cylinders
9 Workshop 2. Housekeeping in the
workshop area was
observed to be poor
3. PPEs were not provided
for welding work-
Welding gloves, and
apron was not available
Fume hoods from the 1st floor
is released on top floor of the
building which is an accessible
10 QC building area.
11 Plant Areas 1. There is no secondary
containment for the raw
material storage area in
plant 2.
must be stored in its dedicated
location.
System:
1. Flashback arrestors must be provided
for the welding cylinders on the torch
and cylinder side
2. Housekeeping must be improved in
the workshop area.
3. Provide appropriate PPEs for the
Global Best
High
Practice workshop work like welding gloves,
and welding apron, safety goggles
while working on grinders etc.
System:
The fume hoods’ stack height needs to be
increased above the height of the
High Global Best building. The stack height of the DG set
Practice must also be increased above the height
of the building.
Medium System:
1. Provision for secondary containment
for the chemical storage area to be
made.
2. The isolation valve for the flammable
 2. The isolation valve for the Global Best solvent supply must be identified and
flammable solvent supply Practice marked for initial manual cut-off
was not identified and during an emergency.
marked.
People:
The team must be made aware of the
position of the isolation valve.

1. Acetone pumping was System:

observed without proper 1. Acetone pumping of any flammable
earthing and bonding. chemical pumping must be carried
2. The tools used for opening out with proper earthing and bonding.
flammable containers The earthing pit must be separate and
were not spark proof. must not be connected to any other
electrical equipment
Global Best 2. Spark proof drum openers must be
Vacuum Pumping Practice
12 High used.
Area

4. Emergency Response & Trainings

Sr. Legal Reference
Area/Process Observation Objective Evidence Criticality Recommendation
No. (If Any)
 Plant has identified and
displayed the list of emergency
responders at the entrance of
the plant.
The refresher training to the
security officers on the use of
extinguishers and hydrant
needs attention.
Emergency
1 Response Training
2 HSE trainings HSE trainings at site are limited
and are made part of other
trainings. There were only 3
dedicated HSE trainings in the
list of trainings.
System:
Identify plant personnel consisting of
plant management, technical, security,
administrative, support staff and plant
workers for:
1. First Aid team which should be
identified shift wise and should
consist at least 30% of plant
employees
2. Firefighting team which should be
identified shift wise and should
consist at least 40% of plant
employees
The Factories Act
High
1948 People:
Training to be provided to the plant
management, technical, security,
administrative, support staff and
identified plant workers
1. First Aid training should include CPR
and electrocution module
2. Basic Fire Fighting training using
portable extinguishers
3. Advanced Fire Fighting training using
fixed lines
4. Workplace safety & Behaviour based
safety awareness workshops
5. Situation based simulation drills
Extreme Global best Practice System:
HSE trainings must be separately mapped
in the training calendar and must include:
Behavioral based safety trainings (top to
lower management), Electrical safety
trainings (Basic & advanced), First Aid
trainings, Hazardous materials handling
trainings, Compressed Gas cylinder
trainings, Chemical handling trainings,
Static charge Hazards training.
5. Security Control & E-Vigilance
Sr.
Area/Process Observation
No.
1 Physical security Security Strength:
Day shift – 3 Guards
Night Shift – 4 guards
1. There is a basic SOP
available for security
purpose, however
situational emergencies,
code of conduct, List of
guards, security equipment
available are not completed
in the security SOPs.
2. The brick wall on the rear
side of block 58 were not
provided with concertina
wires
3. The duplicate keys available
are not well maintained and
marked
Legal Reference/
Objective Evidence Criticality Other requirement Recommendation
(If Any)
System:
A. The security manual must cover the
following broad topics:
1. Organization Structure and Function
2. Code of Conduct on:
 Public Statements and
Appearances
 Neglect of Duty
 Leaving Duty Post
Global Best  Sleeping on Duty
Medium Practice
 Use of Tobacco
 Use of Alcohol
 Possession and Use of Drugs
 Locked Cars and trucks
3. Duties and responsibilities
 Equipment and dress
 Patrol vehicle
4. Duty Schedule and Fitness for Duty
5. Reporting system
 Reporting internal violation
 Investigation of Alleged
misconduct
 Filing safety and security related
 incident reports
6. Issuance and Control of Keys
7. Security of Buildings and
warehouses
8. Responding to
situations/emergencies such as:
 Unidentified objects and
dangerous goods
 Fire, Earthquake, hazardous
material spills etc.
 Effective vehicular and baggage
checks
 Civil unrest and riots inside the
premise
 Security guarding and patrolling
B. Ensure that the perimeter wall is
brick wall compartmentalized
completely and provided with
concertina wires.
C. Duplicate keys must be available for
emergency purposes for all the
critical areas like the storage rooms,
electrical panel rooms etc. It must
be in a transparent glass box, name
tagged, and the security team must
be communicated priorly on the
keys available inside.

1. CCTV cameras were not
displayed in the security
room.
2. Some critical areas like the
liquid chemical storage area
(rear side) – plot 58, were
not covered under camera
surveillance.
2 CCTV
People:
Security team must be made a part of
emergency responders with dedicated
roles and responsibilities for each
Emergency scenarios without
comprising the duty at gate in an
emergency.
System:
1. Conduct a study to identify all the
critical areas wherever CCTV
surveillance is required. E.g.: All
storage areas, boiler electrical,
electrical panel rooms etc.
2. CCTV surveillance must be available
in the security room and n
NBC 2016 Vol 2 observation records must be
Low
maintained based on any findings on
CCTV cameras.
People:
Personnel responsible for CCTV must be
trained on emergency/security related
importance of CCTV like- relevance of
probing any incident by visualising CCTV
footage, reporting the CCTV breakdown
etc.